Privacy

Pursuant to the rules established by the Securities and Exchange Commission, this Notice is intended to provide you with our firm’s policy regarding privacy.  Bloom Asset Management does not disclose, sell or provide information of a non-public, personal nature to any individual, firm or business, other than the Custodian of your assets (Fidelity Investments) and except as otherwise provided herein.  The information provided to the Custodian is limited to the information necessary in order to open your account and to execute purchases, sales and other types of similar transactions.

In the course of providing investment management services, we generally obtain the following confidential and non-public information:

Date of Birth

Social Security Number

Account Information Regarding Investments

Income

We may also collect and review other information that we deem relevant to provide investment advisory services. Such other information may include tax returns, estate planning documents and other similar information.  We provide access to non-public, personal information about you only to those employees who need to know that information to provide services to you.  We maintain physical, electronic, and procedural safeguards that comply with Federal standards to guard your non-public, personal information.  Our staff is advised that the information about your account, your assets and all other confidential information must be maintained in the strictest confidence.  Unauthorized disclosure of the information is unacceptable.

In general, the members of our staff are authorized to have access to your account and your account information only for the purposes needed to provide investment management services.

Confidential information may under limited circumstances, be shared with employees of Bloom, Bloom & Associates, P.L.C.

Other than as provided herein, we do not disclose any non-public, personal information about our customers, or former customers, to anyone except as permitted by law.

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