S.L. Hare Capital, Inc.

                                                    Privacy Policy

Effective 1/23/2008

Our Commitment to Privacy

S L Hare is committed to protecting the confidentiality of nonpublic personal information of our clients. It is our goal to maintain procedures that ensure the information we collect, will always be secure.

S L Hare Capital collects the following information:

Name

Address

Telephone

Social Security Number

Assets

Employer

Employment status

Marital status

Any other personal information we deem relevant to provide a specific service

S L Hare Capital uses the information for the following purposes:

To complete the account application process

To establish credit worthiness

To evaluate risk tolerance

To ensure accuracy in reporting and record keeping

S L Hare does not have affiliates and does not intend to share nonpublic personal information with nonaffiliated third parties except to nonaffiliated parties as authorized by law or to nonaffiliated third parties whom it has contracted to perform services on its behalf, such as printing, mailing, fraud prevention and processing services. S L Hare will enter into a contract with each service provider and require the service provider to preserve the privacy of the information. The contract will state that the information may only be used for the specific services rendered

Internet data security polices restricts access of nonpublic information to authorized employees.

S L Hare Capital’s clearing firm Pershing, maintains physical, electronic and procedural safeguards that are designed to comply with standards to guard nonpublic personal information. Employees who violate these polices are subject to disciplinary action, up to and including termination.

Should you have any questions concerning these privacy policies, please call us at (310) 479-1680.