Fortress Capital Management (FCM) recognizes and respects the privacy expectations of its clients. FCM considers clients' data to be private and confidential, and holds itself to the highest standards of trust and fiduciary duty in their safekeeping and use. FCM has not and will not sell personal information to anyone.

FCM collects non-public personal information about clients from the following sources:
• Account Applications and other Forms, which may include a client's name, address, telephone number, Social Security number, and information about a client's investment goals and risk tolerance;
• A Client's Professional Advisors such as consultants, attorneys and accountants, who may provide financial, investment history and tax information about a client;
• Account History, including information about the transactions FCM has ordered and balances in various accounts; and
• Correspondence, written, electronic or telephonic, between a client and FCM or a client's broker or custodian and FCM.

FCM will not release client account information to any third party unless one of the following conditions is met:
• FCM receives prior client consent;
• FCM believes the recipient to be the client or the client's authorized representative, including the client's attorney or accountant;
• The recipient is a broker, custodian or other service provider with whom FCM must share information in order to manage or service a client's accounts properly;
• FCM is permitted or required by law to release the information to the recipient.

FCM will only use information about a client and a client's account(s) to:
• Help FCM better serve the client's financial needs,
• Suggest services or other materials that may be of interest to the client,
• Fulfill our regulatory obligations, and
• Administer FCM's business.

FCM applies the policies and practices described in this notice to both current and former clients.