Disclosures

As of February 2, 2022

It is the policy of Aeon Partners, Inc. (“Aeon Partners“) and its Affiliates to protect the privacy of any nonpublic, personal information (Confidential Information) about past, present or prospective Clients or Investors who are natural persons or other legally recognized entity. It is our policy not to sell the information under any circumstances and to limit disclosure of Confidential Information:

• to third parties who are authorized by law or rule of any regulatory authority to have the information (such as securities regulators),
• to persons who have been authorized to receive the information in writing by the Client or Investor whose Confidential Information is being shared (such as the Client’s or Investor’s accountant or adviser);
• to third parties that perform services on our behalf (such as our auditors, accountants and attorneys, all of whom are subject to strict confidentiality requirements);
• to third party money managers for which we are providing services; and
• if necessary in providing our services to our Clients or Investors.

Collection and Sharing of Confidential Information

We do not share any personal, nonpublic information about any Client that is a natural person or legal entity. We do not share Confidential Information that we may receive with any third party, except as described above. Occasionally, we may be given Confidential Information or such information may be shared with us by prospective Clients, Investors or their advisers or representatives. Any Confidential Information that we receive will be protected under our privacy policy as described in this notice.

How We Protect Confidential Information

We have implemented several procedures that we believe are reasonably designed to protect Confidential Information, if any, that we may obtain. Those procedures include:

• keeping hard copies of documents containing Confidential Information in locked cabinets;
• protecting electronic information by password, encryption or similar means;
• we educate our employees to be sensitive to privacy concerns and hold them accountable for violations of Aeon Partner’s privacy policy;
• limiting the persons at Aeon Partners who have access to Confidential Information to only those persons who need the information to perform their duties; and
• limiting access by service providers to Confidential Information to only those persons who are required by contract or law to maintain the confidentiality of Confidential Information.