Global Trust Asset Management, LLC (“Global Trust”) is committed to ensuring
our customers, or clients, have access to a broad range of investments and services
to help them achieve their personal financial goals. Accurate information lies at
the heart of our pledge to provide these investments and services, and we strive to
protect your personal nonpublic information. In the course of doing business with
Global Trust, customers are requested to share financial information and they may
be asked to provide other personal details. Customers can be assured that Global
Trust is diligent in its efforts to keep such information confidential.


Financial companies choose how they share your personal information. Federal
law gives consumers the right to limit some but not all sharing. Federal law also
requires us to tell you how we collect, share and protect your personal information.
Please read this notice carefully to understand what we do.

Recognition Of A Customer's Expectation of Privacy

At Global Trust, we believe the confidentiality and protection of customer
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 customers’ trust. Thus, the safekeeping of customer information is a
priority for Global Trust.

Information Collected

In order to tailor available financial services to your specific needs, Global Trust
may request that you complete a variety of forms that require nonpublic personal
information about your financial history and other personal details, including but
not limited to, your name, address, social security number, assets, income and
investments. Global Trust may also gather information about your transactions
with us, our affiliates and others.

Categories Of Information That May Be Disclosed

While Global Trust may disclose information it collects from applications and
other forms, as described above, we at Global Trust also want to assure all of
our customers that whenever information is used, it is done with discretion. The
safeguarding of customer information is an issue we take seriously.

Categories Of Parties To Whom We Disclose Nonpublic Personal Information

Global Trust may disclose nonpublic personal information about you to the
following types of third parties – selectively chosen financial service providers who
we believe have valuable investments or services that could benefit you. Whenever
we do this we carefully review the company and the investment or service to make
sure that it provides value to our customers. We share the minimum amount of
information necessary for that company to offer its investment or service. We may
also share information with unaffiliated companies that assist us in providing our
services to our customers; 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; and at the request
or with the permission of a customer. Some examples of unaffiliated companies
that we share information may include Fidelity Investments, Charles Schwab and
Advent. An example of an affiliated company would be Nowlen, Holt & Miner,
P.A., our related accounting firm. Global Trust, its affiliated and its unaffiliated
companies do not share your information with marketing companies.

Opt Out Right

If you prefer we not disclose nonpublic personal information about you to affiliated
or unaffiliated third parties, you may opt out of those disclosures; that is, you may
direct us not to make those disclosures (other than disclosures permitted by law).
If you wish to opt out of disclosures to unaffiliated third parties, you may make this
request in writing to Global Trust, Attn: Opt Out Notices, 515 North Flagler Drive, Suite
1700 West Palm Beach, FL 33401

Confidentiality And Security

We restrict access to nonpublic personal information about you to those employees
who need to know that information to provide products and services to you. We
maintain physical, electronic and procedural safeguards that comply with federal
standards to guard your nonpublic personal information. If you decide to close your
account(s) or become an inactive customer, we will adhere to the privacy policies
and practices as described in this notice.

Please call us at (561) 472-0191 if you have any questions, because your privacy, our
professional ethics and the ability to provide you with quality financial services are
very important to us.