High Speed LLC, (referred to as “HSA”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, HSA attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of HSA to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/non-affiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of HSA. In that regard, HSA may disclose the client’s information: (1) to individuals and/or entities not affiliated with HSA, including, but not limited to: the client’s other professional advisors and certain service providers that may be recommended or engaged by HSA in furtherance of the client’s engagement of HSA (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, etc.); (2) where HSA is required to do so by judicial or regulatory process; or (3) where HSA is otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by HSA to facilitate the commencement/continuation/termination of a business relationship between the client and/or between HSA and a non-affiliated third party service provider (i.e., broker-dealer, investment advisor, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of HSA (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third party service provider.

HSA permits only authorized employees and affiliates who have signed a copy of HSA’s Privacy Policy to have access to client information. Employees violating HSA’s Privacy Policy will be subject to HSA’s disciplinary process. Additionally, whenever HSA hires other organizations to provide services to HSA’s clients, HSA will require them to sign or provide confidentiality agreements and/or Privacy Policies.

Should you have any questions regarding the above, please contact Dr. Forrest Bryant, Chief Compliance Officer, at drb@highspeedalliance.com or (256) 642-1230.