Privacy Policy and Notice

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We at Fredric E. Russell Investment Management Co. (FERIMC) have implemented policies and procedures to safeguard the nonpublic personal information of all our clients.  Our priority is maintaining your trust and confidence in our firm; protecting your personal information is critical to our commitment.  This Privacy Policy and Notice have been established to ensure that information about our and prospective clients is treated appropriately.  We do not disclose any personal information to anyone outside of FERIMC unless it is a fully vetted third-party service that assists us.  Additionally, we do not allow client information to leave our office, and all files are locked, secured, or shredded, if applicable.  This notice is relevant if you are a current client or have been contacted about our services.  It describes our practices and policies regarding the handling of your information.  The personal information that we collect, maintain, and disclose includes personally identifiable financial information about you that we obtain in connection with providing financial services to you, including:  - Information that you provide us to open an account (such as your address, phone number, and financial information). - Information we generate to service your account (such as trade tickets and account statements). - Information about your transactions with us; and - Information we may receive from third parties regarding you or your account (such as trade confirmations from Schwab or information from consumer reporting agencies).  We regard nonpublic personal information as data that includes your name, address, telephone/fax numbers, e-mail addresses, Social Security number, assets, income, investment objectives, risk tolerance, account numbers, account balances, transaction history, beneficiary information, bank account information, credit card information, as well as any health and medical information.  We may share nonpublic personal information with non-affiliated third-party providers that assist us in servicing your account.  These parties may include financial service providers (such as companies that perform services on our behalf, including compliance regulators and portfolio management software assistance), non-financial companies (such as our technology consultants who assist us in maintaining our computer systems), and other non-affiliated third parties to whom disclosure of nonpublic personal information is permitted by law (such as the Internal Revenue Service for tax purposes).  We only share your nonpublic personal information as current federal and state statutes and regulations permit.  We will not share your nonpublic personal information with non-affiliates.  If you close your account(s) or become an inactive client, we will adhere to this Privacy Policy concerning your nonpublic personal information.  Nonpublic personal information about former clients will not be treated differently from our current clients' information.  To protect your personal information, we take several measures.  We ensure that client and company-related information remains confidential and that our staff refrain from discussing client relationships outside the office.  Physical client files are organized, secured, and locked safely.  Employees keep client-specific information from the plain sight of office visitors.  We do not disclose any detailed "personally identifiable information" to any individual, group, or reporting agency without the client's consent, except where required by law or whenever deemed necessary to transact business on behalf of the client.  FERIMC operates a cloud-based work environment.  If you have any questions about our privacy policy, please contact the firm's chief compliance officer at (918) 743-5959.