Prim Capital Disclaimer

CLEVELAND
Prim Capital Corporation
6500 Rockside Road
Suite 370
Independence, OH 44131
USA
Phone: 216.830.1111
Fax: 216.447.1938
Toll Free: 800.443.1290
E-mail:
contactprim@primcapital.com

BEACHWOOD
OFFICE
One Chagrin Highlands
Suite 200
Beachwood, OH 44122

NEW YORK
445 Park Avenue
9th Floor
New York, NY 10022

Disclaimers and Privacy Policy Effective July 15, 2000: Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage. The Information We Collect: This notice applies to all information collected or submitted on the Prim Capital Corporation website. On some pages, there may be places to make requests and register to receive materials. The types of personal information collected at these pages are: Name, address, e-mail address, phone number, comments, etc. The Way We Use Information: We use the information you provide about yourself when placing a request only to complete that request. We do not share this information with outside parties except to the extent necessary to complete that order. We use return e-mail addresses to answer the e-mail we receive. Such addresses are not used for any other purpose and are not shared with outside parties. We use non-identifying and aggregate information to better design our website and to share with advertisers. For example, we may tell an advertiser that X number of individuals visited a certain area on our website, or that Y number of men and Z number of women filled out our registration form, but we would not disclose anything that could be used to identify those individuals. Our Commitment To Data Security: To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.Our Commitment to Children's Privacy: Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13. How To Contact Us: Should you have other questions or concerns about these privacy policies, please call us at 216.830.1111 and ask for the compliance manager. Notice Regarding Entry of Orders and Instructions: Please do not transmit orders and/or instructions regarding your Prim Securities, Incorporated account(s) by e-mail. Orders and/or instructions transmitted by e-mail will not be accepted by Prim Securities, Incorporated, and Prim Securities, Incorporated will not be responsible for carrying out such orders and/or instructions. Notice Regarding Privacy and Confidentiality: Prim Securities, Incorporated reserves the right to monitor and review the content of all e-mail communications sent and/or received by its employees. Regulatory and Disclaimer Information for www.primcapital.com Regulatory Disclosure: Prim Capital Corporation is composed of several operating units, some of which are regulated by various federal and state regulatory bodies. Prim Advisors, Incorporated is registered as an investment advisor with the U.S. Securities and Exchange Commission. We do not render or offer to render personalized investment advice or financial planning advice through this medium. This medium is limited to the dissemination of general information on the service offerings of Prim Capital Corporation and its subsidiary companies and provides for an efficient mechanism in which a prospective client may contact us. Investment advice may only be rendered after the following conditions are met: Delivery of a disclosure statement (Form ADV Part II) by Prim Advisors, Incorporated to the client. Execution of an investment advisory and/or financial planning agreement between the client and Prim Advisors, Incorporated. Prim Advisors, Incorporated may conduct business only in States in which it is registered, or in which it is excluded or exempted from registration. Prim Advisors, Incorporated must also be registered or exempted or excluded from registration in any State in which it follows up on individualized responses to persons in that State that involve either the effecting or attempting to effect transactions in securities, or the rendering of personalized investment advice for compensation. Prim Securities, Incorporated is registered as a broker/dealer in investment securities with the National Association of Securities Dealers, Inc. (NASD). Prim Securities, Incorporated is a full-service investment banking and brokerage firm and is a member of the Securities Investor Protection Corporation (SIPC). Prim Securities, Incorporated may effect securities transactions only in States where Prim Securities, Incorporated, the client, and the product are registered or exempted or excluded from registration. Prim Securities, Incorporated maintains a fully-disclosed clearing arrangement with National Financial Services and Fidelity Registered Investment Advisor Group for the custody and execution of client funds and securities. We do not render or offer to render securities transaction services through this medium to prospective clients. Other Disclaimers: The information in this web-site is based on data gathered from what we believe are reliable sources. It is not guaranteed as to accuracy, and does not purport to be complete and is not intended as the primary basis for investment decisions. It should also not be construed as advice meeting the particular investment needs of any investor. The identification of specific funds and model portfolios is being made on the assumption that the investor would participate in that investment or portfolio on a long-term basis (in excess of five years) and only after consulting with their investment advisor to determine their needs and tolerance for risk. With respect to any such identification, there can be no assurance that the fund or model portfolio will in fact perform in the manner suggested. All investment and portfolio results assume the reinvestment of all dividends and are gross of any investment advisory fees. The results do not represent actual trading due to the timing of the clients' trades and their trading costs. They may also not reflect the impact that material economic and market factors might have had on the advisor's decision-making if the adviser were managing the clients' money. Investment and portfolio results may be different than the results our discretionary clients achieve due to the timing of trades by the advisor and the market conditions. All references that might be made to an investment or portfolio's performance are based on historical data and one should not assume that this performance will continue in the future.

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