Northern Capital Securities Corporation, as a registered broker-dealer and in keeping with the "know your customer" rule, is required to obtain personal information from you to aid us in meeting your investment needs and to assist us in making certain decisions and determinations in relation to your account(s) with us. Given the sensitive nature of such information, we realize that concerned consumers may have questions about our privacy policies and how we use personal data in our day-to-day business operations. We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms;

• Information about your transactions with us or others; and

• Information we receive from a consumer-reporting agency.

We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

Northern Capital Securities Corporation restricts access to your personal and account information to those employees who need to know that information to provide products or services to you. Employees are required to treat your account information with the strictest confidence and will not divulge information or transact business for anyone who cannot be identified as an individual authorized to transact business for the account in question. Northern Capital Securities Corporation maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information.

Northern Capital Securities Corporation supports our clients’ right to privacy and we are committed to protecting it. Our clients can have confidence in our resolve to handle personal information in the most professional and responsible manner possible. If you believe there are inaccuracies in your personal information as maintained in our records, please contact us. We will investigate and correct any erroneous information.

We do not sell customer information to third parties. Northern Capital only discloses information about you and your account(s) to others under the following circumstances:

• To meet the transaction and record keeping requirements of our correspondent clearing arrangement;

• When it is necessary to complete a transaction on your behalf;

• To comply with a request or court order of a government or regulatory agency, such as the Securities and Exchange Commission (SEC) or Internal Revenue Service;

• At your request, to verify the existence and condition of your Account for a third party, such as a bank or credit agency;

• To perform credit checks;

• As otherwise required by applicable laws, rules, or regulations.

Northern Capital Securities Corporation is dedicated to protecting your privacy. If you have a concern about your personal or account information, please call us for assistance. As always, we thank you for your business and we look forward to serving your investment needs now and into the future.