BAINCO INTERNATIONAL INVESTORS PRIVACY POLICY

Respecting and protecting client privacy is vital to our business. By explaining our Privacy Policy to you, we hope that you will better understand our commitment to keeping client information private and secure.

Our commitment to your privacy

We take our responsibility to protect the privacy and confidentiality of our client information very seriously. We maintain physical, electronic, and procedural safeguards to store your information and secure it against unauthorized access, alteration and destruction. Our control policies, for example, authorize access to client information for employees and other individuals who need the information to complete their work.

Our employees are required to protect the confidentiality of your information and to comply with our established policies. They may access information only when there is an appropriate reason to do so. Employees who violate our Privacy Policy are subject to disciplinary action.

Extent of our Privacy Policy coverage

We provide our Privacy Policy to clients when they open a new account and annually thereafter. If we materially change our Privacy Policy, we will notify you. This Privacy Policy applies to the relationships of both current and former clients of Bainco International Investors (Bainco).

How we collect information about our clients

We obtain most of our information from you when you apply for, access and use the financial services offered by Bainco. We limit the collection and use of information to the minimum necessary to provide superior service to you.

Why we gather client information

We use the information we have about you to provide superior client service, offer more convenient access to our services, and make a wider range of services and investment products available to you. We do not disclose your personally identifiable information to third parties except as described in this Policy.

Disclosure of information for legal and routine business reasons

We may disclose information when required to do so by law, such as disclosure to attorneys or other professionals. In addition, information may be disclosed for audit purposes or to law enforcement and regulatory agencies. Furthermore, we may disclose information to third party service providers to enable them to provide us with business services such as computer or data maintenance, processing services, or to facilitate transactions requested by you. Except in those specific limited situations, we will not make any disclosures of information to other companies who may want to sell their products or services to you without your consent.

Bainco assists clients in obtaining a wide array of financial products and services such as loans, investments and insurance. We will use the information we have about you, such as net worth, income tax, estate planning and new account information, to provide you with the full range of investment options and services available through Bainco.

We believe that the use of your information by Bainco employees will result in improved client service and responsiveness, increased access to new service offerings and immediate detection of unusual behavior that will prevent unauthorized transactions or fraud within your account.

In closing

We reserve the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. This notice complies with a recently enacted Federal law and new SEC regulations regarding privacy.

If you have any questions or comments about Bainco's Privacy Policy, please contact Robert Katz at (617) 536-0333.

NEWBURY STREET CAPITAL PRIVACY POLICY

Respecting and protecting client privacy has been vital to our business. By explaining our privacy policy to you, we hope that you will better understand our commitment to keeping client information private and secure.

Our Commitment to your Privacy

We take our responsibility to protect the privacy and confidentiality of our client information very seriously. We maintain physical, electronic, and procedural safeguards to store and secure information about you from unauthorized access, alteration and destruction. Our control policies, for example, authorize access to client information only by individuals who need access to do their work.

Our employees are required to protect the confidentiality of your information and to comply with our established policies. They may access information only when there is an appropriate reason to do so. Employees who violate our Privacy Policy are subject to disciplinary process.

Extent of our Privacy Policy Coverage

We provide our Privacy Policy to clients when they open a new account and annually after that. If we materially change our Privacy Policy, we will notify you. This Privacy Policy applies to the relationships of current and former clients of Newbury Street Capital (a broker dealer that clears through Pershing).

How we collect information about our clients

We obtain most of our information from you when you open new accounts, transact trades and use other services offered by Newbury Street Capital. We limit the collection and use of information to the minimum necessary to provide superior service to you.

Why we gather client information

We use the information we have about you to provide superior client service, offer more convenient access to your account and our services, and make a wider range of services and investment products available to you. We do not disclose information to third parties that is personally identifiable to you as a client or former client, except as described in this Policy.

Disclosure of information for legal and routine business reasons

We may disclose information when required to do so by law, such as disclosure to attorneys or other professionals. In addition, information may be disclosed for audit purposes or to law enforcement and regulatory agencies. Further, we may disclose information to third party service providers to enable them to provide business services such as custody of your assets at Pershing, performing computer related or data maintenance or processing services for us or to facilitate the processing of transactions requested by you. Except in those specific, limited situations, we will not make any disclosures of information to other companies who may want to sell their products or services to you without your consent.

Newbury Street Capital may assist clients in utilizing a wide array of financial products and services such as margin loans, restricted stock sales, and option writing. We will use the information we have about you, such as personal identification, account agreement, and account information, to provide you with the entire group of investment options and services available through Newbury Street Capital.

We hope that the use of your information will result in improved client service and responsiveness, access to new service offerings and detection of unusual behavior to help prevent unauthorized transactions or fraud within your account.

In closing

We reserve the right to change this privacy policy. The examples contained within this privacy policy are illustrations and they are not intended to be exclusive. This notice complies with a recently enacted Federal law and new SEC regulations regarding privacy.

If you have any questions or comments about Newbury Street's Capital Privacy Policy, please contact Robert Katz at (617) 536-0333.

Phone 617.536.0333 | Fax 781.239.3333 | E-mail info@bainco.com | Employees | Privacy