PRIVACY POLICY

The creation of this Statement and its periodic dissemination to our clients is required by the Securities & Exchange Commission Regulation S-P. Please note this Statement and the policies described do not represent a change from our prior practices and policies.

Guiding Principals
In order to safeguard our clients’ privacy, Howard Capital Management limits the collection of personal information to what is necessary in delivering our services to our clients. We do reserve the right to disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, or is necessary in providing you with our services.

We use this information to conduct business with you. At no time do we sell your information or share it unless necessary to conduct business with you.

Protection of Client Information
Our firm’s policy requires that employees with access to confidential client information may not use or disclose the information except for business purposes. Access to client information is restricted to our employees, representatives and agents with a business reason for access to such information. We safeguard information according to established security standards and procedures and require our employees and representatives to comply with these protections.

Changes to Firm Privacy Policies
From time to time the firm may update and improve its privacy policies. All new clients will receive the firm’s most current privacy policy upon entering into an agreement or opening an account with Howard Capital Management. All clients will be provided with the firm’s most current privacy policies at least annually.