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registered investment adviser
independent investment advice since 1988

Privacy Policy

June 1, 2010

S.E. Thorn & Co. believes the privacy of our clients is a major priority.

Information we collect:

We collect personal information in the normal course of business to open your account(s), administer your account, to process your transactions and to help us serve you better. Our relationship with you is of primary importance. We understand that you have entrusted us with your personal financial information, and we do everything we can to maintain that trust.

If you open an account with us, or meet with us in some other way (e.g. telephonically, private meeting or a seminar), we collect application and registration information such as name, address, phone number, email address, social security number, and information about your finances, income, debts, investments and investment experience, in order to properly handle your account.

Transaction information is collected and maintained, including such items as statements, account balances with providers and similar information so that we may effectively service your account and to fulfill our regulatory responsibilities.

Privacy Policy:

Our privacy policy applies to consumers who are current or former investment advisory clients. Throughout this notice, we refer to any information that personally identifies you or your accounts as "personal information".

1. We do not sell your personal information to anyone.

2. Other than the following exceptions, we will not share your personal information with third parties unless you have specifically asked us to do so, that is, "opted in"
or unless one of the following limited exceptions applies:

a. We disclose personal information to companies and other financial institutions that help us process, clear, service or maintain your account(s), such as broker/dealers, mutual fund companies, insurance companies or our clearing firm.

b. We may report or disclose personal information (in limited circumstances) where we believe in good faith that the disclosure is required or permitted by law. For example, in cooperation with regulators or law enforcement authorities, to resolve customer disputes or in response to subpoena or court orders.

4. We protect the confidentiality and security of your personal information.

a. Companies that we do business with are not allowed to use your personal information for their own purposes, and are contractually obligated to maintain your privacy. We limit the information they are given to the specific product or service we have requested.

b. We restrict access to personal information to our employees and representatives for business purposes only. All employees are trained and required to safeguard such information.

c. We maintain physical, electronic and procedural safeguards to protect your personal information.


We continue to evaluate our efforts to protect your personal information, and to keep it as accurate and up to date as possible. If you discover any inaccuracy in your personal information or need to make any change in that information, please contact us so that we can promptly update our records.

If, at any time in the future, it is necessary to disclose any of your personal information that is inconsistent with this policy, we will give you advance notice so that you may "opt out" of such disclosure ( "Opt-out" a concept requiring us to give consumers and customers notice that non-public personal information may be disclosed to third parties).

Stuart E. Thorn CFP TM, LIFA, MBA, MS

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