PRIVACY POLICY DISCLOSURE

This privacy policy disclosure applies to customers of Valcour, Inc., or any partnership that is managed by Valcour, Inc. ("Valcour") or that transact investment products through a representative of Valcour.

As a customer of Valcour, we respect your desire for privacy in your financial affairs.  This privacy notice is intended to comply with Regulation S-P of the Gramm-Leach-Bliley Act, and explains how we may use information about you, while at the same time protecting your privacy. 

What information do we collect?       

We collect nonpublic personal information about you from the following sources: 

Information we receive from you on applications or other forms; an example of this type of information would include but not be limited to, name, social security number, assets, income, liabilities, etc.; 

Information about our transactions with us, an example of this type of information would include but not be limited to; account balances, security positions, etc. 

What information do we disclose? 

We disclose nonpublic personal information about you to partnership entities managed by Valcour, mutual fund companies, clearing brokers and insurance companies when you direct us to effect transaction with such companies on your behalf.  In these situations, we only disclose the information that is necessary to complete the transaction or to service your accounts with such companies. 

We may also disclose all the nonpublic personal information that we collect about you to nonaffiliated third parties as permitted or required by law.  For example, we may disclose nonpublic personal information about you when or if,

You consent to the disclosure.

It is necessary to protect the confidentiality of your information.

It is necessary to provide the information to our attorneys, accountants and auditors.

Disclosure to law enforcement authorities is required or permitted by the Right to Financial Privacy Act or other laws.

It is permissible under the Fair Credit Reporting Act to report such information to a consumer-reporting agency.

We ever engage in a merger or sale of our business, and the disclosure is necessary to complete such a transaction.

The disclosure is necessary to be in compliance with state or local laws or regulations.