Protecting your privacy is important to Scenic Advisement. We want you to understand what information we may gather, the purpose for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. This Privacy Policy applies to Scenic Advisement’s collection, use, retention and security of the nonpublic personal information about our clients who are consumers holding accounts with us for their personal, family or household purposes. This policy is provided to you as required by applicable financial privacy laws.

How We Gather Information

As part of providing you with financial products or services, we may obtain information about you from the following sources:

• Applications, forms, and other information that you provide to us, whether in writing, in person, by telephone, electronically or by any other means;

• Your transactions and experiences with us;

• Consumer reporting agencies — this information may include account information and information about your creditworthiness;

• Information from outside sources regarding your employment, credit and other relationships;

• General information from other outside sources, such as data from public records, that is not assembled or used for the purpose of determining your eligibility for our products or services;

• As required by the USA PATRIOT Act, we also collect information and take actions necessary to verify your identification; and/or

The Information We Have About You

The typical personal information we may collect about you would include:

• You name, address and other contact details;

• Your age, occupation and marital status;

• Financial information, including source of wealth, investment experience and objectives, and risk tolerance;

• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.; and/or

• Certain identifying information (e.g. passport or driver’s license photo, etc.) as required by laws and regulations addressing due diligence and related matters.

How We Use and Disclose Information

Scenic Advisement will not disclose your personal information to anyone, except as described in this policy.

Scenic Advisement may disclose your personal information to companies that perform administrative services on our behalf, such as custodians, lawyers, accountants, etc., or assist us in marketing our products and services to you. These companies will use this information only for the services for which we hired them and are not permitted to use or share this information for any other purpose. We may also disclose your personal information to fulfill your instructions (such as your request to share information with your accountant, etc.) or pursuant to your express consent.

Scenic Advisement may disclose information with regulators, auditors or other vendors in their capacity as outlined in our agreements or as required by law. We may provide nonpublic information without your permission to third parties:

• to respond to a subpoena or court order, judicial process or regulatory authorities;

• to consumer reporting agencies, in accordance with the Fair Credit Reporting Act;

• in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or an operating unit;

• to protect against fraud.

If your relationship with us ends, Scenic Advisement will continue to treat your personal information, to the extent we retain it, as described in this policy.

Our Security Practices and Information Accuracy

Scenic Advisement is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized employees and agents. Our employees and services providers are held to stringent standards of privacy. We maintain physical, electronic, and procedural safeguards to protect customer information against loss, misuse, damage or modification and unauthorized access or disclosure.

Questions?

If you have questions or concern about this policy, please contact us at 415-528-7301 or email us at info@scenicadvisement.com or send a letter to Scenic Advisement, 915 Battery Street, First Floor, San Francisco, California 94111.

Last Updated: April 2018