Griffin Black, Inc. (“GBI”, “we”) is committed to maintaining the confidentiality, integrity, and security of the personal information entrusted to us.

The categories of non-public information that we collect from clients may include information about their personal finances as needed for the financial planning process and/or investment management planning and execution. This may include information pertaining to personal background, investment objectives, financial situation, tax information & returns, investment holdings, account numbers, account balances, and estate documents, among other items.

If a client requests it, we will provide specific information to attorneys, accountants, insurance agents, and mortgage brokers/lenders with whom that client has established a relationship. We will also share information about clients as necessary with certain third parties, such as Shareholder Services Group, in order to execute transactions on their behalf. In addition, we may disclose information contained in documents required to facilitate transactions between clients and certain third parties or between GBI and such an organizations or individuals for the client’s benefit. Such third parties may include broker-dealers, insurance agents or companies, account custodians, and mortgage brokers, among others.

We maintain a secure office to ensure that client information is not placed at unreasonable risk.

We do not provide personal information about clients to mailing list vendors or solicitors.

If we manage more than one account for a client’s family, we may disclose and discuss information regarding any and all accounts pertaining to that family to each account holder unless otherwise precluded from doing so by written notice from all affected account holders.

Griffin Black, Inc. permits only authorized employees and affiliates who have signed a copy of our Privacy Policy to have access to client information. Employees violating our Privacy Policy will be subject to the company’s disciplinary process.

We require strict confidentiality in our agreements with unaffiliated third parties that require access to clients’ personal information in order to perform work for us, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our company records and client records as permitted by law.

Personally identifiable information about clients will be maintained during a client’s active relationship with GBI and for the required period thereafter, as required by federal and state securities laws. After that time, the information may be destroyed.