We at Towneley Capital Management, Inc. have always placed an emphasis on your privacy and the importance of safeguarding your nonpublic personal information (“Personal Information”). This notice outlines our privacy policies and describes how we use your Personal Information.

Personal Information We Collect

We collect Personal Information (such as your name, address and social security number, etc.) from account applications or other forms you complete, as well as from communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect Personal Information about your accounts (such as your account balances and transactions) with unaffiliated third party broker dealers or custodians.

Personal Information We Disclose

We do not disclose any Personal Information about you to anyone except: (i) to further the business relationship we conduct on your behalf, and then only to persons necessary to effect the transactions and provide the services that you authorize (such as custodians, broker dealers, trustees, etc.); (ii) to persons assessing our compliance with industry standards (such as regulators and consultants); (iii) to our attorneys, accountants, and auditors (to the extent necessary); (iv) to protect against fraud, liability or damages to property; (v) to respond to judicial process or (vi) as otherwise permitted by law. We are permitted by law to disclose nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative services on our behalf). These third parties are prohibited from using or sharing the information for any other purpose.

Security and Confidentiality of Personal Information

We maintain physical, electronic and procedural safeguards that comply with federal regulations to protect your Personal Information.

We restrict access to your Personal Information to those employees who need to know that information to provide products or services to you. Our employees are prohibited, either during or after termination of their employment, from disclosing your Personal Information to any person or entity outside Towneley Capital Management, Inc., including family members, except under the circumstances listed above.

Our privacy policies apply to all current and former clients who have a direct customer relationship with us. In our management, we may provide your Personal Information to firms that assist us in servicing your account and have a need for such information, such as a custodian. These service providers agree to protect the confidentiality of your Personal Information and to use the information only for the purposes for which we disclose the information to them.

Thank you for choosing our investment advisory services. Please call us at (800) 545-4442, if you have any questions about our privacy policies.