NOTICE OF PRIVACY POLICY

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Why and How We Collect Personal Information:

CWV is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. The categories of nonpublic information that we collect may include information about personal finances, information about health to the extent that it is needed for the investment management process, and information about transactions between the client and third parties. We use this information to help our clients meet their personal financial goals.

With client permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom the client has established  a relationship. Our client may opt out from our sharing information with these non-affiliated third parties by notifying us at any time by telephone, mail, fax, Clutinger, Williams & Verhoye, Inc. email, or in person. With client permission, we share a limited amount of information about them with their brokerage firm in order to execute securities transactions on their behalf. We maintain a secure office to ensure that client information is not placed at unreasonable risk.

We employ a firewall barrier, secure data encryption techniques, and authentication procedures in our computer environment. We do not provide client personal information to mailing-list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to client personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and client personal records as permitted by law. Personally identifiable information about clients will be maintained while they are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed. We will notify clients in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to clients annually, in writing.

We collect information that assists us in servicing your financial needs. This information helps us provide you with a high standard of customer service, process your transactions, provide products that may interest you and fulfill legal and regulatory requirements. The personal information we collect includes information collected on applications and related forms such as, name, address, social security number, bank reference, annual income and net worth.

How We Protect Information:

Our employees maintain and protect the confidentiality of your personal information by utilizing physical, electronic and procedural safeguards.

Disclosure of Information:

Non-affiliated third parties – We may disclose any personal information to or as directed by your broker or when we believe it necessary for the conduct of our business, or where law requires disclosure. For example, personal information may be disclosed for audits, to attorneys or other professionals, or to law enforcement and regulatory agencies as necessary to protect our property or rights. In addition, we may disclose personal information to third party service providers such as mutual fund companies and clearing firms to enable them to provide business services for us by performing computer related or data maintenance or processing services, to facilitate the processing of transactions requested by you, and to assist in offering products and services. Except in those specific, limited situations, without your consent, we will not make any disclosures of your personal information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or any marketing agencies. Clutinger, Williams, & Verhoye, Inc. policy requires all third parties to sign strict confidentiality agreements. 

Former Customers:

This policy applies to former customers as well as current customers.

Maintaining Accurate Information:

We strive to maintain complete and accurate information on you and your accounts. We will give you reasonable access to the information we have about you. If you have a question or concern about your personal information or this privacy notice, please contact us. 

Further Information:

We reserve the right to change this Privacy Policy. The examples contained in this Privacy Policy are illustrations and they are not intended to be exclusive.  This notice complies with Federal law and SEC regulations regarding privacy.This notice is being furnished on behalf of Clutinger, Williams, & Verhoye, Inc. registered with the Securities & Exchange Commission, which requires assets under management of at least $100 million. If you have accounts managed by Clutinger, Williams, & Verhoye, Inc. please click here for a copy of our Form ADV, Part II.