At Private Equity Securities, Inc. (“PES”), we understand our obligation to keep information about you secure and confidential. We will inform you of our policies for collecting, using, securing, and sharing personally identifiable and/or nonpublic personal information (“Customer Information”) the first time we do business and every year that you remain a customer with us. Therefore, we maintain the following principles with respect to protecting your privacy:

•  We are committed to protecting your privacy at all times;
•  We do not sell or disclose any nonpublic personal information about you to anyone except as permitted by law;
•  We do not provide customer information to persons or organizations outside the affiliated companies who are doing business on our behalf, for their own marketing purposes;
•  We contractually require any person and/or organization providing products or services to customers on our behalf to protect the confidentiality of PES customer information;
•  We afford prospective and former customers of PES the same protections as existing customers with respect to the use of personal information;

Information We Collect

We collect and use various types of information we believe is necessary to administer our business, and to offer you the best possible customer service. Customer information we collect is categorized into the following types:

• Information we receive from you on applications, or on other forms, through telephone or in-person interviews, such as your name, address, phone number, social security number, your assets, income and other household information;
• Information about your transactions and account experience with us or others, such as your account balance, transaction history;
• Information from consumer reporting agencies, such as information regarding your creditworthiness or credit history;
• Information from visitors to our web site provided through online forms, site visitor data and online information collecting devices such as “cookies.”
• Other general information we obtain about you that is not assembled for the purpose of opening an account or offering certain products or services that you may request, such as demographic information.

Information We Share

The information we share helps us bring you greater convenience and more choices as a customer. We limit who receives Customer Information and what type of information is shared. Unless you tell us not to, we may share all five types of Customer Information among ourselves and with other third-party financial services companies affiliated with us as part of the ordinary course of providing financial products and services to you, for the purposes of offering you new products and services to address your financial needs, for product development purposes, and as otherwise required or permitted by law.

Such “affiliated” companies may include other financial service providers such as brokerage firms, investment adviser firms, insurance companies and payment processing companies; and may also include non-financial companies such as check printing and data processing companies. These companies might assist us, for example, in fulfilling your service request, processing your transaction, or mailing account statements. For a list of companies affiliated with PES please see “PES Affiliated Companies” below.

In addition, we may share any of the five types of Customer Information with companies that work for us to provide marketing and other services or other financial institutions with which we have joint marketing agreements. All of these companies that are acting on our behalf, are contractually obligated to keep the information that we provide to them confidential, and use the information only to provide the services we've asked them to perform.

Limitations to Sharing Customer Information

You can limit information shared about you. If you do not want us to share information from your applications, consumer reports or from other outside sources, please tell us of this request by notifying us through one of the following methods:

•  Writing to:

Private Equity Securities, Inc.
19100 Von Karman Ave., Suite 255
Irvine, CA 92612

•  Calling us at:

(949) 752-5020

•  Sending us an e-mail through the web site at:

  www.privateequitysecurities.com

Please note that this request will apply to customer application information, consumer reporting agencies and/or other outside sources only and may take up to 30 days to be fully effective. Through the normal course of doing business, including servicing your accounts and better serving your financial needs, we will continue to share transaction and account experience information, as well as other general information among our affiliated companies.

Disclosing information in other situations

Under certain circumstances, we may be required by law to disclose your personal information. PES may also disclose personal information to protect its legal rights or to enforce our Customer Agreement. We may disclose certain Customer Information to credit bureaus and similar organizations, and otherwise when permitted by law. For example, this may include:

•  A disclosure in connection with a subpoena or similar legal process;
•  A fraud investigation;
•  Recording of deeds of trust and mortgages in public records;
•  An audit or examination;
•  The sale of your account to another financial institution.

Keeping up-to-date with our Privacy Policy

PES will provide notice of our privacy policy annually, as long as you maintain an ongoing relationship with us. If, at any time in the future, it is necessary to disclose any of your nonpublic personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you may have the opportunity to opt out of such disclosure. Additionally, since this policy may change from time to time, you can always review our current
policy by contacting us for a copy at: (949) 752-5020 or visiting our web site at www.privateequitysecurities.com.

PES Affiliated Companies

Affiliates to whom we may disclose personal information about you may be categorized in several different businesses, including securities and insurance. The following is a list, as of September 1, 2007, of all companies affiliated with PES to which this policy applies:

Brokerage and Investment Firms

• Legent Clearing LLC.

"Opt Out" Notification Form

As described in this brochure, we are committed to protecting your privacy. If you prefer that we not share certain information about you with outside companies; you may choose to opt out. This means that you may direct us at any time not to disclose this information to these outside companies for marketing purposes. Therefore, if you wish to notify us to limit such disclosures of your personal information, please indicate your choice(s) by marking the appropriate box or boxes below.

Please include your name, address, and social security number and/or tax identification number. Then detach and send this form to the address listed below so we may honor your request. If you have previously communicated an opt out choice to us, you do not have to provide it again.

Name: _________________________________________________
Address: _______________________________________________
City: _______________________ State: ___________ Zip Code: __ _____
Social Security Number/Tax ID Number: ________________________

1. ___ Please limit the personal information about me that you disclose to nonaffiliated third parties as described in this brochure.

If you check #1, we will not make these disclosures except as permitted by law, including disclosures necessary to process you account transactions.

2. ___ Please limit the personal information about me that you share with PES
affiliates as described in this brochure.

The law allows us to share with our affiliates any information about our transactions or experiences with you. However, if you check #2, we will not share with our affiliates other information that you provide to us or that we obtain from third parties, unless otherwise permitted by law.

If you have checked any of the boxes above, please mail this form in a stamped envelope to:

Private Equity Securities, Inc.
19100 Von Karman Ave., Ste. 255
Irvine, CA 92612

Information Security

We are committed to preventing others from authorizing access to your customer information, and we maintain procedures and technology designed for this purpose. We take several steps to
protect the customer information we have about you, including the following:

•  We maintain physical, electronic and procedural safeguards to protect your information;

•  We restrict access to information about you to those employees who need to know that information to provide you with the best possible products and services;

•  We require outside companies and independent contractors to whom we provide customer information for marketing, servicing or processing purposes to enter into a confidentiality agreement that restricts the use of such information to be used for specific purposes as intended, and prohibits the independent use of such information;

•  We update and test our technology on a regular basis in order to improve the protection of customer information;

•  We have internal procedures that limit access to customer information to only those members who are considered “authorized” personnel.

If you have any questions about your personal or account information or about PES’s privacy policies and practices, please feel free to contact us at (949) 752-5020.

Order Routing and Payment for Order Flow Information

Pursuant to SEC rules and regulations, PES is required to disclose to its customers is policies for routing its orders for execution and a statistical analysis of the quality of transaction executions. For an analysis of PES’s order routing statistical information, please access the following web link info link . Also note that a copy of order routing reporting will be furnished upon request.

Additionally, pursuant to SEC Rule 11Ac1-3, PES is required to disclosure its payment for order flow practices to its customers at the time that an account is opened and annually thereafter. PES does receive payment for order flow for routing orders to specific execution venues.

FINRA Public Disclosure Information

NASD Conduct Rule 2280 requires the following information be provided to you: (1) FINRA Public Disclosure Program hotline number is 1-800-289-9999; (2) FINRA’s Web site address is, www.finra.org, and (3) FINRA has a brochure available describing the public disclosure program.

Important Information about Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

Use of "Cookies"

Cookies are used on our Web site to help us monitor traffic patterns and see how the user navigates through our site. Private Equity Securities, Inc. cookies are used for internal purposes and are not used to collect disseminate personal information to any third party. Cookies you may establish with companies whose sites are linked to Private Equity Securities, Inc. are not the responsibility of PES Financial, Inc. and you should review their policy on cookies.

Private Equity Securities, Inc. will provide notice of our privacy policy annually, as long as you maintain an account with us. 

Private Equity Securities, Inc. reserves the right to make changes on this policy.