Spinnaker Trust is committed to protecting your privacy. This policy statement outlines what information we collect, how we use the information and steps we take to protect the information that you give us. We maintain strict confidentiality about you and your accounts except as provided by law, regulation, or at your request.

Information we obtain and where we obtain it

We may collect "non-public information" about you. "Non-public personal information" is information about you, which is not available from public sources, obtained in connection with providing you with a financial service or product. For example, we collect information about you from the following sources:

• Information we receive from you in the course of establishing and managing your account(s) including your name, address, and telephone number, your social security number, and assets to be managed, and
• Information about your transactions with us including receipts, disbursements, and other transactions in your account

How we use the information

We do not disclose any non-public information about you except as required or permitted by law. We disclose non-public personal information about you to third parties to assist us in servicing your account. Our service providers include proxy voting services, custodial banks and tax professionals. In addition we may provide non-public personal information about you to government entities as required by law, or to anyone in response to a subpoena or court order.

We will adhere to this policy for both current and former clients.

Security of Personal Financial Information

We restrict access to your personal and account information to those employees who need to know that information as part of their jobs, to service your account or to provide services to you. All employees are trained and required to safeguard such information.

Companies we hire to provide support services are not allowed to use your personal information, and are obligated to maintain strict confidentiality.

We maintain physical, electronic, and procedural safeguards designed to protect your non-public personal information.

Security Reminder

We will never request personal confidential information from you by e-mail. Please report any such requests to us. Additionally, we advise our clients not to include confidential information such as social security or account numbers in e-mails. We discourage the transmission of private information over unsecure communication channels, and we do not send confidential information to our clients by e-mail.

Questions

We are strongly committed to our relationship with you, and we want to be certain that you understand the steps that we have taken to protect your privacy. If you have any questions or concerns, please call Anne Wood at (207) 553-7160.

Revised 10/14/03