Confidentiality

LYONS & SEACREST, P.C.

Disclosure of Nonpublic Personal Information
Policies and Practices

On November 12, 1999, President Clinton signed into law the Gramm-Leach-BIiIey Act (“GLBA”). Under the GLBA, we are required to inform you of our policies and practices regarding the disclosure of nonpublic personal information, which we possess about you, to third parties. The Federal Trade Commission (“FTC”), which administers the GLBA, issued final regulations on November 13, 2000 that requires we make the following disclosures to you by July 1, 2001.

  1. Categories of Information We Collect. We collect nonpublic personal information about you from the following sources:
    • Information we receive from you to assist us in preparing your federal, state and local income tax returns.
    • Information we receive from you to prepare personal and business financial statements.
    • Information we receive from you regarding your personal and business financial matters.
  2. Categories of Information We Disclose. We may disclose the following kinds of nonpublic personal information about you:
    • Information we provide to federal, state and local tax agencies when we file tax returns on your behalf.
    • Information we provide to third party software and computer support agencies in the context of repairing or troubleshooting computer and software problems.
    • Information we disclose to third parties when we deliver your personal and/or business financial statements to them at your direction or with your authorization.
    • Information we may disclose to third parties at your direction or with your authorization.
    • Business and/or financial statements or other financial information we may disclose (on a confidential basis) to professional and/or regulatory bodies performing peer reviews of our accounting practices.
  3. Categories of Information We Disclose and Parties to Whom We Disclose. We do not disclose any nonpublic personal information about our clients or former clients to anyone, except as permitted by law.
  4. Categories of Parties to Whom We Disclose. We may disclose nonpublic personal information about you to the following types of third parties:
    • See disclosures described in 2 above.
    • We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law.
  5. Service Provider/Joint Marketing Exception. Except as described in paragraphs 2, 3 and 4 above, we do not disclose or sell any information we collect about you to companies that perform marketing services. We may disclose customer lists to third parties in a confidential arrangement: (a) if a partner leaves the firm; or (b) if we engage in a merger or sale of our practice to another accounting practice or if we acquire another accounting practice; or (c) if a new partner joins our practice.
  6. Explanation of Opt Out Right. If you prefer that we not disclose nonpublic information about you to nonaffiliated third parties, you may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may write us at the address appearing in this letter.
  7. Confidentiality and Security. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards within our business office to guard your nonpublic personal information.

You should also know that in addition to restrictions imposed by the GLBA, we are restricted from disclosing information about your personal and business financial matters: (i) by law as a result of the accountant/client relationship recognized by Colorado State Law; (ii) by ethical rules and regulations imposed by the Colorado State Board of Accountancy, the Colorado Society of CPA’s and the American Institute of Certified Public Accountants; and (iii) by the Internal Revenue Code of 1986, as amended.