Privacy Policy Statement

Northern Capital Securities Corporation 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;
• 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 record keeping requirements;
• 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;
• To perform credit or background checks;
• As otherwise required by applicable laws, rules, or regulations.

Northern Capital sends clients notice of our privacy policy annually for as long as you maintain an ongoing relationship with the firm. Periodically the firm may revise our privacy policy, and will provide you with a revised policy if the changes materially alter the previous privacy policy. Northern Capital will not, however, revise our privacy policy to permit the sharing of non‐public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. As required by privacy laws in Massachusetts, investment adviser clients must “opt‐in” to share non-public personal information with non‐affiliated third parties before any personal information is disclosed.