At Middleton & Company, Inc., protecting the privacy and confidentiality of your personal information is important to us. We value your business and the trust you place in Middleton and guarding your privacy is a responsibility we take seriously. As an investment adviser, we collect, maintain, and use information about you on a routine basis. In order to help you better understand how we protect your personal information, we are providing this summary of our practices and policies with respect to the privacy of client information. In the event you terminate your relationship with us, we will continue to adhere to the policies and practices described in this notice.

Information We Collect

When you establish an investment management account with Middleton, we collect and retain nonpublic personal information about you that may include your name, address, phone number(s), and social security number. We also collect information about your transactions with us and about transactions by and for your account. This information may include your account numbers, securities, transactions, cost basis information, and other financial information.

Information Security

All information collected by Middleton is used for the purpose of delivering the advisory services you have requested. Middleton does not sell, exchange or share client information with outside organizations unless the third party is essential for providing advisory services to you or for complying with regulatory requirements. Middleton shares personal information with certain third parties under contract with us, including but not limited to custodians, broker-dealers, administrators, accountants, and auditors, solely in connection with the provision of advisory services. These third parties must agree to respect the privacy of any client information and not to disclose that information to other entities, except as required or permitted by law.

We understand that the protection of your nonpublic personal information is of the utmost importance. Middleton maintains strict procedures and policies to safeguard your privacy. We restrict employee access to nonpublic personal information to authorized employees who are trained to protect the confidentiality of all client information. We create and maintain physical, electronic, and procedural safeguards to protect all client information.

Changes to Our Privacy Policy

In the event there were to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt-out of such disclosure arrangements.

Additional Information

If you have any questions or suggestions about this notice or our privacy program, please contact us at 1-800-357-5101.