Privacy Statement

Privacy is an important issue for our clients and is a priority at Flagship Capital Management. It is our policy to respect the privacy of all accounts we maintain as investment advisers and to protect the security and confidentiality of nonpublic information relating to those accounts.

Our relationship with clients is our most important asset. We understand that our clients have entrusted us with their private financial information, and we make every effort to maintain that trust. This policy applies to both current and former clients.

The Securities and Exchange Commission's Regulation S-P requires investment advisers to establish and adhere to privacy policies and to notify their clients accordingly.

Personal Information Collected

In order for Flagship Capital Management to effectively service a client's account as an investment adviser, he or she provides us with information necessary to implement the financial services requested. This information may include:

• Information received from a client, such as name, address, telephone number, email address, Social Security number, occupation and income
• Information relating to a client's investment transactions, including account balances, positions and activity
• Information that may be received from various sources with the client's consent or with the consent of the client's broker dealer and/or third-party administrator

Sharing of Nonpublic Personal Information

Flagship Capital Management does not disclose nonpublic personal information relating to current or former clients to any third parties, except as required by the appropriate broker dealer/custodian or third-party administrator, as permitted or required by law, or with the client's prior permission. Flagship has educated our staff with regard to this privacy policy. As a general policy, our staff will not discuss or disclose information regarding an account as described above. Flagship reserves the right to make changes to this policy.