Pursuant to Title V of the Gramm-Leach-Bliley Act and United States Securities and Exchange Commission (“SEC”) Regulation S-P (17 CFR 248.1-248.30), this document sets forth the Privacy Policy of Smart Execution, LLC hereafter referred to as “The Company” concerning the privacy interests of individual consumers and customers (described below and hereinafter referred to as “customers”) of financial services. Smart Execution, LLC are registered as a California corporation that maintain their principal offices in San Clemente, CA. The Companies are all securities broker dealers registered with the SEC. Among their other securities-related memberships and associations, The companies may maintain other industry memberships and associations including: National Association of Securities Dealers, Inc. (“NASD”); Chicago Stock Exchange, Inc. (CHX); Pacific Stock Exchange (Equity Permit Holder [EPH]); National Futures Association (NFA); Securities Investor Protection Corporation (SIPC); as well as others. The Company may act as in the capacity of an introducing broker/dealer or a broker/dealer that trades its proprietary account in accordance with all laws, rules and regulations applicable. When The Companies act in the capacity of an introducing broker/dealer, The Company’s principal business is to provide institutional and/or retail brokerage services, pursuant to a written clearing agreement that allocate roles, duties and responsibilities between the clearing or “carrying” firm Wedbush Morgan Securities, Inc., (WEDZ) which on a “fully disclosed” basis, provides certain limited and defined “back office” securities clearing, custodial and processing services on the behalf of (The Companies) the “introducing” or “correspondent” broker dealer (see, e.g., NYSE Rule 382 and NASD Rule 3230). The Companies in their capacity as an introducing broker/dealer and WEDZ in its capacity as a securities clearing firm receive and/or come into contact with certain nonpublic personal information concerning the current and/or former customers of the “introducing” or “correspondent” broker dealers for which WEDZ provides securities clearing services, including but not limited to certain nonpublic personal information related to the securities account(s) that said customers open and/or maintain with said introducing or correspondent broker/dealers. Any and all such nonpublic personal information related to such customers and/or such customers’ securities account(s) is hereinafter referred to as “nonpublic personal information”. The Companies receive and/or comes into contact with the nonpublic personal information only for purposes of conducting its business as described above. For convenience herein, “you” or “you” refers to any and all customer(s) described above.

NO SALE OF YOUR NONPUBLIC PERSONAL INFORMATION. THE COMPANIES DO NOT SELL YOUR NONPUBLIC PERSONAL INFORMATION. NONPUBLIC PERSONAL INFORMATION COLLECTED.

A. Information from you: (1) information you provide in connection with any securities account, margin loan, debit card any other financial product or service, whether in writing, in person, by telephone, electronically or by any other means, such as your name, address, social security number, tax ID number, assets, income, investment objectives, financial situation and debt; and (2) information The Companies obtain (or may obtain) for the purpose of tax reporting to you and to the various agencies to which The Companies report as required by law, including disclosures on various Internal Revenue Service (“IRS”) forms that The Companies collect for tax reporting purposes.

B. Information about your securities and/or other transactions: (1) information The Companies collect and relates to account balance, payment history, trading activity and any other transactions which The Companies act in the capacity of an introducing broker/dealer, (2) information The Companies collect as part of servicing your account(s), (3) information The Companies collect through an Internet “cookie” (an information collecting device from a web server).

C. Information about your transactions with nonaffiliated third parties: (1) information from nonaffiliated third parties pursuant to law, rules, regulations, standard securities industry practice and/or legal process, including information and/or documents received, shared, produced or provided in connection with a subpoena, discovery request or other legal process compelling production; and (2) information from nonaffiliated third parties related to servicing your account.

D. Information from a consumer-reporting agency: (1) information from a consumer reporting agency regarding your creditworthiness or credit history or other information with regards to margin lending or other financial transactions; (2) information from other outside sources regarding their employment of, credit to or other relationship with you, or verifying representations made by you, such as your employment history, loan or credit card balances.

NONPUBLIC PERSONAL INFORMATION DISCLOSED TO AFFILIATES AND NONAFFILIATED THIRD PARTIES. The Companies disclose to affiliates and nonaffiliated third parties nonpublic personal information only in connection with The Companies providing securities services in the capacity of an introducing broker/dealer. Such disclosures include, among other things, information related to transactions, settlement, billing, payment, processing, clearing, transferring, reconciling, collection and tax reporting. Such disclosures may be provided to affiliates and nonaffiliated third parties: (i) as required or necessary to carry out fully and properly the securities business conducted by The Companies (such as, for example, disclosures to affiliated and nonaffiliated third party service providers supplying to The Company’s computer related, document processing and delivery, and data maintenance or processing services, and disclosures to nonaffiliated third parties such as securities clearing agencies and entities); (ii) as required by law or legal process; or (iii) with your consent.

FORMER CUSTOMERS. The Companies will disclose nonpublic personal information about former customers only as permitted and/or required by law or legal process, or with your consent.

CONFIDENTIALITY AND SECURITY OF NONPUBLIC PERSONAL INFORMATION. The Companies are committed to implementing and maintaining commercially reasonable and appropriate measures to maintain your nonpublic personal information in a secure and confidential fashion. The Company’s information and security procedures include, but are not limited to, the following features: • Access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals and controls to prevent The Companies employees from providing nonpublic personal information to unauthorized individuals who may seek to obtain this information through fraudulent means. • Physical access restrictions at locations containing nonpublic personal information, such as buildings, computer facilities and record storage facilities to restrict access to unauthorized individuals. • Encryption, where appropriate, of electronic customer nonpublic personal information. • Stringent pre-employment screening, including fingerprinting, and segregation of duties for The Companies employees with responsibilities for or access to nonpublic personal information. • Monitoring systems and procedures to detect actual and attempted attacks on or intrusions into information systems containing nonpublic personal information. • Response programs that specify actions to be taken when The Companies suspects or detects that unauthorized individuals may have gained access to nonpublic personal information. • A disaster recovery plan to protect against loss of or damage to nonpublic personal information due to potential hazards, such as fire and water damage or technological interruption or failure. The Companies regularly review, revise and update thier information security program to account for changes in technology. The Companies reserve the right to change this Privacy Policy at any time.