Dowling & Yahnke, LLC, an independent investment management firm, is committed to safeguarding confidential information. We have adopted policies intended to protect the personal information of all of our present and former clients.

The categories of non‐public information we collect from you about your personal finances may include: 1) information we receive from you on custodian applications or other forms, 2) verbal or written communications, and 3) information about transactions enacted on your behalf at your investment custodian. We use this information to assist you in meeting your personal financial goals.

In order to implement strategies and transactions, we may be required to provide this information to non‐affiliated third parties. Only the information required to implement the strategy or transaction is provided. Non‐affiliated third parties often include discount broker/dealers, tax professionals, attorneys, bankers, and other investment‐related businesses with which you do business. If required, we may disclose non‐public personal information, such as name and brokerage account number, to a third‐party service provider in connection with the filing of class action securities claims on your behalf. Participation is strictly voluntary and you may opt out of this service at any time.

Internally, we limit access to your personal information to those employees who need to know in order to conduct our business, service your account, and assist you in accomplishing your investment objectives. In addition, each employee is required to comply with Dowling & Yahnke, LLC’s Code of Ethics, Privacy Policy, and Privacy & Information Security Policy, which reiterates the confidentiality of all our clients’ information. In complying with applicable laws and regulations, we maintain physical, electronic, and procedural safeguards to protect your personal information.

We maintain a secure office to ensure that your information is not placed at unreasonable risk. Electronic information is subject to all reasonable access control and intrusion prevention technologies. Physical access to electronic and paper records is secured with access codes and locks. We do not provide your personal information to mailing list vendors or solicitors.

Personally identifiable information about you will be maintained during the time you are a client, and thereafter, as such records are required to be maintained by federal and state securities law, and consistent with the CFA Standards of Professional Conduct and the CFP Board’s Standards of Professional Conduct. As permitted by law, federal and state securities regulators may review Dowling & Yahnke, LLC’s records and your personal records, as well as consultants and attorneys to assist in meeting our regulatory obligations. After the required period of record retention, all information may be destroyed.

We reserve the right to modify this policy at any time. You will be immediately notified of any material changes.

June 2017