(initial notice as required by SEC Regulation S-P and the Gramm-Leach-Bliley Act)

We consider client privacy to be fundamental to our relationship with our clients. Since inception, we have been committed to maintaining the confidentiality, integrity, and security of clients' personal information entrusted to us. Internal policies have been developed to protect this confidentiality, while allowing client needs to be served.

In the course of providing products and services, we collect non-public personal information about clients. We collect this information from sources such as account applications and other information provided to us by our clients.

We do not disclose any non-public personal information about clients or former clients to non-affiliated parties, except as directed by clients, as necessary in order to service a client account or as required by law. Your information is used by us or our service providers primarily to complete transactions or account changes that you request or authorize. In the normal course of serving clients, information we collect may be shared with companies that perform various services for us, such as transfer agents and custodians. The organizations that receive client information receive only the information necessary to carry out their assigned responsibilities and are authorized to use that information only for the services required, and are not permitted to share or use this information for any other purpose.

We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted by law (for example, to cooperate with regulators or law enforcement authorities, such as responding to a subpoena or other legal process, or to protect accounts from fraud), or to resolve client disputes.

We do not sell client information—whether it is your personal information or the fact that you are a Bricks and Mortar Capital client—to anyone.

If you are an individual who has or will have an account with us, you typically provide personal information when you execute a client agreement. This information may include your:

  • • Name and address, including email address.
  • • Social Security or taxpayer identification number.
  • • Assets.
  • • Account balance.
  • • Investment activity.

Access to clients' non-public personal information is restricted to employees who need to access to that information to provide products or services. A client's right to privacy extends to all forms of contact with us, including telephone, written correspondence, and electronic media, such as the Internet.

This privacy policy describes our privacy practices for both current and former clients. We may disclose non-public personal information about former clients to the same extent as for current clients.

As required by federal law, we will send you notice of our privacy policy annually, so long as you have an account with us. We may revise our policy in the future, and will provide you with a revised policy if the changes materially alter the prior policy. We 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.

For questions concerning this policy, please contact us by writing to: Bricks and Mortar Capital, LLC, 10680 West Pico Blvd., Suite 360, Los Angeles, CA 90064.

Amended March 2015