GoodWin Asset Management, Inc. considers clients privacy of utmost concern. GoodWin Asset Management, Inc. does not disclose any nonpublic personal information about the client to anyone, except as permitted by law.

In order for GoodWin Asset Management, Inc. to continue to offer the asset management services that best meet client;s investing needs, and to effect transactions that the client request or authorize, GoodWin Asset Management, Inc. may disclose the information GoodWin Asset Management, Inc. collects, as described above, to companies that perform administrative services on the behalf, such as custodians, printers and mailers that assist us in the distribution of written materials. These companies will use this information only for the services for which GoodWin Asset Management, Inc. hired them, and are not permitted to use or share this information for any other purpose.

If the client decides at some point either to close clients account (s) or to become inactive clients, GoodWin Asset Management, Inc. will continue to adhere to the privacy policies and practices described in this notice.