June 1, 2001

Pennaluna & Company has been protecting customer privacy for many years. This will tell you more about our commitment to your privacy, in accordance with new SEC Regulation S-P.

We don't ever sell customer information

Pennaluna & Company does not ever sell any type of personal customer information. This includes nonpublic personal information.

Information we may have

To help us give you good service and in order to fulfill obligations imposed on us by law or regulation, we may receive information about you from various sources, including, for example:

• your requests for our products or services, which may provide such data as your physical or email address, financial situation, social security number, and other information you might enter on a new account application, for instance

• your transactions with us or our securities clearing firm, which may provide such data as your account balances, transaction record, payment history and other information

• consumer reporting agencies, for your credit history or other information regarding creditworthiness for margin lending or other transactions, and other outside parties in order to verify representations concerning employment, loan balances and so forth

How we may share it

Pennaluna may share information it has about you only as lawfully permitted or required for legal or routine business reasons, including maintaining or servicing your account. For instance, we may share information: with regulatory and law enforcement authorities; pursuant to legal process or to protect against fraud; with our securities clearing firm in order to service your account and provide products and services to you; and with anyone if you consent to that sharing, for instance if you want us to release data to a possible lender.

Protection

We maintain physical, electronic and procedural safeguards to help keep information protected from unauthorized access. We compile only the minimum information reasonably necessary for us to meet our obligations to customers and to satisfy requirements imposed by the government. We are a small firm with low employee turnover where everyone knows each other well and works near one another; this helps us to monitor proper use of data, detect misuse, and make sure information is accessed only by those who need it to provide products or services to you.

Who our policy covers

This policy applies to consumers who are customers or former customers of Pennaluna & Company.