NOTICE OF PRIVACY PRACTICES

The Advisor, Ifrah Financial Services, Inc., an investment advisory firm, is committed to safeguarding the confidential information of its clients. We do collect nonpublic personal information in order to open and administer your accounts with us and to provide you with accurate and pertinent advice. We hold all nonpublic personal information you provide to us in the strictest confidence. If we were to change our Firm policy, we would be prohibited under the law from doing so without advising you first.

Ifrah Financial Services, Inc. collects personal information about you from the following sources:

• Applications or other forms.
• Discussions with unaffiliated third parties.
• Information about your transactions with us or others.
• Questionnaires.
• Tax Returns.
•  Estate Planning Documents.

Ifrah Financial Services, Inc. uses your personal information in the following manner:

• We do not sell your personal information to anyone.
• We will provide notice of changes in our information sharing practices. If, at any time in the future, it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so you will have the opportunity to opt out of such disclosure.
• We maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.
• For unaffiliated third parties that require access to your personal information, including, attorneys, accountants, insurance agents and brokers, we require strict confidentiality in our agreements with them and expect them to keep this information private. Federal and state regulators also may review Firm records as permitted under law.
• We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
• Individuals who are signatories on the same advisory agreement with Ifrah Financial Services will be considered to be part of the same household. Information on all accounts under a given household may be shared with every individual who is reflected on the agreement.