Privacy Policy

STERNECK CAPITAL PRIVACY POLICY

March 1, 2022

At Sterneck Capital Management, we consider it a privilege to serve your financial needs and we value the trust

you have placed in us. As we serve your financial needs, we are committed to safeguarding your personal

information.

We hold all personal information provided to us in the strictest confidence. These records include all personal

information that we collect from you in connection with the services provided by Sterneck Capital Management,

LLC. We do not disclose information to non-affiliated third parties, except as permitted by law, and do not

anticipate doing so in the future. If we were to anticipate a policy change, we would be prohibited under law from

making a change without advising you first.

We do share information with others who provide services for our clients* only if the information is required to

execute the agreed upon service and only if they agree to abide by our privacy policy.

• We maintain a secure office and computer environment to ensure that your information is not placed

at unreasonable risk.

• We collect non-public personal information about you from information we receive from you or your

primary custodian. This information is typically relayed to us on applications or other forms that you have

provided.

• Certain non-affiliated third parties, such as auditors, may require access to your personal information.

We also require strict confidentiality in our agreements with them and expectthem to keep this

information private.

• We do not provide your personally identifiable information to mailing list vendors or solicitors for any

purpose. From time to time we may engage an independent third party to conduct anonymous client

surveys on our behalf, though we expect such firms to use information we provide for this sole purpose.

• We limit access to information only to those who have a business or professional reason for

knowing. We may disclose all of the information described above to certain third parties who are not

affiliated with the firm under one or more of the following circumstances;

• As Authorized – if you request or authorize disclosure of the information.

• As Required by Law – for example, to cooperate with regulators or law enforcement

authorities.

• As otherwise Permitted by Law – for example, sharing information with companies that

maintain, process or service customer accounts or financial products and services or effect,

administer or enforce customer transactions is permitted. Among other activities, we may share

information with broker-dealers in order to execute customer trades or with custodians that hold

securities on behalf of customers. We believe that sharing of information for these purposes is

essential to providing clients with necessary or useful services with respect to their accounts.

• Under Joint Agreements – we may also share information with companies that perform marketing

services on our behalf or to other financial institutions with whom we have joint marketing

agreements.

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