In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment adviser firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to non-affiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure.

Harvest Investment Consultants LLC does not share or disclose customer information to non-affiliated third parties except as permitted or required by law. Harvest Investment Consultants LLC is committed to safeguarding the confidential information of its clients. Harvest Investment Consultants LLC holds all personal information provided by clients in the strictest confidence and it is the objective of Harvest Investment Consultants LLC to protect the privacy of all clients. Except as permitted or required by law, Harvest Investment Consultants LLC does not share confidential information about clients with non-affiliated parties. In the event that there were to be a change in this policy, Harvest Investment Consultants LLC will provide clients with written notice and clients will be provided an opportunity to direct Harvest Investment Consultants LLC as to whether such disclosure is permissible.

To conduct regular business, Harvest Investment Consultants LLC may collect personal information from sources such as:

• Information reported by the client on applications or other forms the client provides to Harvest Investment Consultants LLC.
• Information about the client’s transactions implemented by Harvest Investment Consultants LLC or others.
• Information developed as part of financial plans, analyses, or investment advisory services.

To administer, manage, service and provide related services for client accounts, it is necessary for Harvest Investment Consultants LLC to provide access to customer information within the firm and to non-affiliated companies, (Redtail CRM, SmartRIA, eMoney, Fidelity, Charles Schwab, TD Ameritrade, Riskalyze, Black Diamond), with whom Harvest Investment Consultants LLC has entered into agreements. To provide the utmost service, Harvest Investment Consultants LLC may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on Harvest Investment Consultants LLC’s behalf.

• Information Harvest Investment Consultants LLC receives from the client on applications (name, Social Security number, address, assets, etc.)
• Information about the client’s transactions with Harvest Investment Consultants LLC or others (account information, payment history, parties to transactions, etc.)
• Information concerning investment advisory account transactions
• Information about a client’s financial products and services transaction with Harvest Investment Consultants LLC

Since Harvest Investment Consultants LLC shares non-public information solely to service client accounts, Harvest Investment Consultants LLC does not disclose any non-public personal information about Harvest Investment Consultants LLC’s customers or former customers to anyone, except as permitted by law. However, Harvest Investment Consultants LLC may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. In the event that Harvest Investment Consultants LLC has a change to its customer privacy policy that would allow it to disclose non-public information not covered under applicable law, Harvest Investment Consultants LLC will allow its clients the opportunity to opt out of such disclosure.

Any questions regarding our Customer Privacy Policy or this notice should be directed to Michael J. Meily, Chief Compliance Officer and Managing Member.