When an account is opened with R.N. Croft Financial Group Inc. (the Croft Group), there is certain personal information that must be collected and must be kept on file with our office in accordance with the regulatory requirements of our industry.

Personal information provided allows for verification of identity and further allows us to protect a client against possible fraud. Furthermore, the information colleted allows the Croft Group to better determine a clients’ investment objectives based on their individual situation.

The Croft Group recognizes the importance of maintaining high standards for confidentiality and handling of client information, therefore; the Croft Group will make every effort to ensure that only authorized parties have access to a clients’ personal information.

I) Disclosure of Personal Information

The Croft Group Inc. may outsource backoffice and administrative services to various providers that relate to the custody, trade execution, administration and/or reporting on behalf of the accounts managed by, or reported on, by the Croft Group.

As such, the Croft Group may from time to time disclose a clients’ personal information to these external sources. This may also include various financial institutions and other parties who provide services to the Croft Group and its’ client. The Croft Group may also rely on personal information collected and provided by external sources. An example would be in the case of a transfer of assets between institutions.

The Croft Group will collect and use a client’s personal information only for the purpose for which it was intended or for a use consistent with that purpose.

Procedure:

• All employees of the Croft Group must sign a confidentiality agreement as part of their terms of employment.

• No employee or affiliate is permitted to disclose or discuss clients’ personal information or affairs with non authorized individuals or entities. 
  Where “non authorized” means – parties that do not have an interest in the account; parties that do not provide services to the Croft Group for the benefit of the client or parties where express direction from the client allowing the release of such information, has not been received by the Croft Group.

• The Croft Group requires a clients consent before we disclose personal information to third parties and the client may cancel and/or change the release of such information at any time by providing written notification to the Croft Group.

• The Croft Group does not require a client’s consent for the collection, use and disclosure of personal information where such information is reasonably required in the normal course of servicing and managing a client’s account; or to securities regulators, auditors, legal counsel, or law enforcement agencies.

• A client that chooses to open an account with the Croft Group is providing consent to the Croft Group to collect, use and disclose the information as outlined in this Privacy Policy Agreement.

II) Retention of Personal Information

If a client terminates their account and/or management agreement, the Croft Group may retain a client’s personal information on file for a period equal to or greater then the retention period as required by regulators.

For questions or clarification of items, please contact us directly.