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NOTICE OF PRIVACY POLICY

Palisade Capital Management, L.L.C. is committed to protecting your privacy. We have established practices to ensure the confidentiality of your personal information.

Collection of Information

We may collect nonpublic personal information about you from the following sources:

- Account applications or other forms, which may include your name, address and social security number;

- Written and electronic correspondence and telephone contacts;

- Account history, including information about your transactions and balances in your accounts with us, our affiliates or our clearing brokers; and

- Information from consumer reporting agencies.

Disclosure of Information

We do not disclose any nonpublic personal information about our customers or former customers to non-affiliated third parties, except as permitted by law. We do not sell your personal information to third parties for their independent use.

Confidentiality and Security of Information

Access to your information is limited to personnel who need the information to perform their job responsibilities. We maintain physical, electronic and procedural safeguards to protect this information.