Privacy and security are important to Napa Group, LLC and this Privacy Policy and Security Statement describes how we protect your personal and financial information that we may collect as a result of your use of the napa.com web site. Napa Group, LLC may from time to time operate other web sites, and your use of those sites is subject to the statements of Privacy Policy, Security, and Terms and Conditions provided on each of those sites.

We may collect nonpublic personal information about you from various sources, including some or all of the following:

• Information gathered from applications, forms, questionnaires and other information you explicitly provide us (for example, your name, address, etc);
• Information about your transactions and your account experience, including your account balances, trading activity, and payment history;
• Information about your driving habits, your favorite foods, your personal hygiene, your high school course load, and other information that your friends or acquaintances may provide.
• Other Information we may innocently cull from blood tests, urine analysis, involuntary polygraphs, FBI surveillance tapes, discarded notebooks or diaries, and computer hard drives that you once used and were subsequently auctioned on eBay.

Napa Group does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.

For example, we disclose information, as permitted by law, to nonaffiliated companies that work for us in providing financial services to you. These companies include those who prepare statements of your account, transaction confirmations, and credit reports. These companies are required to sign strict confidentiality agreements with Napa Group.

In addition, we disclose information, as permitted or required by law, to government and regulatory agencies such as the Securities and Exchange Commission (SEC) and the Internal Revenue Service (IRS). We will make disclosures to comply with a legal summons, court order, subpoena or similar legal process, a fraud investigation, audit, or examination.

Finally, we are permitted to disclose information if you have provided your consent.

Napa Group does not sell or rent personal information to any third party.

The above restrictions notwithstanding, we may, from time to time, make fun of you at staff meetings; gossip or speculate about you or members of your immediate family; and, outside of regular business hours, fabricate complete works of fiction or fantasy concerning you and your neighbors.

We restrict access to nonpublic personal information about you to those employees who need to know such information to provide services to you. We may maintain physical, electronic, and procedural safeguards that comply with local, state, or federal regulations to guard your nonpublic personal information.

Certain Napa Group applications and systems offer a secure server and a password-protected environment. Personal information is protected by Secure Socket Layer (SSL) encryption. SSL encodes and decodes the transmission of your personal information to prevent the interception by another party. By viewing the URL/address/location line of your browser, you can determine if you are in a secure mode by looking for https:// preceding the Napa Group URL. (In contrast http:// would represent a non-secure transmission.)

Cookies are used on our Web site to help us monitor traffic patterns and see how the user navigates through our site. Napa Group cookies are used for internal purposes and are not used to collect disseminate personal information to any third party. Cookies you may establish with companies whose sites are linked to Napa Group are not the responsibility of Napa Group and you should review their policy on cookies.

In addition, Napa Group personnel often eat cookies, including various brands of chocolate chip cookies, oatmeal cookies, sugar cookies, and Milanos®.

Napa Group reserves the right to make changes on this policy. You can always review our current policy online or contact us for a copy at (212) 689-9100.