RAFFERTY CAPITAL MARKETS, LLC

Privacy Policy

Rafferty Capital Markets, LLC ("RCM") has adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that our customers expect us to service them in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about them.

Information We Collect

In connection with providing our customers with investment products, financial advice, or other services, we obtain nonpublic personal information about customers including:

• Information we receive from customers on applications, in person, by telephone, electronically or by any other means, such as their name, address, social security number, assets, debt and income.
• Information about the customer's transactions with us or others, including their financial adviser; and
• Information from credit or service bureaus or other third parties.

Information We Disclose

We will not disclose information regarding our customers or their account with us except under the following circumstances:

• To the customer's financial adviser and their manager;
• To establish or maintain an account with an unaffiliated third party, such as a clearing broker providing services to the customer and/or RCM, or to service the customer's account as authorized;
• To government entities or other third parties in response to subpoenas or other legal process as required by law;
• To our affiliated companies as permitted by law;
• To companies that perform marketing services on our behalf, or to other financial institutions with whom we have joint marketing agreements, that are restricted from disclosing your personal information except as permitted by law;
• And as otherwise permitted by law.

Our Security Policy

Only those individuals who need it to perform their jobs are authorized to have access to confidential customer information. We maintain physical, electronic, and procedural security measures that comply with applicable state and/or federal regulations to safeguard confidential customer information.

Closed or Inactive Accounts

If a customer decides to close their account(s) or become an inactive customer, we will adhere to the privacy policies and practices then in effect.

Changes to this Privacy Policy

If we make any substantial changes in the way we use or disseminate confidential information, we will notify our customers prior to implementing such change with respect to that customer.

Distribution to this Privacy Policy

Rafferty Capital Markets will distribute this Privacy Policy to all customers of the broker with a cover letter annually on the 30th of June.