Revised as of August 2002

This Policy is issued on behalf of Summit Advisors, Inc. and Jack Pratt. For more information on us, please see our Corporate Overview.

We are always aware that when you are a client, you entrust us with more than your information. You also share personal and financial information. We take very seriously the obligation to keep that information confidential and private. SAI is committed to maintaining the privacy of the information you share with us. We want to assure you that information about shared with us is not sold to any third party. In the following statement, we describe what information is gathered from www.jack-pratt.com and from certain other sources and how we use it. If you have any questions, please call 281-980-1900 and we will be happy to assist you.

Information we gather from our customers.
SAI collects nonpublic personal information about you from applications or other forms you complete and from your transactions with us or our affiliates. The term "personal information" includes information such as your name, address, telephone number, email address, Social Security number or other national identification number, account number, income, assets information, account balance, trade secrets, strategic plans, and investment history.

Information we gather on this web site.
We gather two types of information on this site: personal information about you and general information about how the site is being used.

We gather personal information in phone calls, in person and when you fill out a questionnaire forms. We also collect general web site tracking information, such as which pages are viewed at which times, automatically through our web server software.

What we do with the information we gather.
We do not disclose information about you, or our former customers, to our affiliates or to service providers or other third parties except on the limited basis permitted by law. For example, we use this information to administer your accounts with us through such activities as sending you confirmations, annual reports, feedback forms and assessments. Your personal information also lets us know how to contact you so that we may answer your question or respond to your request. Your Social Security number and account number help us protect your privacy; they help us verify that you are authorized to access the account you are requesting to view. To serve you better, we may combine information you give us through this web site or through other communication channels.

The general web site tracking information is used to give us a summary view of how our web site is used. Currently we do not track individual users; but we may implement the capacity to do so in the future. In any case, we currently analyze the data, and will analyze the data in the future, only to determine how to make the web site better and more useful. This information is and will be strictly for our internal use.

We may conduct surveys regarding our services, including the operation of our web site. The information you provide is used only on an aggregated basis and is analyzed only to improve our services and for company management and planning purposes. You will not receive communications as a result of your participation in one of our surveys if you notify us not to contact you

Our policy on sharing site information with third parties.
Your privacy is one of our biggest priorities. Information about you and any users of www.jack-pratt.com is not sold or rented to any third party. We do not trade such information with any third party. Even within, only people involved with servicing your accounts have access to your personal information.

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, and to protect our rights or property. We reserve the right to use your email or other address to send you important information relating to your account, including regulatory communications.

How we protect your information.
To ensure a high level of confidentiality and security, SAI maintains physical, electronic and procedural safeguards that meet or exceed federal standards.

When we share personal information with our service providers, we expect them to treat that information with strict confidentiality and to retain your personal information no longer than is necessary to provide the  service or information.

We expect our employees with access to confidential customer information not to use or disclose the information except for business purposes. Personal information about you is normally used only by those employees who need to know that information to provide our products or services to you. All employees are expected to safeguard such information and employees who violate these obligations will be subject to our normal disciplinary process.

Special security measures apply to your communications with us on this web site. Detailed information is available at our Web Security & Privacy FAQs. Internally, we employ encryption technologies, user authentication systems (e.g., passwords and personal identification numbers) and access control mechanisms to secure access to our computer systems and files. We employ firewalls for our Internet-based systems.

How you can correct and update personal information.
If you need to update or correct any personal information, you may contact us at 281.980.1900.

How you can block access to your account information from our web site.
We hope that you'll benefit from having 24-hour Internet access to your SAI account. However, we understand that you may prefer not to participate in this service. If for any reason you wish to block access to your account information from this web site, simply call 281-980-1900 and ask that your account be blocked from the web site.

Communications with us.
Jack Pratt welcomes your email correspondence. Our associates are available during normal business hours to address your general investment questions as well as respond to your suggestions for improvement. At this time, however, in order to ensure your protection and client confidentiality, our email responses will not include any personal account information such as Social Security numbers, account numbers, etc.

Changes to this Statement
We reserve the right to change or remove this Policy at our discretion. If we decide to change it, we will post those changes here. We encourage you to visit this area frequently to stay informed. If you access our web site after we have posted changes to this Statement, you are agreeing to accept the changes.