HM Capital Management, LLC (HM), places the highest priority on protecting its clients’ privacy. In the course of doing business with HM, clients need to share financial information and may be asked to provide other details. Clients can be assured that HM is diligent in its efforts to keep these communications confidential. We do not disclose our clients’ nonpublic individually identifiable personal information to anyone except as permitted by law or upon client consent, and we restrict access to this information to our personnel who are necessary or appropriate to provide products or services to you. Moreover, we maintain various physical, electronic and procedural safeguards to guard your nonpublic personal information.

The following is an explanation of certain of the policies adopted by HM in order to maintain the privacy of your nonpublic individually identifiable personal information. This notice refers to HM Capital Management, LLC by using the terms “we,” “our,” or “us.”

Nonpublic individually-identifiable personal information includes much of the information you provide to us and the related information about you and your transactions involving your HM investment services. Examples of nonpublic individually-identifiable personal information include the information you provide on new account applications for HM investment services, your share balance or transactional history.

As noted above, we place the highest priority on protecting the privacy of our clients’ financial information and other personal details. The steps we take include:

● A corporate policy for employees. HM employees understand that they must maintain the integrity of personal and financial information that they come across when communicating with clients and processing requests. We restrict access to nonpublic personal information about you to personnel who are necessary or appropriate to provide products or services to you. They are required to refrain from disclosing any confidential information or materials to unauthorized persons.

● Contractual commitments. HM hires firms that assist us in delivering services to clients including, but not limited to, CLJM, LLC (d/b/a Huntleigh McGehee). These firms contractually commit to protecting the privacy of any HM client information that they review or handle.

The information we gather is used for internal purposes only to help us find ways to better serve clients and to enhance our products and services. HM may use the information we collect to send notices to clients about products and services that we believe may interest them. But the information gathered on clients is not sold to other firms, such as direct marketers. The details HM collects will not generate any correspondence, e-mails, or phone-calls from unaffiliated marketers.

HM may have to provide information about clients to the Securities and Exchange Commission or other regulatory agencies, or as otherwise required by law. We also share client information with firms that we have contracted with to deliver services to our customers. We do not disclose any nonpublic individually-identifiable personal information about our clients or former clients to other parties, except as permitted by

law or upon client consent. As noted above, however, these firms have contractually committed to protect the confidentiality of all the HM client information to which they have access.

With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

For questions about our policy, or for additional copies of this notice, please write us at HM Capital Management, LLC or call us at 314-746-1700.