Our Commitment to Privacy: Because of the common concern about privacy on the World Wide Web, we have adopted the following Privacy Policy for our Web site (the "Site"). This Privacy Policy was developed as an extension of our commitment to combine the highest-quality products and services with the highest level of integrity in dealing with our customers and partners. The Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our Site and our products and services. This statement will be continuously assessed against new technologies, business practices and our customers' needs.

What Information Do We Collect? When you visit our Site you may provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis and Site use information collected as you browse our Site.

1. Personal Information: Except for information that your Internet service provider automatically provides to our Web server, such as Web site addresses and possibly user's e-mail addresses, we will not collect any personally-identifiable information about you (e.g., your name, address, telephone number or email address ("personal data") through the Site unless you have provided it to us voluntarily. Please note that e-mail sent to us may not be secure.

As a registered investment adviser, we must comply with SEC Regulation S-P (or other applicable regulations), which requires registered advisers to adopt policies and procedures to protect the "nonpublic personal information" of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information. Non-public personal information includes nonpublic "personally identifiable financial information" plus any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed or transactions entered into on behalf of clients, advice provided by us to clients, and data or analyses derived from such nonpublic personal information. We must also comply with the California Financial Information Privacy Act (SB1) if the firm does business with California consumers.

We maintain safeguards to comply with federal and state standards to guard each client's nonpublic personal information. We do not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:

• As necessary to provide the service that the client has requested or authorized, or to maintain and service the client's account;
• As required by regulatory authorities or law enforcement officials who have jurisdiction over Shelterwood Financial, or as otherwise required by any applicable law; and
• To the extent reasonably necessary to prevent fraud and unauthorized transactions.
  Unless inconsistent with the policy set forth herein, we may use that information in the following ways, unless stated otherwise: we may store and process that information to better understand your needs and how we can improve and enhance our products and services; we may use that information to contact you and send offers and other information to you; and we may provide other third parties with information about visitors to our Site.

2. Web Site Use Information: In some cases, we may automatically (i.e., not via registration) collect technical information when you connect to our Site that is not personally-identifiable. Examples of this type of information include the type of Internet Browser you are using, the type of computer operating system you are using and the domain name of the Web site from which you linked to our Site.

When you view our Site, we also may store some information on your computer. This information will be in the form of a "Cookie" or similar file and can help us in many ways. Cookies are pieces of information that some Web sites transfer to the computers browsing that Web site, and are often used for record-keeping purposes. Cookies perform various functions such as saving your passwords, listing potential purchases (shopping carts) and saving your personal preferences with respect to particular Web sites. Many consider the use of Cookies to be an industry standard.

Your Internet browser is probably set to accept Cookies. With most Internet Browsers, you can erase Cookies from your computer hard drive, block all Cookies or receive a warning before a Cookie is stored. Please refer to your Browser instructions or help screen to learn more about these functions. If you alter the configuration of your browser to refuse Cookies, it is possible that some areas of our site that may use Cookies will not function properly when you view it.

What About Other Web Sites Linked to Our Web Site? We are not responsible for the practices employed by Web sites linked to or from our Site nor the information or content contained therein.

Please remember that when you use a link to go from our Site to another Web site, our Privacy Policy is no longer in effect. Your browsing and interaction on any other Web site, including Web sites that have a link on our Site, are subject to that Web site's own rules and policies. Please read over those rules and policies before proceeding.

Your Consent: By using our Site you consent to our collection and use of your information as described in this Privacy Policy. If we change our privacy policies and procedures, we will post the revised Privacy Policy on our Web site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. We encourage you to review this Privacy Policy each time you visit our Site to check for any updates or changes. Any changes shall be effective when posted to this Site.

Last Updated: June 2008