Gunderson Capital Management, Inc.



Gunderson Capital Management's Commitment to its Client's:

Gunderson Capital Mgt. Inc. (GCM) recognizes and respects the privacy expectation of each of its clients. GCM believes that keeping confidential, and protecting its non-public personal information is one of its fundamental responsibilities. GCM does not sell clients' non-public information to any third parties. GCM uses its clients' non-public personal information only in connection with the performance of its obligations under the Investment Advisory Agreement between GCM and its clients.

Information GCM receives about its clients:

GCM receives non-public, personal information from the following sources: Directly from our clients. For example, information we receive from clients on applications, questionnaires, other forms, and in oral or written communications. From our affiliates, and from the broker-dealer(s) who have custody of your account(s) and your assets under GCM's management.

How GCM handles its client's financial information:

As noted above, GCM does not sell non-public personal information about current or former clients to third parties. Below is a description of the circumstances in which GCM may disclose non-public personal information to third parties.

In order to complete certain transactions or account changes, it may be necessary to provide certain non-public personal information about a client to companies, individuals, or groups that are not affiliated with GCM. For example, if a client asks GCM to transfer assets from another financial institution, GCM will need to provide certain non-public information about that client to the institution involved to complete the transaction.

GCM will release non-public information about clients if directed by that client to do so or if GCM is authorized by law to do so.

How GCM safeguards its client's personal information:

GCM restricts access to information about clients to those of its employees who require the information to provide services to that client. GCM maintains physical, electronic, and procedural safeguards that it deems reasonable to guard its clients, non-public personal information.