At Winebrenner Capital Partners, LLC. (WCP) we value our relationship with you and understand the importance of protecting your privacy. This privacy notice applies to personal information gathered in connection with the products and services provided to you by WCP and our affiliated divisions. Please read this notice carefully, as it explains why we collect non-public, personal information (NPI), what we do with NPI, and how we protect your privacy.


We collect NPI about our customers to provide them with investments, insurance, and other products we offer. The type of data we collect depends on the type of product or service you request. This includes, but is not necessarily limited to: telephone number, address, date of birth, social security or tax identification number, occupation, income, and health history. We obtain NPI from your applications and other account opening documents, as well as information received from third parties, such as consumer reporting agencies. We collect personal information needed only to service and administer your business with us.


We share your NPI primarily with people and companies that perform administrative and professional services for us, including, but not limited to, insurance companies, mutual funds, outside money managers, and our clearing firm, Sterne, Agee & Leach, Inc. We may also share information about you with non-affiliated third parties that assist us in transacting business for your account, and to legal or governmental entities in response to subpoenas and other written requests, when required by law. Considering the sensitive nature of medical record information, we will not disclose such information for any purpose unless it is authorized by you, required by law, or necessary to fulfill a request you have made. We may, however, disclose other non-medical information to affiliate and non-affiliated companies, including service providers, in order to carry out our normal business activities. We do not disclose any other information about you to any nonaffiliated third parties, except as permitted by law.


We have policies to maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of your NPI. NPI is only available to those employees that we have determined require access, in order to perform their duties. Employees that violate our privacy policy and procedures are subject to disciplinary action.


It is not necessary for you to take any action. This is because we do not share your information except to service the business you have requested from us. If you have questions or would like to learn more about how we use your personal information, please visit our office, contact your financial adviser or visit our web site at www.winebrennerpartners.com.

10602 Timberwood Circle, Suite 13
Louisville, KY 40223
Member NASD, SIPC, MSRB
502-671-0015



SIA is committed to clarity through full and unambiguous disclosure, as well as enhanced understanding of the securities markets.

We believe that the needs of the investor should always come first. As an investor, you have important rights, including the right to high quality products and services from the securities firm you choose.

At the same time, investors need to shoulder certain responsibilities themselves — for example, to plan carefully to meet their investment goals and to stay informed about the risks and rewards of their investments.


As an investor, you have the right:

• To be treated in a fair, ethical, and respectful manner in all interactions with a securities firm and its employees and affiliates;
  
  
• To receive competent and courteous service and advice (if provided by your firm) at a fair price;
  
  
• To select your own representative or request a different one if you are not satisfied;
  
  
• To move your account to another representative or a new investment firm whenever you wish in a simple, efficient manner;
  
  

• To clear, accurate, easy-to-understand descriptions of all your transactions, statements, and other communications from your investment firm;
  
  
• To be informed clearly about all the costs associated with your account and the costs related to individual transactions, including commissions, sales charges (or loads), and other fees;
  
  
• To accurate and timely regular statements of your account, including detailed transactional information;
  
  
• To be provided with clear descriptions of your firm's policies and practices for protecting the privacy of non-public, personal information;
  
  

• To be provided with responsible investment recommendations based on your personal objectives, time horizon, risk tolerance, and other factors, as disclosed by you;
  
  
• To be apprised of significant conflicts of interest identified in a financial relationship between an investor and his or her broker-dealer or account representative;
  
  
• To expect that your investment firm will provide professional assistance to help you clarify your investment goals and risk tolerance;
  
  
• To be able to rely on your firm's assistance also in setting realistic expectations about the long-term performance and associated risks of various securities. The firm will present you with reasonable investment alternatives designed to meet those expectations, and disclose the comparative risks, benefits, and costs;
  
  

1. To fair consideration and a prompt response from your investment firm, if any problem with your account ever arises;
   
   
2. To a clearly defined process for raising and resolving a complaint. Your firm will provide you with full information about this process, particularly about how you can elevate an issue to the appropriate level of the firm's management to gain satisfaction;
   
   
3. To be apprised of alternatives if your investment firm is unable to resolve a dispute to your satisfaction;
   
   

Currently you maintain an account at our firm, Winebrenner Capital Partners, LLC. (WCP) Through your financial advisor, our firm provides technology, product, and support services for the account you maintain with us. Your assets are held at our clearing firm, Sterne, Agee & Leach, Inc. or directly by the mutual fund or annuity company.

Securities Industry regulations require that each member firm create and maintain a "Business Continuity Plan" (BCP), which is reasonably designed to meet our obligations to our clients in the event of a disruption to our business. Accordingly, WCP has designed a BCP to address a variety of possible scenarios in an effort to minimize any service impact to our clients.

Some of the key areas that are addressed in our BCP include, but are not limited to the following:

• Data back-up and recovery
  
  
• Operation of mission critical systems
  
  
• Financial and operational assessments
  
  
• Alternate means of communication between our financial advisors and our clients
  
  
• Alternate physical locations
  
  
• Regulatory reporting
  
  
• Communication with regulators
  
  
• How WCP will ensure customers will have access to their account information and/or funds or securities in the event that WCP determines it is unable to continue its business.
  
  

There are a significant variety of events that may cause business disruptions. These events may vary in nature and scope. WCP has anticipated the following scenarios:

• A temporary disruption at its main offices in Louisville, KY (less than 24 hours)
  
  
• A more lengthy disruption at its main offices in Louisville, KY
  
  
• A city wide catastrophe
  
  
• A regional catastrophe
  
  

In the event of a temporary or lengthy building disruption at the main office of WCP, all phones will be forwarded to our Clearing Firm utilizing an 800# number or routed to an alternate location, with a local number. Once the disruption is over, all office phones will be switched back to our normal main line phone number. Additionally, our web site will be updated to include emergency contact information for at least two of the principals of WCP, indicating both their home and cell phone numbers. In the unlikely event of a city wide or regional disruption, WCP has established a relationship with another Broker Dealer, approximately 60 miles from our location, where key employees may be relocated until the disruption has ended. However, if the geographic incident should encompass our alternate locations, than all contact will be directed to our Clearing Firm, whose main office is located in Birmingham, AL. Sterne, Agee & Leach, Inc. also has branch offices in several states, offering additional contact facilities in the event of a disaster.

At a minimum the WCP BCP is reviewed, updated, and tested on an annual basis. Additionally, our primary mission critical systems and applications are tested periodically each year to verify that all are in working order. Our BCP is available on our website at www.winebrennerpartners.com and may be modified in the future. If changes are made, the updated plan will be posted to the website promptly.

Our financial advisors and our clients are extremely important to us, and we believe that our BCP is designed in such a way that it will allow us to continue to provide the quality of services you have come to expect in the event of any type of disruption or emergency. Feel free to call 502-671-0015 if you would like us to mail you a written copy of the WCP BCP plan.