Privacy Statement

The following information is provided, as required by law, to help you understand our privacy policy and how we will handle and maintain confidential personal information as we fulfill our obligations to protect your privacy. “Personal information” refers to the nonpublic financial information obtained by Kraft Asset Management, LLC (KAM) in connection with providing investment advisory or other services.

Information we collect

KAM collects personal information as part of our relationship to you as an investment advisor, to provide client services and fulfill legal and regulatory requirements. The type of information KAM collects may include:

• Information KAM receives from you on forms (such as name, address, social security number, assets and income); and
• Information you provide KAM directly about your personal finances or personal circumstances or which KAM may receive from brokerage statements or other information you authorize KAM to receive.

Information disclosed in administering products and services

KAM will not disclose personal information about current or former clients to non-affiliated third parties except as permitted or required by law. KAM does not sell any personal information about you to any third party. KAM will not disclose personal information without your authorization, except as required or permitted by law.

Procedures to protect confidentiality and security of your personal information

KAM has procedures in place that limit access to personal information to those employees who need to know such information in order to perform business services. KAM educates our employees on the importance of protecting the privacy and security of confidential personal information. KAM will update our policies and procedures where necessary to ensure that your privacy is maintained and that KAM conducts our business in a way that fulfills our commitment to you. If KAM makes any material changes in our privacy policy, we will make that information available to clients through our Web site and/or other communications.