At HRC Investment Services, Inc. (“HRC”), we recognize the importance of maintaining your privacy.  The purpose of this notice is to let you know the policy we have developed to protect your personal information.

We do not sell information about, or lists of, our clients.  It is our practice to collect and share information only to provide and maintain our products and services, or as required by law.

We may share with other third parties involved in providing or maintaining your contract or benefit.  We share only information they need to perform their functions.  This may include:

Your account

Other financial institutions such as

Broker-dealers, investment advisers, insurance agents.

For your protection only those who need personal information to provide our products and services, or as the law requires, may have access to it.  We train our employees on how to handle your personal information.  They must follow our rules to keep it confidential and safe.  We maintain physical, electronic and procedural safeguards.  We employ a professional service to properly destroy all documents we no longer need.  The shredding of these documents is done in our presence and on our premises to insure that your information remains secure and confidential.

We keep records of our customers’ transactions and retain them in our office.  This may include:

Account values

Beneficiaries and claims

Payments and account activity

We restrict access to nonpublic personal information about you.  We may disclose nonpublic personal information about our customers, under limited circumstances permitted or required by law to regulators or law enforcement authorities.  We use your personal information to fulfill our regulatory obligations and to help us deliver the best possible service to you.

We collect nonpublic personal information about you from the following sources:  Information we receive from you and your applications or other forms; Information about your transactions with us, our affiliates, or others (including other financial institutions such as mutual fund companies and annuity companies).

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 nonpublic information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you will have the opportunity to opt out of such disclosure.

If you have any questions regarding our privacy policy, please contact us at 800-786-1598.

Sean S. Mohammadi

President

HRC Investment Services, Inc.

Member FINRA/SIPC

Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records and allowing our customers and transact business.

Our plan anticipates two kinds of SBD’s internal and external. Internal SBD’s affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBD’s prevent the operation of the operations of the securities markets or a number of firms, such as a terrorist’s attack, or wide-scale regional disruption due to floods, loss of power etc. Our response to an external SBD relies on other organizations and systems, such as mutual fund and insurance companies and in a limited extent our clearing broker dealer.

In the event of an internal and external SBD that causes the loss of our paper records, we will physically recover these records from our backup tape. Since we deal only in mutual funds and variable annuities we will also have the ability to access the records held at the respective companies. In selected instances HRC will clear other securities transactions through Pershing & Co., a division of BNY Securities Corporation. The clearing firm has provided us with alternative contact persons and organizations in the event it cannot be reached.

In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees and other critical personnel. Although the effects of an SBD will determine the means of alternative communication, the communications option we will employ will be our telephone voice mail and telephone provided our service is operable. In addition, we will retrieve records as the section above.

We now communicate with our customers using the telephone, fax, U.S. mail and very occasionally email. In the event of an SBD, we will assess which means of communications are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past. If we have always communicated by telephone but service is unavailable we will follow up by communicating by U.S. mail.

We now communicate with our employees using the telephone, email and in person. In the event of an SBD, we will assess which means of communication are still available to us. Since we are a small company all our employees have a directory of all employees home addresses and telephone numbers and we have in the past, used the “call tree” method to communicate in emergency situations i.e. inclement weather or power failures. We will do the same in the event of an SBD. Rachel Pino will call key persons and assign them persons to call so that all employees are reached.

Sean S.Mohammadi, a registered principal is responsible for approving the plan and for conducting the required annual review. Rachel Pino, a registered principal, has the authority to execute this BCP.