This Notice summarizes the privacy policy of GNI Capital, Inc. We are committed to safeguarding the confidential information of each of our clients. We regard your personal data as confidential and strive to ensure its safekeeping. We will obtain your permission before we disclose your confidential personal information with anyone external to our firm, except as described in this Notice.

How We Handle Your Information

The information we gather about you includes the information you provide us on our questionnaires, information we collect with your permission from other financial institutions you work with, and information from statements and other sources that you give us. We also collect information about transactions effected in your account with us and in accounts you may hold with nonaffiliated third parties (such as the broker-dealer that custodies your account) with whom we are authorized to interact in the course of providing services to you.

We do not disclose information to third parties not affiliated with us except as required or permitted by law or in carrying out the duties for which you retained us. We do not anticipate any change to this policy, and, in the unlikely event that we were to change it, we will contact you prior to such a change and give you the option to protect your data.

Other key points you should know about how we handle your personal information:

• We may use the financial and personal information you give us to assist you in meeting your personal financial goals. This may involve sharing your information among our affiliated firms.

• We may also share any of your information with nonaffiliated parties as required or permitted by law or as may be necessary or customary in order to transact business on your behalf. Common examples would be sharing your personal or transaction information with other financial service providers, such as the brokerage firm acting as custodian of your account (for example, Schwab or Fidelity) or other firms (for example, the brokerage firm sponsoring your wrap account) that may be involved in the process of providing you services. We may also disclose your information to non-financial companies, such as companies hired to assist us in making government filings, or others, such as government regulators who may request access to client data in the course of inspecting us.

• We expect nonaffiliated third parties that require access to your personal information (such as a custodian brokerage firm) to also maintain your confidentiality and keep your information private in accordance with their own privacy policies.

• We do not provide your personally identifiable information to mailing list vendors or marketing companies for any purpose.

• We maintain data security procedures in our offices and our computers are protected to ensure that your information is not placed at unreasonable risk. We limit access to information to only those employees who have a business or professional reason for knowing it.

• Within our firm, disclosure of private client information is an offense subjecting employees to possible termination.

Householding Statements

As a convenience to you, we may consolidate some or all account statements with the same address in the same envelope. This practice is known as "householding." In addition to account statements, other communications from us to our clients may similarly be householded. If you wish to opt out of householding, please call us and let us know that you prefer to receive individual statements and mailing sent in separate envelopes.

Retaining Your Information

We will maintain your files, with your personal information, as long as you are our client and for as long thereafter as is required by law or other requirements to which we are bound. Thereafter, we may dispose of your files and personal information by appropriate means.

We consider the protection of your personal information a serious matter. If you have any questions about our policy and how we handle your personal information, please feel free to call us at 864-288-4221.