January 4, 2008

Lightship Mutual recognizes the importance of privacy. This policy applies to all of the products, services, and websites offered by Lightship Mutual LLC, its subsidiaries, and affiliated companies (collectively, Lightship Mutual's "services").

Lightship Mutual adheres to the US safe harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement, and is registered with the U.S. Department of Commerce's Safe Harbor Program.

If you have any questions about this Policy, please feel free to contact us through our website or write to us at Privacy Matters, c/o Lightship Mutual, 3525 Piedmont Road, 7 Piedmont Center, Suite 300, Atlanta, GA 30305 USA.

Topics

• Information We Collect and How We Use It
• Choices for Personal Information
• Information Sharing
• Information Security
• Data Integrity
• Accessing and Updating Personal Information
• Enforcement
• Changes to This Policy
• Disclosure Statement
• Copyright Statement
  
  

We offer a number of services that do not require you to register for an account or provide any personal information to us, such as 'Money Center' and 'The Daily Compass'. In order to provide our full range of services, we may collect the following types of information:

• Information you provide - When you sign up for Email Blog Delivery, Email Newsletter Delivery, or other Lightship Mutual service or promotion that requires registration, we ask you for personal information (such as your name and email address). We may combine the information you submit under your account with information from other Lightship Mutual services in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
  
  
• User communications - When you send email or other communication to Lightship Mutual, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
  
  
• Links - Lightship Mutual may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our search technology and customized content.
  
  
• Other sites - This Privacy Policy applies to web sites and services that are owned and operated by Lightship Mutual. We do not exercise control over the sites displayed as search results or links from within our various services. Moreover, we do not exercie control over the various blogs, external sites, and websites referenced within our corporate blog (The Daily Compass). These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We encourage you to review the privacy policy of all third party websites.

Lightship Mutual only processes personal information for the purposes described in the applicable Privacy Policy. In addition to the above, such purposes include:

• Auditing, research and analysis in order to maintain, protect and improve our services;
• Ensuring the technical functioning of our network; and
• Developing new services.

Lightship Mutual processes personal information on web servers hosted by various third parties such as Forefield, Incorporated, RedTail Technologies, and Yahoo Business Hosting.

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When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.

You can decline to submit personal information to any of our services, in which case Lightship Mutual may not be able to provide those services to you.

Lightship Mutual only shares personal information with other companies or individuals outside of Lightship Mutual in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Lightship Mutual, its users or the public as required or permitted by law.

If Lightship Mutual becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who searched for a particular term, for example, or how many users clicked on a particular weblog article. Such information does not identify you individually.

Please contact us at the address below for any additional questions about the management or use of personal data.

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We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where our company website and business data are stored.

We restrict access to personal information to Lightship Mutual employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

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Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes). Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any additional questions or concerns about this Policy, please feel free to contact us any time through this web site or at Privacy Matters, c/o Lightship Mutual, 3525 Piedmont Road, 7 Piedmont Center, Suite 300, Atlanta, GA 30305 USA.

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Lightship Mutual is a Georgia Registered Investment Advisor. LM and its representatives are in compliance with the current registration requirements imposed upon registered investment advisers by those states in which LM maintains clients. LM may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements.

Lightship Mutual's web site is limited to the dissemination of general information pertaining to its investment advisory services. Accordingly, the publication of LM's web site on the Internet should not be construed by any consumer and/or prospective client as LM's solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Furthermore, the information resulting from the use of tools or information on this Internet site should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from LM.

Any subsequent, direct communication by LM with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.

For information pertaining to the registration status of LM, please contact the state securities law administrators for those states in which LM is registered. A copy of LM's current written disclosure statement discussing LM's business operations, services, and fees is available from LM upon written request.

Opinions expressed herein are solely those of LM. LM does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to/from LM's web site or incorporated herein, and takes no responsibility therefore. All such information is provided for convenience purposes only and all users thereof should be guided accordingly.

This web site is believed to provide accurate and authoritative information in regards to the subject matter covered. The accuracy of the information is not guaranteed and is provided with the understanding that we are not rendering legal, accounting, tax, or other professional services. If legal advice or other expert assistance is required, the services of a competent professional should be sought.

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All rights reserved. All material contained herein is copyright protected and may not be reproduced in any manner without the express written permission of the copyright owner. Text, photos, articles and logos: Copyright © 2004-2008 Lightship Mutual, LLC., Damon P. Williams and Justin S. Parr, Principals. "The Financial Guiding Light"™ and "Keys to SHINE"™ and "Engage. Educate. Empower."™ and "Degree Rich, Money Poor"™ and "SHINE On"™ rights owned by Lightship Mutual, LLC. All Rights Reserved. "Fee-Only Financial Planning and Advice for Everyday Life"™ "Hourly, As-Needed Financial Planning and Advice"™ "Building Brighter Financial Futures"™ and "The New Choice for Smart Consumers"™ rights owned by The Garrett Planning Network, Inc., Sheryl Garrett, Principal. CFP®, CERTIFIED FINANCIAL PLANNER™ and CFP (with flame logo) are certification marks owned by Certified Financial Planner Board of Standards Inc.  These marks are awarded to individuals who successfully complete CFP Board's initial and ongoing certification requirements.

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CFP^®, CERTIFIED FINANCIAL PLANNER™ and CFP (with flame logo) are certification marks owned by Certified Financial Planner Board of Standards Inc.  These marks are awarded to individuals who successfully complete CFP Board's initial and ongoing certification requirements.

Member, The Garrett Planning Network, Inc., an International Affliliation of Fee-Only Advisors. As-Needed Financial Planning and Advice...The New Choice for Smart Consumers™.