Performance Tracking Inc. recognizes that you expect your personal information to be handled in a confidential manner and we have, therefore, adopted the following policies to safeguard your privacy and to explain the circumstances under which we may collect, maintain and use any non-public personally identifiable information that you may provide to us. We collect information about you to help us and our custodian firm(s) perform our duty as a registered investment advisor and to fulfill applicable legal and regulatory requirements. The type of information we gather may include the following: Information we receive from you on account opening applications or other forms, such as your name, address, social security number, employment and marital status, beneficiary designations (if applicable) income and liquid asset value. Information about your transactions with us, such as your account balances, correspondence with us, and payment history.

We do not share any non-public personal information about you with unaffiliated third parties unless 1. You give us written permission; 2. It is necessary to process your account application or service your account(s) or otherwise complete a transaction on your behalf; 3. It is necessary to protect against fraud or to comply with a subpoena or other court order; or 4. It is otherwise required or permitted by law or regulation. However, we do provide information to our custodian firm(s) or broker dealer(s), who have adopted similar privacy policies, government or regulatory agencies and certain service providers. These companies and agencies are not permitted to use or share this information for any purpose, and will also maintain such information as confidential.

We do not disclose any non-public, personal information about you to any outside unaffiliated company, except as permitted by law or as needed to service your account. Furthermore, we maintain physical, electronic and procedural safeguards to protect your non-public information.