BGM Wealth Partners is entrusted with, or has access to, non-public personal information about its clients and is responsible for the confidentiality and security of that information. BGM Wealth Partners recognizes and respects the privacy expectation of its customers and will only disclose customer information it collects to third parties who are not affiliated with BGM or its affiliates (1) as authorized or directed by a client, (2) as permitted by law, (3) to service providers who provide investment products or services to the client, (4) in connection with an audit or examination or (5) to respond to a subpoena or similar legal process. Information provided to BGM Wealth Partners is used to help clients meet their personal financial goals while guarding against any real or perceived infringements of privacy rights. BGM Wealth Partners may disclose client information we have collected to our affiliates Boeckermann, Grafstrom & Mayer, P.A. and Cornerstone Private Asset Trust Company, LLC after a signed waiver is provided by the client. BGM Wealth Partners’ policy with respect to personal information is stated below:

• BGM Wealth Partners maintains a hardware firewall to protect our server from intrusion by outside parties whereby non-public personal information might be accessed from outside BGM Wealth Partners.

• BGM Wealth Partners maintains all customer records electronically, and in cases where we must maintain paper files, they are in a secure area in locked cabinets so that access to those records can be controlled. All electronic client records are password protected.

• BGM Wealth Partners has a disaster recovery plan that provides for redundant recordkeeping.

• BGM Wealth Partners personnel are regularly coached on providing a high level of professionalism to all clients, making each employee responsible for the security and confidentiality of client information. BGM Wealth Partners limits employee access to non-public personal information to those employees who have a business reason for knowing such information.

All clients receive the BGM Wealth Partners Privacy Policy as part of the process for establishing a client relationship and thereafter in the event of a policy change.