SOL Capital Management Company (SOL) is an SEC registered investment advisor located in Rockville, Maryland. SOL is in compliance with the current registration and/or notice filing requirements imposed upon SEC registered investment advisors by those states in which it maintains clients. SOL may only transact business in those states in which it is registered, or qualify for an exemption or exclusion from registration requirements. The SOL website is limited to the dissemination of general information pertaining to SOL’s investment advisory services. Accordingly, SOL does not, and will not, effect or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication with a prospective client shall be conducted by a representative of SOL who is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.
As you may know, the U.S. Securities and Exchange Commission has adopted Regulation S-P, “Privacy of
Consumer Financial Information,” which applies to, among other things, brokers, dealers, investment
companies and registered investment advisers. Generally speaking, Regulation S-P requires that these
entities limit their use of certain non-public personal information they may learn about you, such as your
name, occupation and financial history. In addition, state laws may further limit these entities’ use of such
information. As a registered investment adviser, SOL Capital Management Company (SOL) is required to
provide our clients with an annual notice describing our privacy policies and practices. The policies
described below apply both to current clients and to individuals who no longer have a relationship with
Information We Collect. In order to provide our services to you we collect non-public personal
information about you from the following sources: (1) information we receive from you on brokerage
account applications, investment advisory contracts or other forms or that you otherwise provide, such as
your name, birth date, telephone number, social security number, tax identification number, bank account
information, address and income; (2) information about transactions in accounts managed by SOL, such as
your trading history and account balance; (3) information we may receive from non-affiliated third parties;
and (4) through the use of session “cookies” that record encrypted authentication information, but which
expire when you log out of our website or close your web browser.
How We Use This Information. In general, the information we collect is used for the purpose of
providing you with the services you have requested in the manner you have requested them. For
example, you may request that SOL post your account information in the password-protected area of our
website for you to view at your leisure. If you have not requested this specifically, it is not posted there for
you. While we may use the information we collect for purposes of marketing our services to you, we do
not sell or rent any information about you, including any non-public personal information, or any
information collected during your use of the password-protected area of our website. We have no
intention of doing this in the future. Nor do we share your non-public personal information with nonaffiliated
companies so that they may market their products or services to you or engage in joint
marketing with us. We have no intention of doing this in the future.
Who Has Access To This Information? We make no disclosure of any non-public personal information
we collect to any non-affiliated third parties other than to government regulatory agencies or as otherwise
permitted or required by law. We limit access to non-public personal information to individuals in our
organization who need it in order to perform their jobs, and to non-affiliated third parties who provide
services you request. For instance, we may provide some non-public personal information to service
providers so that we (and the service providers) can provide services to you. As one example, non-public
personal information that we collect from you and your transactions with us or non-affiliated third parties
is shared with financial services providers, such as the custodians that handle the securities custody and
trading for your portfolio(s). Our employees and these service providers are contractually prohibited from
disclosing or using this information for any purpose other than that for which it was disclosed. We also
may disclose your non-public personal information when we believe such disclosure is required to comply
with a legal requirement, such as in response to a court order, subpoena or in the course of a legal proceeding.
We may also disclose personal information as otherwise permitted by applicable law.
Business Transfers. If there is a change of control in SOL’s business (whether by merger, sale, or
otherwise), our client information could be sold as part of that transaction and your non-public personal
information could potentially be used by the purchaser. However, if the purchaser materially changes this
privacy statement or the information-handling practices described herein, such changes will be described
to you and you will have the ability to opt-out of any proposed changes in the way your non-public
information will be used, if such opt-out right is required under the law.
How We Protect Your Information. At SOL, the security and confidentiality of our clients’ non-public
personal information is carefully guarded. We restrict access to non-public personal information about
you to those service providers, or employees of SOL who need to know that information in order to
provide products or services to you. SOL does not construct or sell any list, description or other grouping
of our clients’ non-public personal information derived from information that is not publicly available. We
have no intention of doing so in the future.
In order to protect your non-public personal information, we maintain physical, electronic and procedural
safeguards that comply with applicable standards. Your account information and profile are passwordprotected.
We monitor for intrusion attempts, conduct security audits and inspections, and use firewalls
and SSL (Secure Socket Layer) data and password encryption technology. Notwithstanding these security
measures that we use to help protect your non-public personal information, no electronic data
transmission or storage of information can be guaranteed to be secure. Please note that we cannot ensure
or warrant the security of any information you provide to us.
How to Help Protect Your Information. Because you, too, play a role in protecting your non-public personal information, we recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. When using the password-protected area of our web site, remember to sign out of your account and close your browser window when you have finished your service. This is to help ensure that others cannot access your non-public personal information if you share a computer with someone else or are using a computer in a public place where others may have access to it.
any material changes we will notify you prior to the change becoming effective.
Your Right to Review Your Information. You may, if you wish, request that we send you a summary of
the information we have collected about you, and you may seek correction of information you believe to
Please be assured that we at SOL are committed to protecting the privacy and confidentiality of your nonpublic
personal information. If you have questions about this notice or about how your confidentiality is
being protected, please do not hesitate to call us at (301) 881-3727.
SOL Capital Management Company