POLICY STATEMENT ON PRIVACY AND SECURITY

Hutchinson Capital Management (HCM) does not disclose, and does not wish to reserve the right to disclose, any nonpublic personal information about our customers or former customers to anyone, except as required by law. At HCM, we will use the term client when we establish a customer relationship with you.

COLLECTING AND SHARING INFORMATION

In the course of providing advisory services, HCM acquires information about you, both from you and from other sources. Categories of nonpublic personal information that HCM collects includes information we receive from you on applications or other forms, and information about your transactions with HCM and non-affiliated third parties. For example, you give us your social security number, date of birth, and other such facts. A broker or bank with which we transact business on your behalf may give us such information as account numbers, start date of accounts, and details of specific transactions. Other possible sources of information are the attorneys and accountants you may ask us to contact.

HCM does not disclose such information to anyone, except as required by law.

SAFEGUARDS

We restrict access to nonpublic personal information about you to those HCM employees and permitted parties necessary to provide our services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.