Virtera Partners, LLC

Virtera Partners LLC has adopted this privacy policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information.

Information We Collect: We collect certain nonpublic information about you ("Customer Information"). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:

• Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.

• Identifying information such as your name, age, address, social security number, etc.

• Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).

• Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill a service request.

Security of Your Information: We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

Virtera Partners shares office space with an unaffiliated third party. In order to safeguard and protect client personal information and Virtera's proprietary information, Virtera has adopted the following procedures:

• All computers are required to be locked and password-protected when not in use. As an additional safeguard, each company computer will automatically lock after 2 minutes of inactivity.

• All file cabinets will remain locked at all times.

• All files must be immediately returned to the locked file cabinet when not in use.

• Access to electronic files requires permission based access and must be password protected.

• If printing information that contains a client's nonpublic personal information, all associated persons are required to print to their local printer, rather than a shared printer.

• Associated Persons shall avoid business discussions in common areas and/or in shared office spaces.

Information We Disclose: As required or permitted by law, we disclose the nonpublic personal information we collect about our customers: (i) to persons necessary to effect the transactions and provide the services that our customers authorize, such as broker-dealers, custodians, independent managers etc.; (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.

Information We Disclose to Affiliated Third Parties: We share information about you, including personal information, with third parties when you give us consent to do so. We also work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, analysis and other services for us, which may require them to access or use information about you, sometimes including personal information. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including instructions that require that they abide by policies and procedures designed to protect your information.

Opt Out Right of Sharing with Non-affiliated Third Parties: If you prefer that we not disclose nonpublic personal information about you to non-affiliated third parties, you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to non-affiliated third parties, you may call our main number 216-859-8800 and ask to speak to the Chief Compliance Officer.

Former Clients: If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time.

Changes to Our Privacy Policy: In the event there were to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt-out of such disclosure arrangements.

Questions: If you have questions about this privacy notice or about the privacy of your customer information call our main number 216-859-8800 and ask to speak to the Chief Compliance Officer.