1.  Capstone Futures Group obtains and/or maintains nonpublic personal information regarding each client such as, but not limited to, social security number, occupation, income level, net worth, account number and account status.

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2.  Capstone Futures Group and its principals and employees shall not disclose any nonpublic personal information regarding its existing and past clients to any third party except as permitted by law, such as lawyers, accountants, auditors and regulators. 

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3.  Capstone Futures Group will restrict access to clients’ personal information to those employees who need to know such information in order to provide services to clients.  Capstone Futures Group will maintain physical, electronic, and procedural safeguards to guard each client’s personal financial information.  Such safeguards include:

• restricting the use of any personal information to each client’s personal account executive, that person’s supervisor and such other persons as the CCO deems as needing to know the information, 

• hard copies of clients’ personal information will be maintained in Capstone Futures Group’s central files, and will be secured (locked) after normal business hours,

• electronic access to client personal information will be restricted via passwords and

• ·whenever an employee leaves Capstone Futures Group any password or code used to gain access by that employee is extinguished or changed.

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4. Each client will initially be provided with a copy of Capstone Futures Group’s privacy policy by receiving a copy of its Disclosure Document that contains a notice therein. 

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5.  Capstone Futures Group will provide notice to its clients on an annual basis that states the following:

We consider privacy to be fundamental to our relationship with you.  In order to invest with the Advisor you must provide us with personal information about you, such as your occupation, income level and net worth.  We collect this information to know who you are so that we can meet our obligations under the laws and regulations that govern us.  It is our policy and practice to respect your privacy and to protect all personal information entrusted to us.  Our employees will only have access to such information if they need to know in order to service you on behalf of the Advisor.  We also do not disclose any nonpublic information about our clients or former clients to third parties except as permitted by law, such as lawyers, accountants, auditors and regulators.

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6.  Annual notice will be provided every year by March 30. Capstone Futures Group will send such notice by US Mail, registered, return receipt requested or by courier service.  Capstone Futures Group will keep a copy of the cover letter and the return receipt/courier notice in the client file.