Green Drake Capital Corp. Privacy Policy
(in accordance with Regulation S-P requirements)

Overview

This Privacy Policy explains how Green Drake Capital Corp., which includes its two divisions – Aspenwood Capital and Restricted Stock Partners – and its subsidiaries and affiliates (collectively, "GDCC", "We", "Our", "Us") collects and protects your personal information.  If you have any questions that this policy does not address, please contact us at (212) 668-5920.  By opening an account with GDCC, you give your consent to the collection and use of personal information by GDCC as explained in this policy.

GDCC's Privacy Policy applies to current and former GDCC clients.  The term "personal information" as used herein refers to non-public information that personally relates to or identifies you as an individual, entity or your GDCC client name.

You can count on us to protect the privacy of the information you have entrusted to us and to provide you with the responsive, professional service you deserve.

Our Pledge to You

We recognize that the trust of our clients is our most precious asset.  GDCC is committed to maintaining the confidentiality, integrity and security of personal information regarding our clients. Keeping client information secure, and using it only as our clients would want us to, are matters of principle for all of us at GDCC. With this in mind, here is our pledge to each and every GDCC client:

We will:

• Respect the trust you place in us and the confidential nature of the information you provide through your financial relationship with us;
• Limit the collection and use of client information to what we believe would be useful to service your accounts, administer our business, or tell you about our services;
• Restrict employee access to client information to those who need to know in order to provide services to you;
• Educate our employees to reinforce the importance of confidentiality and client privacy;
• Maintain appropriate security standards and procedures to protect information about you; and
• Respond quickly to your request to correct inaccurate information.

Updates and Changes to GDCC Privacy Policy

Please note that, in the event of a change in policy, a revised Privacy Policy will promptly be posted to our Web site.  You agree to accept posting of a revised Privacy Policy electronically on the Web site as actual notice to you.  Any dispute over our Privacy Policy is subject to this notice.

How and Why We Gather Information

GDCC does not sell personal information about its clients to anyone.

We collect information from you that is required to open an account, to transact business, to communicate with you, verify your identity and fulfill legal and regulatory requirements.  From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences.

Types of Information We Collect

The information we collect and maintain about you comes primarily from you during the course of your doing business with GDCC. This personal information, not available publicly, comes from the following sources:

• Information you provide to us when you fill out account opening documents, complete a form or make a request for services, including your name, address, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, telephone number, e-mail address and similar information;
• Information from your transactions with us, such as your account balance and account usage; and
• Information obtained from others, such as credit reporting agencies.

How We Protect Your Information

GDCC considers the protection of sensitive information to be a foundation of client trust.

Keeping Information Safe

We limit access to the information we have about you to those employees who need to know to provide you with services to help you meet your financial needs. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information.

We have invested in software, systems and procedures to offer you a safe and secure trading environment and protect your personal, financial and trading information.  While no security system is absolutely impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.

The Importance of Being Accurate

We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, we urge you to notify us immediately.

We only use your information as appropriate to provide you with quality services and to ensure security.  For example, we may use the information collected from you to verify your identity and contact information.  We may also use this information to establish and set up your trading account, issue an account number, and maintain your trading information.  This information helps us improve our services to you.

An Ongoing Commitment to Your Privacy

We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, you will continue to be protected by the privacy policies and principles described in this policy.  Should you close your account with us, GDCC will retain your information, but only use it to comply with regulatory requirements.

How Information Helps Both You and Us

Our mission is clear: to help you reach your financial goals.  Information about you and your accounts plays a key role in our ability to succeed in this mission. It also helps us service your accounts and administer our business.  For example, we use information about you to:

• Respond more accurately and efficiently to your requests;
• Identify opportunities to give you more convenience and control by developing new services that may benefit you; and
• Secure your accounts and help protect you and GDCC from fraud.

Sharing Your Information with Unaffiliated Third Parties

We Limit the Sharing Of Information

To protect your privacy, we limit the sharing of information outside GDCC. We conduct our business with great respect for the confidential nature of the information being provided. We will not share information about you except as outlined below.

The cornerstone of our Privacy Policy is the commitment to keep our clients' personal information confidential.  We do not sell, license, lease or otherwise disclose your personal information to any unaffiliated third party for any reason, except as noted below:

• Where such disclosure is required or appropriate pursuant to laws or securities regulations, including cooperating with government agencies, other regulatory bodies and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.

• To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account processing, client services or other data collection relevant to our business.  We may also provide a party with client information from our databases to help us analyze and identify client needs or to notify clients of particular services offerings.  Use of the information shared is strictly limited to the performance of the task we request and used for no other purpose.

Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us, such as data processing and companies that perform securities execution and clearing services on our behalf.  GDCC has entered into a contractual arrangement with Terra Nova Trading LLC ("Terra Nova") to provide clearing and settlement services to GDCC and its clients. GDCC provides all client information to Terra Nova that is necessary to service and settle trades properly on a timely basis.

GDCC may share information with affiliates if the information is required to provide the services you requested.  An affiliate is a company that we own or control, or with which there is common ownership with us.

Protecting Shared Information

All third parties with which we share personal information are required to protect it in a manner similar to the way we protect information.  If at any time you choose to purchase a product or service offered by another company, any personal information you share with that company will no longer be controlled under our Privacy Policy.

As noted above, GDCC also reserves the right to disclose your personal information where required by law to regulatory, law enforcement or other government authorities.  We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

Reviewing, Changing or Correcting Information

You are responsible for helping us to maintain the accuracy and completeness of your personal and other information.  We urge you to review your information regularly to ensure that it is correct and complete.  If you would like to review your personal information or if you believe that any of your information is incorrect, or if you have any questions regarding your personal information, or if you have any other questions or concerns regarding this Privacy Policy, please contact us at (212) 668-5920.

Our Privacy Policy Statement Does Not Apply to the Sites, if any, to Which We Link

We are not responsible for the privacy policies or the content of sites we link to, and have no control of the use or protection of information provided by you or collected by those sites.  Whenever you elect to hyperlink to a linked Web site, you may be asked to provide registration or other information.  Please note that the information you are providing is going to a third-party, and you should familiarize yourself with the privacy policy provided by that party.