Privacy Notice

Facts

WHAT DOES KEMPNER CAPITAL MANAGEMENT, INC. DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security Number and driver’s license number
• Account balances and income
• Addresses and contact information

When you are no longer our client, we continue to share your information as described in this notice.

How?

All financial companies need to share client’s personal information to run their everyday business. In the section below, we list the reasons financial companies can share their client’s personal information; the reasons Kempner Capital Management, Inc. chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Kempner Capital Management, Inc. share?

Can you limit this sharing?

For our everyday business purposes – such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations.

Yes

No

For our marketing purposes – to offer our products and services to you.

No

N/A

For joint marketing with other financial companies

No

N/A

For our affiliates’ everyday business purposes –Information about your transactions and experiences

Yes

N/A

For our affiliates to market to you

No

N/A

For our non-affiliates to market to you

No

N/A

Who is providing this notice?

Kempner Capital Management, Inc.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We collect your personal information, for example, when you

• Open or close an account
• Authorize a trade or authorize a direct fee-deduction
• Authorize to raise cash

We may also collect your personal information from other companies.

Federal law gives you the right to limit only

• Sharing for affiliates’ everyday business purposes – information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Harris L. Kempner, Jr. is a limited partner/unit holder of Kempner Securities, LP (“KSLP”) and Galveston Finale LP (“GFLP”). Mr. Kempner is one of three members of Kempner Securities GP LLC, the General Partner of KSLP. Mr. Kempner is also one of three members of Galveston Finale GP LLC, the General Partner of GFLP.

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

These include broker/dealers, mutual fund companies, insurance companies and other financial institutions.

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Kempner Capital Management, Inc. does not do joint marketing