Holland Capital Management LLC
Notice of Privacy Policy & Practices

Holland Capital Management LLC recognizes and respects the privacy expectations of our customers. We are providing this notice to you so that you will know what kinds of information we collect about our customers and the circumstances in which that information may be disclosed to third parties who are not affiliated with Holland Capital Management LLC.

We collect nonpublic personal information about our customers from the following sources:

• New Account Applications and other forms, which may include a customer’s name, address, social security number, and information about a customer’s investment goals and risk tolerance;
  
  
• Account History, including information about the transactions and balances in a customer’s accounts; and
  
  
• Correspondence, written, telephonic or electronic between a customer and the Holland Capital Management LLC or service providers to Holland Capital Management LLC We may disclose all of the information described above to certain third parties who are not affiliated with Holland Capital Management LLC as permitted by law - for example sharing information with companies who maintain or service customer accounts for Holland Capital Management LLC is permitted and is essential for us to provide customers with necessary or useful services with respect to their accounts. We may also share information with companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

We maintain, and require joint marketers and service providers to Holland Capital Management LLC to maintain policies and procedures designed to assure only appropriate access to, and use of, information about our customers. When information about Holland Capital Management LLC customers is disclosed to nonaffiliated third parties, we require that the third party maintain the confidentiality of the information disclosed and limit the use of information by the third party solely to the purposes for which the information is disclosed or as otherwise permitted by law.

We will adhere to the policies and practices described in this notice regardless of whether you are a current or former customer of Holland Capital Management LLC.