PRIVACY POLICY ADVISE


PRIVACY POLICY ADVISE
O´ROURKE & ASOCIADOS, S.A. DE C.V.
INVESTMENT FUNDS BROKER
(O'ROURKE INVESTMENT FUNDS)

In accordance with the Federal Law for the Protection of Personal Information in Possession of Private Individuals and its Regulations (herein “Law”), O'ROURKE INVESTMENT FUNDS issued this Privacy Policy Advise under the following terms:

• PARTY RESPONSIBLE FOR THE PERSONAL INFORMATION

For purposes of this Privacy Policy Advise, the General Management of O'ROURKE INVESTMENT FUNDS shall be responsible for obtaining, disclosing, storing, using, incorporating access to, managing, exploiting, transferring, or the arrangement of personal information (herein “Handling”), and it is located at Avenida Mariano Otero 1917, Local 3, Zona C, Plaza Turquesa, Colonia Residencial Victoria, 45089 Zapopan, Jalisco (Main Office)

• INFORMATION TO BE OBTAINED

O'ROURKE INVESTMENT FUNDS will obtain your information from different sources, which include:

1. In Person: When you solicit or contract the financial services offered by O'ROURKE INVESTMENT FUNDS.

In continuation, the personal information that can be requested is described without limitation: name, address, telephone numbers (house, office, cell phone), e-mail address, age, date of birth, occupation, nationality, marital status, CURP (personal ID number), RFC (tax ID number), name of the company where you have worked, education, economic dependents, income sources, spouse’s information, contract type, activity/type of business, post/occupation, work address in Mexico, bank account information, etc.

2. Indirectly: From any information sources commercially available or which are permitted by law.

The information that we obtain from you can be combined to help us offer, benefit and/or improve our financial services.

• OBJECTIVES THAT ARE SUBJECT TO THE HANDLING OF PERSONAL INFORMATION

The objective in handling the personal information which we may obtain, unless otherwise stipulated by the titleholder in the manner described in this Privacy Policy Advise, is to develop new financial products and services, to provide advisory services, to promote new financial products, to create and administer accounts for services contracted by you or the company that you represent, and other obligations derived from any legal relation between the titleholder of the personal information and O'ROURKE INVESTMENT FUNDS.

Your personal information may also have the following objectives:

1. To attend to legal requirements of competent authorities.

2. To inform you the scope of new financial products and services as well as benefits, funds research study’s, notifications of changes in the Funds Prospectus, and in general all of the publicity derived from the services that O'ROURKE INVESTMENT FUNDS offers.

3. To analyze the use of our financial products and services.

4. To fulfill our terms and conditions for the benefit of our services.

• O'ROURKE INVESTMENT FUNDS IS COMMITED WITH THE TITLEHOLDERS OF PERSONAL INFORMATION TO LIMIT THE USE OR DISCLOSURE OF INFORMATION UNDER THE FOLLOWING TERMS:

The personal information of the titleholder will be kept under strict confidentiality in accordance with the security, administrative, technical and physical measures that O'ROURKE INVESTMENT FUNDS implements in its policies and security procedures, remaining prohibited its ilegal disclosure and limiting its usage to third parties in accordance with that described in this Privacy Policy Advise.

• METHOD FOR EXERCISING THE RIGHTS OF THE TITLEHOLDER

The titleholder of the personal information can exercise his rights of access, rectification, cancellation, opposition, limitation of usage, disclosure or revocation as of January 6, 2012 by e-mail to: hcordova@oafondos.com.mx, or in person at the offices of O'ROURKE INVESTMENT FUNDS located at Avenida Mariano Otero 1917, Local 3, Zona C, Plaza Turquesa, Colonial Residencial Victoria, 45089 Zapopan, Jalisco, or by certified letter to the address mentioned above with a written request that contains the following information:

1. The full name of the titleholder of the personal information, address, and e-mail address to send the reply of the request.

2. The documents that verify the identity and, if necessary, the legal representation of the titleholder of the personal information.

3. A clear and precise description of the personal information in respect to those that seek to exercise any of the rights mentioned above.

4. Any other element or document that facilitates the localization of the personal information.

5. For requests to amend personal information, the titleholder should indicate the changes to be realized and submit the documentation that supports the petition.

• TRANSFER OF PERSONAL INFORMATION

O'ROURKE INVESTMENT FUNDS may transfer the information to:

1. Third party service providers to comply with the legal obligations acquired by O'ROURKE INVESTMENT FUNDS.

2. Third party service providers of research, information analysis, sending of information focused on the needs of the titleholder of the personal information, as well as the realization of other financial services necessary or required by the titleholder of the personal information.

3. Third parties derived from a corporate restructuring, including the merging, consolidation, sale, liquidation, or transfer of assets.

4. Other transmissions provided in the Law cited and its Regulations.

The third parties and the entities receiving the personal information assume the same obligations and/or responsibilities as O'ROURKE INVESTMENT FUNDS in accordance with that described in this Privacy Policy Advise.

The titleholder of the personal information accepts the transfer of his information in accordance with the terms described in this Privacy Policy.

• CHANGES TO THE PRIVACY POLICY

O'ROURKE INVESTMENT FUNDS will inform you of any changes made to this Privacy Policy by any of the following means:

1. Notices in the offices of O'ROURKE INVESTMENT FUNDS.

2. E-mail to the address provided by the titleholder of the personal information.

3. Notices on the O'ROURKE INVESTMENT FUNDS website (www.oafondos.com.mx).

4. In any other public or private communication medium provided in the contract that protects the operations signed with O'ROURKE INVESTMENT FUNDS.

Zapopan Jalisco, July 1, 2011