MCCULLEY FINANCIAL GROUP, LLC is committed to adhering to the requirements and
expectations regarding the privacy of personal information. Privacy regulations are founded
upon three definitions:

1. Consumer – a person who has not entered into an investment advisory relationship but
   has disclosed non-public personal information to our firm.
2. Client – a person who has entered into an investment advisory relationship with the firm
   or that individual’s designated representative.
3. Confidential Information – personally identifiable private information, not available
   from public sources, about a client or consumer. In general it includes name, address,
   age, social security number, assets, income, net-worth, account balances, account
   numbers, beneficiary information, or investment history.

Our firm collects non-public information about client and consumers. We will not share nonpublic
information about clients or consumers with third parties not affiliated with our firm, except
as noted below:

• To complete transactions or account changes, as directed by the client.
• To maintain or service a client’s account.
• If requested by the client.
• With entities under common ownership and control of our firm.
• With contracted third-parties who require the information to develop, support and deliver services.
• If our firm is required or permitted by law or regulatory authorities with jurisdiction over the firm.
• With one or more of our affiliated entities, at our sole discretion and for purposes either related or
  unrelated to services we provide you, and to nonaffiliated entities that either perform services for
  us or function on our behalf (such as check printing services, account aggregation providers,
  investment companies, and insurance companies). Definitions: Nonaffiliates – Companies not
  related by common ownership or control. They can be financial and nonfinancial companies.

As a client of our firm, your privacy is important to us. We are dedicated to safeguarding your
personal and financial information. We restrict access to confidential 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 to comply with federal
standards to guard your confidential personal information.

We will notify you in advance if our privacy policy is expected to change. We are required by
law to deliver this Privacy Notice to you annually, in writing. Please contact us with any questions
about this policy.