PILOT Asset Management

PRIVACY NOTICE (REGULATION S-P)

Pursuant to Regulation S-P adopted by the Securities and Exchange Commission, it is the policy of Pilot Asset Management to keep confidential nonpublic personal information (“information”) pertaining to each current and former client (i.e., information and records pertaining to personal background, investment objectives, financial situation, investment holdings, account numbers, account balances, etc.) unless Pilot Asset Management is:

1) previously authorized by the client to disclose information to individuals and/or entities not affiliated with Pilot Asset Management, including but not limited to, the client’s professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment advisor account custodian, etc.);

2) required to do so by judicial or regulatory process; or

3) permitted to do so in accordance with the parameters of Regulation S-P. 

The disclosure of information contained in any document completed by the client for processing and/or transmittal by Pilot Asset Management in order to facilitate the commencement/continuation/termination of a business relationship between the client and nonaffiliated third party service provider (i.e. broker-dealer, investment advisor, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for Pilot Asset Management (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.  Each individual and/or entity affiliated with Pilot Asset Management is aware of Pilot Asset Management’s privacy policy, and has acknowledged his/her/its requirement to comply with same.  In accordance with the Pilot Asset Management privacy policy, each such affiliated individual and/or entity shall have access to information to the extent reasonably necessary for Pilot Asset Management to perform its services for the client and to comply with applicable regulatory procedures and requirements.