FNTC AMERICA TRUST COMPANY PRIVACY POLICY

FNTC America Trust Company (FNTCA) collects information about our clients from public and private sources in order to (1) conduct thorough and prudent due diligence, (2) to maintain up-to-date client files, and (3) to comply with all federal and state laws.

To adhere to best practices and know-your-client protocols, FNTCA collects private client information by direct request and public information from various sources, prior to taking on a new client, and periodically thereafter. We rely on our clients to provide us complete information initially and update us of changes.

FNTC America Trust Company believes it is imperative to safeguard the privacy of client information. We are wholly committed to maintaining client confidentiality and discretion concerning the information we collect. We do not sell, share or otherwise disclose non-public information about our clients, except (i) internally amongst our corporate parent, affiliates, or subsidiaries, as necessary, or (ii) as required by law. FNTCA maintains physical, electronic and procedural safeguards to protect the confidentiality of client information.