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North Capital's Commitment to Privacy

North Capital is committed to protecting your privacy and safeguarding your personal and financial information. Your trust is our most important asset. The following Privacy Statement explains how North Capital collects and protects your personal information. For the purposes of this Statement, "North Capital" includes North Capital, Inc. along with its subsidiaries and affiliates. Custodians, brokers and other third parties generally maintain their own Privacy Policies and are not covered by this Privacy Statement, except as described below. If you have any questions that this Statement does not address, please contact your advisor. By establishing an advisory relationship with North Capital or by using the North Capital Web Portal, you give your consent to the collection and use of certain personal information as explained in this Statement. Any dispute regarding the Privacy Statement is subject to this notice, the Web Portal Terms of Use, and the North Capital Investment Advisory Agreement, including arbitration of disputes and limitation of damages.

What information does North Capital collect?

North Capital collects and maintains information required to communicate with you, including your name, mailing address, telephone numbers, and e-mail address. In addition, North Capital requests information to identify who you are, such as government identification, employer name and address, and Social Security or Employer Identification number. To facilitate the creation of an Investment Policy Statement and to comply with state and federal laws and regulations, North Capital also collects information to assess your current financial situation, your goals and objectives, and your investment experience. The information requested may include your approximate annual income, sources of income, approximate net worth, and approximate value of investment assets. If you register through the Web Portal, North Capital may collect certain demographic information, including age, gender, education, occupation, etc. Certain information also is collected automatically if you access the Web Portal, including your Internet Protocol (IP) address, browser type, operating system, Internet service provider (ISP), pages accessed, and prior and following sites that you view. The North Capital Web Portal utilizes cookies, which are small text files sent from the server to your local computer. Cookies help North Capital by providing operational data that we can use to improve the navigation, usability and content of the Web Portal.

When does North Capital obtain information about you?

Most of the information collected by North Capital is provided directly by you, by completing the questionnaires and documentation required to create an Investment Policy Statement, develop an Investment Plan, and open custodial accounts. Other ways information may be obtained are by (1) observing your usage of the Web Portal, (2) providing services to you, and (3) collecting information available from publicly or commercially available sources, such as online databases.

Why does North Capital gather information?

North Capital gathers information about you and your financial situation in order to provide you with investment advisory solutions that are tailored to your particular situation and to meet your individual needs. North Capital collects information to create an Investment Policy Statement and an Investment Plan, to open up custodial accounts, to transact business efficiently and effectively, and to comply with all applicable laws and regulations. In addition, North Capital may gather information to help expand the scope and improve the quality of services that North Capital may offer to you now or in the future.

How does North Capital use clients' personal information?

The trust of our clients is our most important asset. North Capital is careful to use personal information only as appropriate to provide clients with premium service while maintaining confidentiality and security. For example, North Capital may use information collected to verify your personal identity and contact details, create an Investment Policy Statement and an Investment Plan, complete account opening forms, and provide you access to the North Capital Web Portal. If the information you provide suggests that other services may be suitable and appropriate for you, North Capital may offer additional advisory or investment management services to you. North Capital also may use the demographic information collected, along with general demographic information provided by third parties, in order to develop additional capabilities and services for clients. Should you elect to terminate your relationship with North Capital, your information will be retained as necessary to comply with applicable laws and regulations.

What information may be shared with affiliates, partners, and third-party service providers?

North Capital may share information with affiliates, partners and third-party service providers if the information is required to provide a service you have requested or to provide you the opportunity to participate in the products or services offered by the affiliates. The use of your personal information is limited to the purposes identified in North Capital's agreement with the affiliate, partner or third-party service provider, although you may be asked to agree to additional terms including acknowledging additional privacy terms, as a condition of accepting the provision of services. An affiliate is a company that North Capital owns or controls or with which there is common ownership with us and our shareholders. North Capital may share information related to the services provided to you, such as name, e-mail address, mailing address, date of birth, employment status, and general account and demographic information. North Capital does not share information with affiliates other than the type of experience information described above. A partner or third-party service provider is a firm contracted by North Capital to support certain functions of the advisory and investment management business, such as account processing, research, reporting, information technology support, or custodial services. Use of any shared information is strictly limited to the provision of the contracted service, and all partners and third-party service providers with whom personal information has been shared are required to protect such information in a manner similar to the way we protect such information, including restricting its dissemination except as necessary to provide the contracted service. Any personal information that you provide directly to another company that also is a partner or third-party service provider to North Capital, will no longer be controlled under our Privacy Statement. North Capital also reserves the right to disclose your personal information to regulatory, law enforcement or other government authorities, and as necessary to protect our rights or property.

Does North Capital's Privacy Statement apply to other web sites linked to the Web Portal?

No. North Capital is not responsible for the privacy policies or the content of sites that link to or are linked from the Web Portal, and has no control of the use or protection of any information provided by you or collected by those sites. Whenever you follow a URL 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 third party.

What steps does North Capital take to safeguard clients' personal information?

North Capital utilizes a broad array of security software, systems, and operational procedures to ensure the confidentiality and safety of your personal information. While no security system is flawless, North Capital is regularly reviewing and upgrading the security technology and procedures that safeguard your confidential information. If you access the Web Portal, a unique login identifier and password will be maintained for your online account access. You are responsible for keeping this information secret. You also may be offered online access to your account information through the custodian's own online systems. In such case you are responsible for safeguarding the credentials provided by the custodian.

Will I be able to review, change or correct my information?

Yes. Personal identifying information may be reviewed, changed or corrected at any time. You are responsible for maintaining the accuracy and completeness of your personal and other information. Please review your information at regular intervals to ensure that it is accurate and complete. If you would like to review your personal information, or if you believe that any of the information you have provided may be incorrect or out of date, or if you have any other questions or concerns regarding your personal information or regarding this privacy policy, please contact your advisor.

How will I know if there are any changes to this Privacy Statement?

In the event that North Capital makes any material changes to this Privacy Statement, the revised Privacy Statement will be posted to the Web Portal along with a notice informing you of such changes. In addition, this Privacy Statement has an effective date displayed in the lower, left corner indicating when it first came into effect. You should review this Privacy Statement at regular intervals to remain informed of any changes. You agree that the act of posting a revised Privacy Statement electronically on the Web Portal satisfies any obligation of North Capital to physically deliver the Privacy Statement to you.


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