Privacy Policy

Effective Date: October 1, 2018

1) YOUR PRIVACY IS OUR PRIORITY

Praus Capital Management, LLC (“the Company”) is committed to safeguarding the personal information that you provide us. This Privacy Policy describes how we handle and protect personal information we collect about individuals, such as you, who apply for or receive our products and services. The provisions of this notice apply to former customers as well as our current customers.

2) WHY AND HOW WE COLLECT PERSONAL INFORMATION

When you apply for or maintain an investment account with the Company in one of our investment products, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. The personal information we collect about you includes:

• information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets, and income;

• information about your transactions with us and with our affiliates, if any;

• information we may receive from consumer reporting agencies, such as your credit history and creditworthiness, and other entities not affiliated with the Company if we so choose to gather this information; and

• information you provide to us to verify your identity, such as a passport or drivers license, or received from other entities not affiliated with the Company.

3) HOW WE PROTECT PERSONAL INFORMATION

We limit access to your personal information to those employees who need to know in order to conduct our business, service your account, and help you accomplish your financial objectives, such as providing you with a broad range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so. We maintain physical, electronic, and procedural safeguards to protect your personal information. We do not share, lease, rent or sell your name or personal information with or to anyone.

4) SHARING INFORMATION WITH OUR AFFILIATES

We have affiliated entities. We may have business alliances with selling agents, other NFA Members, wholesalers, and broker dealers that are critical to raising assets for our business products. We may share personal information described above with our affiliates and alliances for business purposes, such as servicing customer accounts and informing customers about new products and services, and as permitted by applicable law. We do not share any information with these entities if they were not responsible for selling the product to you. The information we share with these third parties business alliances may include the information described above, such as name, address and account information such as account balance in one of our products that they sold to you. We will not share information with them that they will not already have. For example, we will not share with them information such as credit history appearing on a consumer credit report or net worth and income information appearing on applications that they may not have for our products and services.

5) DISCLOSURE TO NON-AFFILIATED THIRD PARTIES

In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers with us, including companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail monthly account statements, auditors, lawyers, and compliance consultants. These companies acting on our behalf are required to keep your personal information confidential. Also, we may disclose personal information with non-affiliated companies and regulatory authorities as permitted or required by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

6) ACCESSING AND REVISITING YOUR PERSONAL INFORMATION

We endeavor to keep our customer files complete and accurate. We will give you reasonable access to the information we have about you. Most of this information is contained in account statements that you receive from us and applications that you submit to obtain our products and services. We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have a question or concern about your personal information or this privacy notice, please contact your account representative.