HILTON FINANCIAL GROUP, LLC, an independent Financial Planning Firm, considers

client privacy to be a fundamental aspect of our client relationships. We are committed to

maintaining the confidentiality, integrity, and security of our current, prospective and former

clients’ personal information.

In the course of providing you with advisory services, we may collect, retain, and use client

information for the purpose of administering our operations, providing client service, and

complying with legal and regulatory requirements. This information may come from sources

such as account applications, investment policy statements, from your transactions, and other

forms from other written, electronic or verbal correspondence from your brokerage, attorney,

accountant or other advisor you may employ. We do not sell, exchange or disclose client

information with outside organizations unless the third party is essential in administering our

operations or except as required or permitted by law.

No confidential information, whatever the source, regarding any customer or client, may be

disclosed except the following: We reserve the right to disclose or report personal information

where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities. Adviser reserves the right to disclose information with other Adviser employees in connection with the Adviser’s business and to non-affiliated third parties with whom the Adviser has a contractual agreement to jointly offer, endorse or sponsor a financial product or service; and to service and maintain customer accounts including effectuating a transaction. Adviser may disclose information about client or client’s account to a non-affiliated third party at client’s written request.

Finally, to further safeguard client information digitally, we maintain password protected

systems, updated anti-virus and anti-spyware software, and encrypted hardware and software

firewalls.