Privacy Policy

Keeping client information secure is a priority in the investment advisor community, and it is a top priority for Roanoke. We are sending you this privacy notice to help you understand how we handle the personal information about you that we collect and may disclose.

The provisions of this notice will apply to former clients as well as current clients, unless we state otherwise. The non-public personal information that we collect about you comes from the following sources:

• Information we receive from you on applications or other forms;

• Information about your transactions with us or others; and

• Information we receive about you from other sources, such as your custodian, accountant and other third parties.

We do not disclose any non-public personal information about you to anyone, except to non-affiliated third parties in connection with servicing, processing, and accounting for the investment advisory services you have requested or authorized. We may disclose it to other third parties as permitted or required by law, such as in response to subpoenas or as required by our regulators. We restrict access to your personal and account information to those of our employees who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards to guard your non-public personal information.