We collect personal information about you that we obtain in connection with providing a financial product or service to you (“nonpublic personal information”) from information we receive from you on applications or other forms, information about your transactions with us or others, and information we receive from third parties such as transfer agents, custodians, and financial institutions. The nonpublic personal information we may collect includes your name; postal address; telephone number; email address; Social Security number, tax identification number or any similar number or other government-issued ID; online account information, such as username and password; and financial account numbers and routing information.

We only use information about you and your account to help us better serve your investment needs, to respond to your inquiries and fulfill your requests, to personalize your experience on our website, to suggest services or educational materials that may be of interest to you, or for our business purposes (e.g., data analysis, audits, fraud monitoring and prevention).
We do not disclose any nonpublic personal information to anyone, except (1) our affiliates, (2) our third-party service providers, (3) as required or permitted by law, (4) with your consent, or (5) as otherwise described in this Privacy Policy.

We may disclose your nonpublic personal information to nonaffiliated third parties (such as financial service providers) for our everyday business purposes, such as to process transactions, maintain accounts, prevent fraud, detect and prevent cyber-attacks or attempts to commit identity theft, provide requested products and services, respond to court orders and legal investigations and report to credit bureaus.

We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; or (c) to protect our rights, privacy, safety or property, and/or that of you, or others.

If you terminate your relationship with us, this Privacy Policy (as it may be modified in the future) will continue to apply to your nonpublic personal information after that time, and we will retain nonpublic personal information in accordance with federal law and our records retention policies.

We maintain physical, electronic and procedural policies and safeguards designed to protect nonpublic personal information within our organization. We also endeavor to restrict access to your personal and financial data to authorized associates who have a need for these records and who are required to safeguard your sensitive personal information. Please do not send such information to us in non-secure e-mails. We may request that you provide us with your Social Security number in order for you to make an
investment. We only use and disclose such information to facilitate your requests, prevent fraud or other harm, and to comply with legal, audit, tax, insurance and other similar requirements, and otherwise in accordance with applicable law.

We may change this Privacy Policy. The “Last Updated” line at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective upon receipt of the revised Privacy Policy. We may notify you of some changes to this Privacy Policy and we may give you choice with respect to them.

If you have any questions about this Privacy Policy, please contact us tony.condino@lcapitalmgmt.com (650-544-5662) or tony.condino@lcapitalmgmt.com (909-938-2533).