GLOBAL BUSINESS MANAGEMENT, INC.

PRIVACY POLICY STATEMENT

The relationship with our clients is our most important asset. We understand that you have entrusted us with your personal and financial data. We consider our clients’ data to be private and confidential, and we hold ourselves to the highest standards of trust and fiduciary duty in their safekeeping and use. The following describes our firm’s privacy policy.

We do not sell your personal information to anyone.

We collect nonpublic personal information about our clients from the following sources:

• Tax Organizers, Account Applications and other Forms, which may include a client’s name, address, social security number, and information about a client’s investment goals and risk tolerance;
• A Client’s Professional Advisors such as attorneys and accountants, who may provide financial, investment history and tax information about a client
• Account History, including information about the transactions we have ordered for you and balances in your account;
• Correspondence, written or telephonic between you and us or your broker or custodian and us; and

Information we receive from a consumer reporting agency.

We will not release information about you or your accounts to any non-affiliated third party unless one of the following conditions is met:

• We receive your prior consent
• We believe the recipient to be you or your authorized representative, including your attorney or accountant
• The recipient is a broker, custodian or other service provider with whom we must share information in order to manage your account properly
• We are required by law to release the information to the recipient

We will only use information about you and your accounts to:

• Help us better serve your investment and financial needs
• Suggest services or other materials that may be of benefit to you, from affiliated corporations; Global Business Management, Inc., Global Financial Advisory Services, Inc., and Garelick, Wilkerson & Associates, Inc., and
• Administer our business.

We restrict access to nonpublic personal information about you, as much as possible, to those employees who need to know that information in order to provide our services to you. We also maintain physical, electronic and procedural safeguards to guard your nonpublic personal information.

We will adhere to the policies and practices described in this notice whether you are a current or former client.

We may revise our privacy policy in the future. If you would like a current copy of our privacy policy, you may call us at (818) 385-3100.