HedgeCoVest.com and HedgeCoVest LLC, now doing business as Smart X, do not disclose nonpublic personal information about its current or former clients to third parties other than as described below.  The HedgeCoVest LLC/Smart X Platform, does collect information about clients (such as name, address, social security number, assets and income) from its user registration process, its discussions with clients, from documents that clients may deliver to HedgeCoVest LLC/Smart X, and in the course of providing services to clients. In order to service the clients’ accounts and effect transactions, HedgeCoVest LLC/Smart X may provide clients’ personal information to HedgeCoVest LLC/Smart X affiliates and to firms that assist HedgeCoVest LLC/Smart X in servicing such clients’ accounts and have a need for such information to provide the service that the client has requested or authorized, or to maintain and service the client’s account.  HedgeCoVest LLC/Smart X may provide clients’ personal information as required by regulatory authorities or law enforcement officials who have jurisdiction over HedgeCoVest LLC/Smart X, or as otherwise required by any applicable law and, to the extent reasonably necessary, to prevent fraud and unauthorized transactions.  HedgeCoVest LLC/Smart X does not otherwise provide information about clients to outside firms, organizations or individuals except as required or permitted by law. Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation, and is not permitted to share or use this information for any other purpose.

Safeguarding standards encompass all aspects of the HedgeCoVest LLC/Smart X Platform that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that HedgeCoVest LLC/Smart X may adopt are included in its written supervisory procedures and are available upon request.