BREAKWATER CAPITAL

PRIVACY NOTICE

BREAKWATER CAPITAL is committed to maintaining confidentiality, integrity and security of personal information entrusted to us by our current and prospective clients. We are proud of our privacy practices and want you to know how we protect your information and how we use it.

When you seek our services you provide us with personal information by completing an application, transfer accounts form, questionnaire, etc. This information may include:

Name and address
Social Security number
Assets
Income
Accounts balances
Accounts at other institutions

It is our policy not to:

1. Sell such information about our current or former clients or their accounts to third parties, or
2. Share such information, except when needed to complete transactions at the client’s request.
3. We do not share or sell SMS opt-in, or phone numbers for the purpose of SMS.

In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information to those fund companies or groups we deal with such as Fidelity Investments, TlAA-CREF or Schwab.

We will release information about you if you direct us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to protect your account from fraud).

We limit access to your personal information to those employees who need to know such information to service your accounts. Furthermore, your personal information is protected by physical, electronic and procedural safeguards in accordance with federal and state standards, including strict access and use of electronic data and authentication procedures to ensure the confidentiality of the information. This is done through a strict policy of limited access to our office and to our computers.

For your protection, we recommend that you do not provide your account information, user name, or password to anyone. If you become aware of any suspicious activity relating to your account, please contact us immediately.

As required by federal law, we will notify you of our privacy policy annually. We reserve the right to modify this policy at any time, but rest assured that if we do change it we would notify you of such changes promptly.

Delivery of Privacy Notices

Initial Privacy Notices

Breakwater Capital shall deliver an initial privacy notice to a client before the client relationship is established—i.e., before it begins to manage a client’s account.

Annual Privacy Notices

Breakwater Capital will notify its existing clients of our privacy policy annually. We reserve the right to modify this policy at any time, but rest assured that if we do change it we would notify you of such changes promptly.