Privacy Notice

WINNING POINTS ADVISORS, LLC

PRIVACY NOTICE

 (9/25/11)

Client Information Privacy Principles

Like most industries today, the financial services industry is rapidly being shaped by technology, which is literally changing the way we do business. To be successful in this environment, we must continue to insure that our clients are confident that we will manage their financial affairs expertly and confidentially.

Winning Points Advisors, LLC (hereafter “Winning Points”) collects personal, private information from its clients in order to determine the client’s specific investment goals and objectives, which will assist in determining how to adequately service the client account based on the services provided by Winning Points, as disclosed in Winning Points’ Form ADV Part 2A.

Recognition of a Client’s Expectation of Privacy:  At Winning Points we believe the confidentiality and protection of client information is one of our fundamental responsibilities.  And while information is critical to providing quality service, we recognize that one of our most important assets is our clients’ trust.  Thus, the safekeeping of client information is a priority for Winning Points.

Use, Collection, and Retention of Client Information: Winning Points limits the use, collection, and retention of client  information to what we believe is necessary or useful to conduct our business, provide quality service, and offer products, services, and other opportunities that may be of interest to our clients. Information collected may include, but is not limited to: name, address, telephone number, tax identification number, date of birth, employment status, annual income and net worth.

Maintenance of Accurate Information: Winning Points recognizes that it must maintain accurate client records.  The above referenced information is collected at the inception of your relationship with Winning Points.  Therefore, Winning Points will contact you periodically to review your overall account holdings, and to ensure that personal/confidential information contained in your file is accurate.  Winning Points also request that you review any information provided to you related to your advisory account, and notify Winning Points promptly on the discovery of erroneous information.  Winning Points will respond to a comment/request to correct inaccurate information immediately.

Limiting Employee Access to Information:      At Winning Points, employee access to personally identifiable client information is limited to those employees that have a business reason to know such information.  Employees are educated on the importance of maintaining the confidentiality of client information and on these Privacy Principles.  Because of the importance of these issues, all Winning Points employees are responsible for maintaining the confidentiality of client information and employees who violate these Privacy Principles will be subject to disciplinary measures.

Protection of Information via Established Security Procedures: Winning Points recognizes that a fundamental element of maintaining effective client privacy procedures is to provide reasonable protection against the unauthorized access to client information.  Therefore, Winning Points has established appropriate security standards and procedures to guard against any unauthorized access to client information.

Restrictions on the Disclosure of Client Information:  When it comes to sharing client information with unaffiliated companies, Winning Points places strict limits on who receives specific information about client accounts and other personally identifiable data.

We may share information with unaffiliated companies that assist us in providing our products and services to our clients; in the normal course of our business (for example, with consumer reporting agencies and government agencies); when legally required or permitted in connection with fraud investigations and litigation; in connection with acquisitions and sales; and at the request or with the permission of a client.

Maintaining Client Privacy in Business Relationships with Third Parties:  If we provide personally identifiable client information to a third party with which we have a business relationship, we will insist that the third party keep such information confidential, consistent with the conduct of our business relationship.

Disclosure of Privacy Principles to Clients: Winning Points recognizes and respects the privacy expectations of our clients.  We want our clients to understand our commitment to privacy in our use of client information.  As a result of our commitment, we have developed these Privacy Principles which are made readily available to our clients.  Clients who have questions about these Privacy Principles or have a question about the privacy of their client information should call us at (561) 367-9111.

These Privacy Principles apply to individuals, and we reserve the right to change these Privacy Principles, and any of the policies or procedures described above, at any time.  Under such circumstances, we will provide you with an updated set of our policies, and will provide adequate time for you to opt out of any information sharing arrangement.  These Privacy Principles are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreements we have with our clients.