Orion Capital Management LLC considers the privacy of its clients to be of fundamental importance and has established a policy to maintain the confidentiality of the information you share with us. In providing investment management services to you, we collect certain nonpublic information about you. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as permitted or required by law. This policy is applicable to information for current and former clients.

Information we collect

The personal information we collect includes information required to communicate with you and assist us in effectively addressing your financial needs. This information could include:

• Your name and address
• Your email address and phone number(s)
• Investment objectives and experience
• Financial circumstances and credit references
• Account balance and account transactions
• Social security number
• Employment information and income

In connection with providing you investment services, we may collect your personal information from:

• Applications and other forms you submit to us, either in writing, in person, by phone, or electronically;
• Your transactions with us or others;
• Others such as custodians, broker/dealers, accountants, legal entities and other companies;
• Or public sources.

How information is used

All financial companies need to share some client personal information to run their everyday business. We use information about you to provide our investment management services to you. We do not sell your personal information to anyone. We do not disclose client non-public personal information to other companies who may want to sell their products or services to you. For example, we do not sell client lists, and we will not sell client names to catalogue companies.

We will not share non-public personal information about our clients with nonaffiliated third parties without prior client consent, except for specific purposes described below. We may disclose the information to third parties as permitted by law such as:

• the broker/dealers, custodians or other companies used to provide services to you;
• accounting firms, legal or other third party representatives as directed by you;
• or we may be required to give information about our business to regulatory authorities or as required by law. This could include personal information about you.

We only disclose non-public client information to nonaffiliated third parties without prior client consent when we believe it necessary for the conduct of our business or as required or permitted by law, such as:

• If you request or authorize the disclosure of the information;
• To provide client account services or account maintenance;
• To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
• To perform services for the firm or on its behalf to develop or maintain proprietary trading or other software;
• In connection with a proposed or actual sale, merger, or transfer of all or a portion of our business or an operating unit;
• To help us prevent fraud;
• With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;
• To comply with federal, state or local laws, rules and other applicable legal requirements; and
• Pursuant to any other exceptions enumerated in the California Information Privacy Act.

How information is safeguarded

We have procedures in place that we believe are reasonably designed to protect the security and confidentiality of your information. These include confidentiality agreements with companies we hire to help us provide services to you, password-protected user access to our computer files, training of employees, and strict confidentiality policies that apply to all employees.

We reserve the right to change this policy at any time as needed and you will be notified if any changes occur.

We do not make any disclosure of client nonpublic personal information to other companies who may want to sell their products or services to you. For example, we do not sell client lists, and we will not sell client names to catalogue companies.

Opt Out Provision

If, at any time in the future, it is necessary to disclose any client personal information in a way that is inconsistent with this policy, Orion Capital Management LLC will give its clients advance notice of the proposed disclosure so that they will have the opportunity to either opt-in or opt-out of such disclosure, as required by applicable law.

Clients are advised that Orion believes that sharing client private information under the circumstances noted above is either mandated by law or necessary for the Firm to conduct its business and to best service client accounts. Clients desiring to opt out of any third party disclosures should contact the Firm immediately. Opting out may necessitate that we terminate our management agreement with you and arrange for you to transfer your account.

Former Clients

Our Privacy Policy continues to apply to all former clients.

To Whom This Policy Applies

This Privacy Policy applies to individuals who obtain or have obtained services from Orion Capital Management used primarily for personal, family or household purposes.

Other Information

We reserve the right to change this Statement of Privacy Policy. The examples contained within this Privacy Policy are illustrations, and they are not intended to be exclusive. If you have any questions about our Privacy Policy, please contact Peter Thoms at thoms@orioncapitalmgmt.com or 619-435-1701.