DISCLOSURE & PRIVACY POLICY

Disclosure

Palmerston Group Advisors, L.L.C. (“Palmerston Group”) is a registered investment advisory firm in the state of New Jersey, located in Highland Park, New Jersey. Palmerston Group and its representatives are in compliance with current registration and/or filing notice requirements imposed upon New Jersey State Registered Investment Advisors. Registration information, including its ADV Part Two “brochure,” is available upon request by using the Investment Advisor Search function at http://www.adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx . The firm will not solicit or accept business in any state in which it is not properly registered or otherwise qualified to conduct business by virtue of a state “de minimus” exemption. Insurance services, which clients are free to use or not use, are provided through Palmerston Group Indemnity Solutions, L.L.C., a business entity registered with the New Jersey Department of Banking and Insurance.

Palmerston Group’s websites on the Internet are limited to the dissemination of general information pertaining to its investment advisory and financial planning services. Accordingly, Palmerston Group’s websites should not be construed by any consumer and/or prospective client as Palmerston Group’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation over the Internet. Palmerston Group does not render or offer to render personalized investment advice or financial planning advice through the firm’s websites. No client or prospective client should assume that any information presented and/or made available on Palmerston Group’s websites serves as the receipt of, or a substitute for, personalized individual advice from a Palmerston Group advisor or any other investment professional. Palmerston Group’s services are provided only upon the commencement and within the context of contractual agreements with each client. Any subsequent, direct communication by Palmerston Group with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.

Palmerston Group uses reasonable efforts to obtain information from sources which it believes to be reliable; however, Palmerston Group makes no representation that the information or opinions contained on Palmerston Group’s websites are accurate, reliable, timely or complete. Neither Palmerston Group nor entities from which Palmerston Group obtains information shall be liable for any inaccuracies, errors, lack of timeliness, or disruption or delay in the transmission of information to the user. The information and opinions contained on Palmerston Group’s websites are provided by Palmerston Group for personal use and informational purposes only and are subject to change without notice.

Palmerston Group’s websites contain live ‘links’ to other Internet addresses. These links and the information at these addresses include information developed, published, maintained, or otherwise posted by entities entirely separate from and unrelated to Palmerston Group. Palmerston Group does not sanction, approve, control, attest to the veracity of, or endorse these external Internet addresses. It neither warranties nor assumes responsibility for the truthfulness, fullness, value, or timeliness of content found at these sites. Use of any information obtained from these independent locations is voluntary, and reliance on it should be undertaken only after an independent review of its accuracy, completeness, efficacy, and timeliness. Reference therein to any specific commercial product, process, or service by trade name, trademark, service mark, manufacturer, or otherwise does not constitute or imply endorsement, recommendation, or favoring by Palmerston Group.

Future results are not necessarily indicated by past performance. Nothing on Palmerston Group’s websites should be interpreted to suggest otherwise. Therefore, no prospective or current client of Palmerston Group should assume that any specific investment strategy, investment, or product to which a Palmerston Group website refers directly or indirectly or through a link to any other website will be profitable or comparable in performance to indicated comparators.

If you have any questions or concerns, please call our office at (732) 248-5777 or email us at inquiries@palmerstongroup.com.

Privacy Policy

Palmerston Group Advisors, L.L.C. understands that your privacy is important to you. We are committed to protecting the privacy of your personal information. This Privacy Policy tells you how we protect and use information that we gather from you. By using Palmerston Group websites, you consent to the terms described in the most recent version of this Privacy Policy. You should also read our Disclosure below to understand the general rules about your use of Palmerston Group websites and any additional terms that may apply when you access particular materials on certain website areas. “We” or “our” means Palmerston Group Advisors, L.L.C. “You,” “your,” "visitor,” or “user” means the individual accessing a Palmerston Group website.

PERSONAL AND NON-PERSONAL INFORMATION

Our Privacy Policy identifies how we treat your personal and non-personal information.

WHAT IS NON-PERSONAL INFORMATION AND HOW IS IT COLLECTED AND USED?

Non-personal information is information that cannot identify you. If you visit a Palmerston Group website to read information, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information.

WHAT IS PERSONAL INFORMATION AND HOW IS IT COLLECTED?

Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, telephone number, fax number, and Social Security Number. It can also include income, assets, investment experience, transaction history, holdings, and financial account balances. We may collect personal information from you in a variety of ways, for example, when you:

Send us an application or other form
Open an account
Describe your investment or retirement portfolio to us
Send us personal information about yourself through a Palmerston Group website to elect to receive particular information or to participate in an activity.
Request advice about financial planning or investments
Sign an agreement with us for investment advisory services

HOW DOES PALMERSTON GROUP ADVISORS, L.L.C. USE PERSONAL INFORMATION?

Palmerston Group Advisors, L.L.C. may keep and use personal information we collect from or about you to respond to your requests, to contact you with information that might be of interest to you, such as about our products and services, and for record-keeping and analytical purposes. We may also use your personal information for other everyday business purposes, such as maintaining your account(s) and processing transactions. Personal information collected online may be combined with information you provide to us through other sources. In some uses of your personal information, we may also remove your personal identifiers (your name, email address, Social Security Number, etc.). In such a case, you would no longer be identified as a single, unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information. Finally, we may use your personal information to protect our rights or property, or to protect someone’s health, safety or welfare, and to comply with a law or regulation, court order or other legal process.

DOES PALMERSTON GROUP ADVISORS, L.L.C. SHARE PERSONAL INFORMATION WITH OTHERS?

We will not share your personal information with an unrelated third party without your permission, except as otherwise provided in this Privacy Policy. We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition. We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We will cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behavior that is harmful to other visitors or illegal. We may disclose your personal information to third parties if we feel that the disclosure is necessary to protect our rights or property, protect someone’s health, safety or welfare, or comply with a law or regulation, court order or other legal process.

We do not share information about your transactions and experiences or information about your creditworthiness with our affiliates (companies related to Palmerston Group through common ownership or control) for their everyday business purposes. We do not share with nonaffiliates (companies not related to Palmerston Group through common ownership or control) personal information they can use to market to you. In this regard, be advised that we do not jointly market financial products or services with nonaffiliated financial companies.

Relevant to the foregoing is that according to federal law, you have the right to limit only: our affiliates from using your personal information to market to you; our sharing of your personal information with nonaffiliates for the purpose of their marketing to you; our sharing of information about your creditworthiness with our affiliates for their everyday business purposes. State laws may give you additional rights to limit sharing.

HOW IS PERSONAL INFORMATION USED FOR COMMUNICATIONS?

We may contact you periodically by e-mail, mail or telephone to provide information regarding programs and content that may be of interest to you. In addition, some of the features on Palmerston Group websites allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

HOW IS PERSONAL INFORMATION SECURED?

We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration, or destruction. Only authorized personnel have access to your personal information, and these employees are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.

HOW CAN A USER ACCESS, CHANGE, AND/OR DELETE PERSONAL INFORMATION?

You may access, correct, update, and/or delete any personal information that you submit to a Palmerston Group website. You may also unsubscribe from any registrations on a Palmerston Group website. To do so, please either follow instructions on the page of the website on which you have provided such information or subscribed or contact us at inquiries@palmerstongroup.com. Regarding access to personal information not submitted through a Palmerston Group website, and regarding changes to and/or deletions of such information, please contact us at inquiries@palmerstongroup.com.

CHILDREN’S PRIVACY

Palmerston Group Advisors, L.L.C. will not intentionally collect any personal information (such as a child’s name or email address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us at inquiries@palmerstongroup.com.

LINKS

Palmerston Group is not responsible for the privacy practices of these entities.

CHANGES AND QUESTIONS

Palmerston Group Advisors, L.L.C. reserves the right to modify this statement at any time. Any changes to this Privacy Policy will be listed here. If you have any questions about the privacy of your personal information, or about privacy at any websites operated by Palmerston Group Advisors, L.L.C. or about our website practices, please contact us at inquiries@palmerstongroup.com.