Privacy PolicyIndependence Capital Financial Partners, LLC (ICFP)

Gathering Information:

Independence Capital Financial Partners (ICFP) collects personal information about you to help us serve your financial needs, process transactions in your account(s), provide client service, offer new products or services, and fulfill legal and regulatory requirements. ICFP collects nonpublic personal information from you as well as from other sources. The sources and the information collected may include: information you provide to us, to our affiliated entities, or to your registered representative on applications and related forms, thorough discussions with our client service staff, or on our website, such as, but not limited to, address, social security number, birth date, net worth, assets, income, or medical information; if applying for insurance. Also, information regarding your transaction history with us, such as products or services purchased, account balances, trading history, and payment history.

Sharing Information:
We may disclose any of the nonpublic personal information that we collect about you, as required to conduct our business and as permitted or required by law. We may share information about our clients with our affiliated Investment Adviser and/or with unaffiliated financial or nonfinancial services providers, such as insurance companies, mutual fund companies, banks, investment firms, third-party administrators, clearing firms, and other third parties who assist us in providing account maintenance or customer service to your account(s). We also may share your information with regulators and law enforcement organizations or in response to a subpoena or discovery request, as permitted or required by law. We do not sell, share, or disclose your nonpublic personal information to unaffiliated third-party marketing companies. If the advisor servicing your account(s) leaves ICFP to join another financial institution, the advisor may retain copies of your personal information with the new firm but is otherwise required to keep confidential the personal information obtained from you while the advisor is affiliated with ICFP, and he or she may only use it to service your account(s).

Safeguarding Policy:
ICFP recognizes the need to prevent unauthorized access to the information we collect, including information held in electronic format. ICFP authorizes access to your nonpublic personal information only to personnel who need that information to serve you and to conduct our operations. We maintain physical, electronic, procedural, and contractual safeguards regarding your nonpublic personal information to ensure that we comply with our own policy, industry practices, and federal and state regulations. And we train our employees in the proper handling of sensitive information. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and the practices as described in this notice.