Privacy Policy

We obtain information about you from different sources. Most of our information about you is derived from the account opening process and our initial meeting with you. We may also later gain information from conversations with your other advisors, or with family members or business associates.

We use this information to more knowledgeably implement the investment policy for your portfolio, as well as implement other related actions pertaining to your portfolio and your account. We may discuss aspects of your situation with one or more of our or your advisors, such as an attorney, a pension consultant, a computer consultant or an accountant. Some of this information, the information on your account application, goes to the securities firm (such was the Schwab Institutional Division of Charles Schwab & Co) where your portfolio is domiciled or from whom we deal in securities on your behalf, and we may discuss aspects of your account with personnel from that firm or other securities firms that we may deal with from time to time in order to better serve you. Your information may be available to firms that service Clark Asset Management, such as outside information systems consultants, computer and data service providers, and accountants or attorneys.

We have no owned affiliates that we share this information with. We do not sell this information, and we generally do not disclose to others that we have a client relationship with you. The information on your account application is subject to disclosure on presentation of a subpoena, and is disclosed to various federal anti-terrorist database administrators, such as the Office of Foreign Asset Control. Information transmitted electronically to us over the Internet is subject to wiretap and monitoring for the purpose of protecting the security of the Homeland by the National Security Agency, the FBI, and the Department of Homeland Security. Telephone communications transmitted over the facilities of the local phone company, formerly SBC renamed AT&T, may be subject to warrantless and unlimited searches and eavesdropping by the National Security Agency on an ongoing basis.

You will not get offers for products or services from other companies from Clark Asset Management disclosures, except in specific circumstances, such as an attorney referral for a specific situation that you may be involved in and request. We will not reveal that you have a client relationship with us, except in conversations with persons such attorneys, accountants, or pension administrators in circumstances who have a fiduciary obligation to your interests.

Here is the California Financial Privacy Information Act:

http://www.leginfo.ca.gov/cgi-bin/displaycode?section=fin&group=04001-05000&file=4050-4060