Capita Financial Network, LLC takes precautions to maintain the privacy of personal information concerning its clients. These precautions include the adoption of certain procedures designed to maintain and secure such clients’ nonpublic personal information from inappropriate disclosure to third parties. Federal regulations require Capita Financial Network, LLC to inform clients of this privacy Policy.

Capita Financial Network, LLC collects nonpublic personal information about its clients from theFollowing:

• Client profile sheets
• Forms and questionnaires
• Other communications (SMS, Email, verbal) with clients

Examples of nonpublic personal information include but are not limited to names, addresses, phone numbers, SSNs, and the like.

Capita Financial Network, LLC collects nonpublic personal information for the purpose of complying with regulatory and custody requirements, as well as Know Your Client rules. The information is retained on file for as long as the person is a client at Capita and for years after termination, as required by law and regulation.

Capita Financial Network, LLC does not disclose or share any nonpublic personal information about its prospective, existing or former clients or investors to anyone, except as permitted by law and regulation. Also, phone numbers collected for SMS purposes are not shared, except as permitted by law and regulation.

Capita Financial Network, LLC restricts access to nonpublic personal information about its clients to those employees and agents of Capita Financial Network, LLC who need to know that information in order to provide services to its clients. Capita Financial Network, LLC may also disclose such information to its affiliates and to service providers and financial institutions that provide services to clients. Capita Financial Network, LLC will require such third-party service providers and financial institutions to protect the confidentiality of the clients’ nonpublic personal information and to use the information only for purposes for which it is disclosed to them. Capita Financial Network, LLC maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard the clients’ nonpublic personal information and which Capita Financial Network, LLC believes are adequate to prevent unauthorized disclosure of such information.

If you have any questions concerning this privacy policy, please contact Mr. Scott Watko, ChiefCompliance Officer, at 801-566-5058.