Worth Asset Management strongly believes in protecting the confidentiality and security of information we collect from you, our customer.

How and Why We Obtain Information
In order to facilitate the serving of your account, Worth Asset Management may receive nonpublic personal information about you from you or any of the following sources: 1) from your applications or forms (examples include name, address, social security number, driver’s license number, birth date, beneficiaries, assets and income) 2) from transactional activity in your account (examples include trading history and balances) 3) from verification services and consumer reporting agencies
(to ensure accuracy of application data, or to assess creditworthiness if you apply for our credit products) and 3) from other sources with your consent or with the consent of your broker dealer.
We verify our customer’s identity to actively prevent, deter, and detect illegal financial activity. As of October 1, 2003, pursuant to the USA Patriot Act, all customers who open new accounts with Worth Asset Management will be required to provide identification verification documents to help establish their identity including your driver’s license or other identifying documents.

Nonpublic Personal Information We Disclose
We do not disclose the nonpublic personal information we collect about our customers to anyone except:
1. in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.)
2. to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.)
3. our attorneys, accountants, regulatory agencies and auditors
4. as otherwise provided by law*
We do not disclose the nonpublic personal information we collect about our former customers to anyone except:
1. to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.)
2. our attorneys, accountants, regulatory agencies and auditors
3. as otherwise provided by law*
* We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose. If you decide at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time.
We maintain records containing nonpublic information of former customers for the required retention period by federal and state securities laws. After that time, information may be destroyed.

How We Protect Your Information
Worth Asset Management has always considered the protection of sensitive information to be a sound business practice and a foundation of customer trust. We employ extensive information protection controls in keeping with industry standards and practices, and we regularly adapt these physical, electronic and procedural controls to respond to changing requirements and advances in technology.
Within Worth Asset Management and among our service providers, we restrict access to your information to those who require that access in order to provide products and services to you. We do not sell your personal information to anyone. We may share the personal information that we collect about our customers, prospects or former customers with their broker dealers or with:
Affiliates–including affiliated service providers (for example, our data processing company, Internet backup provider and printing operation). You do not have the option to opt out of information provided to Affiliates.
Unaffiliated service providers (for example, fulfillment companies and securities clearinghouses). We do not share information with Unaffiliated service providers.
Government agencies and law enforcement officials (for example, for tax reporting or under court order)
Other organizations, as permitted by the laws that protect your privacy (such as fraud prevention)
Other organizations, with your consent or as directed by your financial advisor (for example Worth’s performance reporting company)
Other employees with a valid business reason have access to your personal information. These employees are educated on the importance of maintaining the confidentiality and security of this information. They are required to abide by our information handling practices.
Your personal investment advisor with Worth Asset Management has access to your nonpublic personal information. This access is gained through copies of new account forms and/or access to vendor or custodial firm (National Financial Services and TD Ameritrade) systems that display this information. In the event of your investment advisor leaving or terminating his or her registration with Worth Asset Management it is likely he or she will maintain your nonpublic personal information and may use this information in his or her attempt to transfer your account to his or her new firm. Note, upon termination Worth Asset Management will cancel all logon permissions the advisor was granted with Worth’s custodial firms.
The law allows you to “opt out” of only certain kinds of information sharing with third parties. Worth Asset Management does not share personal information about you with any third parties that triggers this opt-out right. This means YOU ARE ALREADY OPTED OUT.

Privacy Online
Worth Asset Management considers privacy, security and service to be just as critical in the online environment as in the rest of our operation. We therefore employ all of the safeguards described above, along with the following Internet-specific practices:
Worth Asset Management, along with its custodial firms use a variety of proven protections to maintain the security of your online session. For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures. We also use cookies and similar files that may be placed on your hard drive for security purposes, to facilitate site navigation, and to personalize the appearance of the site. When we conduct business online, we may collect technical and navigational information, such as computer browser type, internet protocol address, pages visited, and average time spent on our Website. This information may be used, for example, to alert you to software compatibility issues; or it may be analyzed to improve the Web design and its functionality.

Access to Your Information
You may access your account through a variety of media offered by Worth Asset Management and our custodial firms (ie. statements or online services). Contact your investment advisor if you require any additional information. Please direct any questions you may have regarding this notice to Worth Asset Management Inc., attention Jim Clark, 16660 Dallas Parkway, Suite 2200, Dallas TX 75248, by telephone to (469) 916-4287 or by email to jclark@worthassetmgmt.com .