PRIVACY POLICY

Keene Advisors, Inc. considers the protection of your information to be a most important priority. Our privacy policy and practices are designed to support this objective. We want you to understand what information we collect and how we use it.

We may collect non-public, sometimes personal, information about our clients and parties who engage our firm to participate in certain securities transactions from the following sources:

• Information we receive from you on applications and other forms;

• Information we receive from you in order to provide certain investment banking advisory or consulting services;

• Information concerning your engagements with us, our affiliated persons, or others; and

• Information from a consumer-reporting agency or vendor providing anti-money laundering or Know Your Customer compliance services.

 We do not disclose any non-public information about you to anyone, except as permitted or required by law.

 We restrict access to non-public personal information about you to those employees, and affiliated persons who need to have access to such information in order to provide advisory services to you. We maintain physical, electronic, and procedural safeguards to guard your non-public personal information.

 If you have any questions regarding this policy, please contact us via phone at 617-765-2055 or via email at info@keeneadvisors.com.