Privacy in financial transactions and relationships is an important issue. We recognize the importance of protecting personal information as central to our role as a fiduciary. We have developed policies, procedures and various electronic and legal safeguards to protect the confidentiality of information.

We collect nonpublic personal information from the various sources including information we receive from applications, account agreements or other forms; information about transactions with us, our affiliates or others; and information we may receive from attorneys, accountants and others in the normal course of our fiduciary duties.

As a Correspondent Broker Dealer and Registered Investment Advisor, all accounts are held at Raymond James and Associates, Inc. (Member NYSE/SIPC). Because of this relationship, Harbor Financial Services, LLC must disclose all relevant information to Raymond James & Associates. Harbor Financial Services, LLC may share relevant information with companies in the Raymond James family – that is, companies that are owned by Raymond James Financial. That may include information shared by the Heritage Family of Funds with Raymond James broker/dealers and investment advisors, and information shared among other Raymond James financial service providers such as Financial Advisors and insurance and annuity consultants. Raymond James & Associates may also share information with outside vendors who assist by providing tax processing, investment performance reporting, and proxy distribution. These vendors have all contractually agreed that they will not share any information with any third party, except as required by law. We share information only to the extent necessary to process transactions or otherwise service accounts with us. We may also be required to share information by federal and state regulatory agencies having jurisdiction over us.

Simply put, we do not disclose any nonpublic personal information about clients to anyone except as noted above. We follow the same policy with respect to nonpublic information received from all clients and former clients.

Harbor Financial Services, LLC has policies that restrict access to nonpublic personal information to those employees who have need for that information to provide investment alternatives or services, or to employees who assist those who provide investment alternatives or services. We maintain physical, electronic and procedural safeguards to protect nonpublic personal information.

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