The use, collection, and retention of all ‘non-public personal information’ are limited to what is necessary to conduct our business and provide quality service, such as that described in the examples above.

Maintenance of Accurate Information. Procedures are in place to maintain the accuracy of customer information and to keep such information current and complete. These procedures include responding to requests to correct inaccurate information in a timely manner.

Limiting Employee Access to Information. Employee access to customer information is limited to those with a business reason to know such information. Employees are instructed on the importance of maintaining the confidentiality of customer information.

Restrictions on the Disclosure of Customer Information. Mastrapasqua Asset Management does not disclose or share any non-public personal information to anyone, except as required by law. Information is only disclosed to nonaffiliated third parties in circumstances such as maintaining or servicing a customer’s account, or complying with federal, state, or local laws. For example, we may disclose non-public personal information about you to third parties to assist us in servicing your account with us (i.e., mailing of fund related materials) and to government entities (e.g., IRS for tax purposes). MAM maintains physical, electronic, and procedural safeguards that are designed to comply with federal standards to guard your information. We will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.

1 in accordance with an exception under sections 248.14 or 248.15 (Regulation S-P)

Keeping information secure
We maintain physical, electronic and procedural safeguards and procedures to protect your financial and other personal information, and we continually assess new technology with the aim of adding these safeguards to those we have in place.

Accuracy of information
We strive to keep our records of your information accurate, and we take immediate steps to correct errors. If there are any inaccuracies in your statements or in any other communications from us, please contact us or contact your investment professional.

Maintaining customer privacy in business relationships
We do not share customer information with anyone who does not agree to keep such information confidential. If you believe we have shared your information inappropriately, please contact us or your investment professional.

Online Privacy Guidelines
We are firmly committed to protecting our shareholders' personal and financial information online. The following guidelines are designed to help you understand how we gather, use and protect that personal and financial information.

Information Collection, Use and Disclosure
We do not collect any personal information about you online, unless you fill out and submit your name and email address to us. We do not give out your personal information unless we are authorized or permitted to do so. We do not sell your personal information to any third parties.

When Information is Collected and Not Collected
You may browse our web site anonymously, and we will not collect personal information such as your e-mail address. In order to evaluate the usefulness of our site, we also gather and analyze data regarding usage of the site, such as domain name, number of hits, pages visited and length of user session.

Our Use of Cookies
What is a cookie? A cookie is a small piece of information placed on your computer by the Web site you are visiting. It allows the Web site to “remember” or “recognize” your computer during subsequent visits. Although different Web sites use cookies for different purposes, one important function is to allow a site to personalize your experience. For example, a cookie can be used to designate start pages within a site, or to indicate an area of interest to you on a Web site.

Web sites may use two types of cookies.
Temporary - cookies that are stored on your computer only during your browsing session, and are automatically deleted from your compute when you close your browser.
Permanent - Cookies that are stored on your computer and are not deleted when you close your browser. Permanent cookies retain your preferences for a particular Web site, allowing those preferences to remain for future browsing sessions.

How we Handle E-Mail
We preserve the content of your e-mail, your e-mail address and our response so that we can more efficiently handle any follow-up questions you may have and to meet legal and regulatory requirements. It is important to understand that regular non-encrypted Internet e-mail is not secure. E-mail addresses that we provide on our site are for information inquiries of a non-sensitive and non-confidential nature.

We strongly urge you not to send confidential information such as social security or account numbers to us via a non-secure e-mail address.

Because our e-mail response back to you would not be secure, we will not include confidential account information in an e-mail response. You may also contact us by phone, fax or U.S. mail.

Hyperlinks
This Web site may contain hyperlinks that enable you to visit other sites. Other sites may have hyperlinks to this site. You should be aware that Web sites linking to and from this site may have different privacy practices from ours. It is assumed that visitors to our site will read the privacy statements of this and other Web sites they visit. However, our privacy statement applies solely to information contained on this Web site. Because we cannot control information on other Internet sites, we are not responsible for the content of sites linked this Web site nor for the privacy policies given on those sites.

You Can Count On Our Commitment to Your Privacy
You can count on us to keep you informed about the procedures and the technology we use to protect your privacy and limit the sharing of information you provide to us, whether in a mailed application, over the phone or through the Internet.

This is our policy as of 12/19/2006. This privacy policy applies to individuals, and we reserve the right to change any or all of the principles, along with related provisions, at any time.