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Regulation S-P, Privacy of Consumer Financial Information, requires financial institutions including Investment Advisers, to provide notice to current clients and prospective clients about their privacy policies and practices to all existing clients a privacy disclosure policy notice.

Privacy Disclosure Statement
Custodio Asset Management's primary client goal is to protect your privacy. We do not sell your personal information to anyone.

To conduct regular business, we may collect nonpublic personal information from sources such as information reported by you on applications or other forms you provide to us as well as transactions with us, our affiliates, or others.

We may enter into contracts with third parties so that they can assist us in servicing your account. We disclose personal information to companies that help us process transactions for your account (for example, executing your trades at an exchange or prime broker).

Custodio Asset Management does not share or disclose any nonpublic personal information about its current or former Clients, except as permitted by law. All information will remain confidential.

We may disclose or report personal information in limited circumstances where it is required by law. For example, we may be required to disclose personal information to cooperate with regulators or law enforcement authorities, to resolve consumer disputes, to perform credit/authentication checks, or for institutional risk control. All information will remain confidential.

Information Safeguarding
Custodio Asset Management will internally safeguard your nonpublic personal information by restricting access to only those employees who provide products or services to you or those who need access to your information to service your account. In addition, we will maintain physical, electronic and procedural safeguards that meet federal and/or state standards to guard your nonpublic personal information.

Additionally Custodio Asset Management will include in our client brochure, the above listed disclosure notice, so that all prospective clients may review our Privacy Disclosure notice upon receipt.