FRIEDBERG INVESTMENT MANAGEMENT, INC. DOES NOT SELL YOUR INFORMATION. WE WILL ONLY DISCLOSE INFORMATION ABOUT YOU AT YOUR REQUEST OR AS REQUIRED BY LAW. WE HAVE NO SUBSIDIARIES OR COMPANY ALLIANCES WITH WHOM WE SHARE INFORMATION OTHER THAN THE BROKERAGE FIRMS THAT HAVE CUSTODY OF YOUR ACCOUNTS. YOU WILL RECEIVE A SEPARATE PRIVACY POLICY NOTICE FROM YOUR BROKERAGE FIRM(S).

The following is Friedberg Investment Management Inc.'s (FIM) Privacy Policy, designed to protect the confidentiality of our current and former clients. As required by law, we will send our most recent privacy policy notice to our current clients on an annual basis.

FRIEDBERG INVESTMENT MANAGEMENT, INC.

PRIVACY POLICY/REGULATION S-P

Friedberg Investment Management, Inc. (FIM) views protecting private information regarding its clients and potential clients as a top priority. Pursuant to the requirements of the Gramm-Leach-Bliley Act (the "GLBA") and guidelines established by the Securities Exchange Commission regarding the Privacy of Consumer Financial Information (Regulation S-P), FIM has instituted the following policies and procedures in an effort to ensure that such nonpublic private information is kept private and secure. This policy also outlines how FIM and its Associated Persons are allowed to use the confidential personal information collected in connection with its advisory activities.

Regulation S-P defines "consumer" as an individual who obtains or has obtained a financial product or service from a financial institution primarily for personal, family, or household purposes, or for that individual's legal representative. Generally, an individual is a consumer if he or she provides nonpublic information to a company in connection with obtaining or seeking to obtain investment advisory services, whether or not the company provides such services to the individual or establishes a continuing relationship with the individual.

"Customer" is defined as a consumer who has an on-going relationship with the institution . Generally, a customer is a consumer who has an investment advisory contract with the Company (whether written or oral) and/or the Company regularly effects or engages in securities transactions with or for a consumer even though the Company does not hold assets of the consumer.

While these terms have specific definitions, for the purposes of Friedberg Investment Management’s policies, both consumers and customers will be collectively referred to as "clients" (or "potential clients" or "former clients" where applicable).

This policy serves as formal documentation of the Friedberg Investment Management’s ongoing commitment to the privacy of its clients. All Associated Persons will be expected to read, understand, and abide by this policy, as well as to follow all related procedures and to uphold the standards of privacy and security set forth by FIM. This Policy and the related procedures contained herein are designed to comply with applicable privacy laws, including the GLBA, and to protect nonpublic personal information of the FIM's clients.

The Company is aware that the SEC has proposed amendments to Regulation S-P that set forth more specific requirements for safeguarding personal information against unauthorized disclosure and for responding to information security breaches. When these new amendments are adopted, or in the event that new privacy-related laws or regulations affecting the information practices of the Company are adopted by federal or state regulators, this Privacy Policy will be revised as necessary and any changes will be disseminated and explained to all personnel.

Scope of Policy

This Privacy Policy covers the practices of Friedberg Investment Management and applies to all nonpublic personally identifiable information, including information contained in consumer reports, of our current and former clients.

Overview of the Guidelines for Protecting Client Information

In Regulation S-P, the Securities and Exchange Commission (the "SEC") published guidelines, pursuant to section 501(b) of the GLBA, that address the steps a financial institution should take in order to protect client information. The overall security standards that must be upheld are:

Ensuring the security and confidentiality of client records and information;

Protecting against any anticipated threats or hazards to the security or integrity of client records and information; and

Protecting against unauthorized access to or use of client records or information that could result in substantial harm or inconvenience to any client.

FIM keeps all client information such as statements, applications, management agreements and fee invoices secured in locked offices. In some cases, the file cabinets themselves are locked. All computers and data software are password protected. Firewalls are used for all computers. No unauthorized persons are allowed in the offices unless accompanied by a FIM employee. Service providers are screened as described in this Policy. FIM’s Code of Ethics prevents employees from taking client information with them if they leave the firm. Personal information of people who are no longer clients is subject to the same security, confidentiality and protection stated in this Policy.

Responsibility

Information Practices

Friedberg Investment Management limits the use, collection, and retention of client or potential client information to what we believe is necessary or useful to conduct our business and to offer quality services to our clients or potential clients.

FIM collects nonpublic personal information about clients and/or potential clients from various sources. These sources and examples of types of information collected include:

Broker account applications or other forms, such as new client profiles, agreements, etc., which typically request information such as name, address, telephone number, social security number or taxpayer ID number, date of birth, employment status, annual income, and net worth;

Information about transactions with FIM and account custodian(s), such as account balance, types of transactions, parties to the transactions, and investment history.

Disclosure of Information to Nonaffiliated Third Parties - "Do Not Share" Policy

Friedberg Investment Management has a "do not share" policy. We do not disclose nonpublic personal information to nonaffiliated third parties, except under one of the GLBA privacy exceptions, as described below. Since FIM currently operates under a "do not share" policy, it does not need to provide the right for its clients to opt out of sharing with nonaffiliated third parties, as long as such entities are exempted as described below. If our information sharing practices change in the future, we will implement opt out policies and procedures, and we will make appropriate disclosures to our clients.

Types of Permitted Disclosures - The Exceptions

In certain circumstances, Regulation S-P permits FIM to share nonpublic personal information about its clients with nonaffiliated third parties without providing an opportunity for those individuals to opt out. These circumstances include sharing information with a nonaffiliate (1) as necessary to effect, administer, or enforce a transaction that a client requests or authorizes; (2) in connection with processing a service a client authorizes; and (3) in connection with maintaining or servicing a client account with FIM.

From time to time, FIM may have relationships with nonaffiliated third parties (such as attorneys, accountants, custodians, and other consultants), who, in the ordinary course of providing their services to us, may require access to information containing nonpublic information. FIM may also share information with providers of data processing and storage and computer technicians. These service providers are already bound by the policies of their companies to maintain the confidentiality of all nonpublic information they obtain from or through us. These third-party service providers are necessary for us to provide our investment advisory services. In some instances, as a further precaution, we require the service provider to sign a Confidentiality Agreement with Friedberg Investment Management. In addition, we select and retain service providers that we believe are capable of maintaining appropriate safeguards for nonpublic information.

FIM may also share information when it is necessary to effect, administer, or enforce a transaction requested or authorized by clients. In this context, "necessary to effect, administer, or enforce a transaction": includes what is required or is a usual, appropriate, or acceptable method:

To carry out a transaction or service of which the transaction is a part, and record, service, or maintain the client's account in the ordinary course of providing the financial service or financial product;

To provide confirmation, statement, status or other records of client account information, per the client’s instructions, to a third party such as their personal accountant or mortgage company.

Sharing as Permitted or Required by Law

FIM may disclose information to nonaffiliated third parties as required or allowed by law. For example, this may include disclosures in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit or examination, or the transfer of an account to another financial institution.

By understanding how Friedberg Investment Management shares data with its clients, their agents, service providers, or parties related to transactions in the ordinary course of business, FIM endeavors to ensure that client data is shared only within the exceptions noted above.

Disclosure of Information to Affiliated Third Parties

As stated in our Privacy Notice, FIM restricts access to nonpublic personal information to those persons or parties associated with FIM who need access to such information in order to provide our services.

FIM is not currently affiliated with any other firms.

Privacy Notice

Friedberg Investment Management has developed a Privacy Notice, as required under Regulation S-P, to be delivered to clients initially and to current clients on an annual basis. The notice discloses FIM’s information collection and sharing practices and other required information. The notice will be revised as necessary any time information practices change.

Privacy Notice Delivery

Initial Privacy Notice - As regulations require, all new clients receive an initial Privacy Notice at the time the client relationship is established (i.e., upon execution of the agreement for services).

Annual Privacy Notice - The GLBA regulations require that disclosure of the Privacy Policy be provided to existing clients on an annual basis. FIM delivers its annual Privacy Notice in conjunction with the annual Objectives review and update letter. A copy of the complete Privacy Policy document is available, free of charge, upon request.

Revised Privacy Notice

In accordance with Regulation S-P, FIM will amend its Privacy Policy and promptly distribute a revised disclosure to clients if there is a change in FIM’s collection, sharing, or security practices.

Joint Relationships

If two or more individuals jointly obtain a financial service from Friedberg Investment Management, FIM may satisfy the initial, annual, and revised notice requirements by providing one notice to those individuals jointly.