ALPHA SQUARED CAPITAL, LLC

PRIVACY NOTICE

Maintaining the trust and confidence of our clients is a high priority. That is why we want you to
understand how we protect your privacy when we collect and use information about you, and the steps
that we take to safeguard that information. This notice is provided to you on behalf of Alpha Squared
Capital, LLC (“ASC”).

Information We Collect: In connection with providing investment products, financial advice, or other services,
we obtain non-public personal information about you, including:

  • Information we receive from you on account applications, such as your address, date of birth, Social
    Security Number, occupation, financial goals, assets and income;
  • Information about your transactions with us, our affiliates, or others;
  • Information about your visit to our website. We store that information in web server logs, which are
    records of the activities on our sites. The servers automatically capture and save the information
    electronically. The information we collect in web server logs helps us administer the site, analyze its
    usage, protect the website and its content from inappropriate use and improve the user’s experience.

Categories of Information We Disclose: We may only disclose information that we collect in accordance with
this policy. ASC does not sell customer lists and will not sell your name to telemarketers.

Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account
at ASC, except under the following circumstances:

 

  • To entities that perform services for us or function on our behalf, including financial service providers,
    such as a clearing broker-dealer, investment company, or insurance company, other investment
    advisers;
  • To comply with broker-dealer firms that have regulatory requirements to supervise certain
    representatives’ activities;
  • To third parties who perform services or marketing, client resource management or other parties to
    help manage your account on our behalf;
  • To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
  • To our attorneys, accountants or auditors; and
  • To government entities or other third parties in response to subpoenas or other legal process as
    required by law or to comply with regulatory inquiries.

How We Use Information: Information may be used among companies that perform support services for us,
such as data processors, client relationship management technology, technical systems consultants and
programmers, or companies that help us market products and services to you for a number of purposes, such
as:

 

  • To protect your accounts/non-public information from unauthorized access or identity theft;
  • To process your requests such as securities purchases and sales;
  • To establish or maintain an account with an unaffiliated third party, such as a clearing brokerdealer providing services to you and/or ASC;
  • To service your accounts, such as by issuing checks and account statements;
  • To comply with Federal, State, and Self-Regulatory Organization requirements;
  • To keep you informed about financial services of interest to you.

 

Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility
information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing
use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the
consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the
marketing solicitations; and (3) the consumer has not opted out.

Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who
need to know that information to provide products or services to you and perform their respective duties. We
maintain physical, electronic, and procedural security measures to safeguard confidential client information.

Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy is
available upon request.

Departing Investment Adviser Representatives (“IARs”): ASC recognizes that your relationship with your
IAR is important. If your IAR leaves ASC to join another firm or elects to sell or transfer some or all of his or her
business, your IAR might retain copies of your personal information so that your account can continue to be
serviced or to contact you regarding your options. Subject to legal and regulatory requirements, your personal
information maintained on ASC systems and those of ASC’s service providers may be shared with your new
financial service provider. If you do not want your IAR to take your information should he or she leave or
transfer his or her business from ASC, you have the right to opt out of such disclosure. You may opt out now or
at any time in the future. If you have a joint account, ASC will treat an opt out by any joint customer as applying
to all joint customers. If you wish to exercise your right to opt out under this section, please contact us at (480)
470-6200 or by mail.

Certain states have adopted a requirement for you to approve the sharing of information in advance, otherwise
known as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts, Maine, Alaska, North
Dakota or Vermont), then ASC will require your consent to share your information with unaffiliated third
parties who are not servicing your account. State requirements vary and may change without notice.

Succession Planning: In the event that the owner(s) of ASC retire, become incapacitated or perish
unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating
a business succession plan. A change in control of ownership of ASC would require your consent, as dictated by
your signed agreement with ASC, in order to continue providing services to you.

Your Right to Opt Out: Federal privacy laws give you the right to restrict some sharing of your personal
financial information. These laws balance your right to privacy with ASC’s need to provide information for
normal business purposes. You have the right to opt out of some information sharing with companies that are
(1) Part of the same corporate group as your financial company (or affiliates); or (2) Not part of the same
corporate group as your financial company (or non-affiliates). Choosing to restrict the sharing of our personal
financial information will not apply to (1) Information about you to firms that help promote and market the
company’s own products or products offered under a joint agreement between two financial companies; (2)
Records of your transactions–such as your loan payments, credit card or debit card purchases, and checking
and savings account statements–to firms that provide data processing and mailing services for your company;
(3) Information about you in response to a court order; and (4) Your payment history on loans and credit cards
to credit bureaus. If you opt out, you limit the extent to which ASC can provide your personal financial
information to non-affiliates.

Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our
Privacy Policy will continue to apply to you.

Complaint Notification: Please direct complaints to: Corbin Hixson at Alpha Squared Capital, LLC, 9319 N 94th
Way, Suite #900, Scottsdale, Arizona 85258; (480) 470-6200.

Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate
confidential information, we will notify you. If you have any questions concerning this Privacy Policy, please
contact us at: Alpha Squared Capital, LLC, 9319 N 94th Way, Suite #900, Scottsdale, Arizona 85258; (480) 470-
6200.

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Alpha Squared Capital  is a Registered Investment Adviser. Advisory services are only offered to clients or prospective clients where Alpha Squared Capital and its representatives are properly licensed or exempt from licensure. This website is solely for informational purposes. Past performance is no guarantee of future returns. Investing involves risk and possible loss of principal capital. No advice may be rendered by Alpha Squared Capital  unless a client service agreement is in place.