All information given to Roundstone Advisors, LLC ("Roundstone") and all recommendations and advice furnished by Roundstone to its clients will be kept confidential and will not be disclosed to anyone, except as Roundstone may so agree in writing or as may be required to do so by law.

Roundstone will collect non-public, personal information (NPI) about its clients as part of this engagement. This information will be obtained directly from the client and includes details such as the client's date of birth, social security number, financial account numbers and balances, tax returns, sources and amounts of income, home addresses and telephone numbers.

As part of Roundstone's policy, Roundstone restricts access to confidential personal information about its clients to those Roundstone employees who need to know that information in order to provide products or services to its clients. Roundstone maintains physical, electronic, and procedural safeguards to comply with federal standards to guard its clients' confidential personal information.

The firm will provide nonpublic information about former customers only if required to do so by law or regulation or to those parties who need such information in order for the firm to carry out any continued obligation with respect to the services covered by the former adviser/customer relationship. Should a client agree to accempt financial advisory services provided by Roundstone, Roundstone may share the client's NPI with non-affiliated third parties. Roundstone may maintain agreements with various affiliated or non-affiliated entities who may act as the custodian and account holder for customers of Roundstone and securities may be offered directly through those other broker-dealers properly engaged by Roundstone. These third-party institutions may require agreements to establish a Roundstone client's account with them. Roundstone will share only the appropriate customer NPI needed to facilitate these account agreements on behalf of its clients.

Should you prefer, Roundstone will not disclose confidential personal information about you to non-affiliated third parties. You may opt out of such disclosures; that is, you may direct Roundstone not to make those disclosures (other than disclosures required or permitted by law). Should you wish to opt out of disclosures to non-affiliated third parties, please contact the following number: (978) 635-3700.

Last revised: May 16, 2006