PRIVACY POLICY

Financial institutions like HonTe Advisors LLC (“HonTe” or the “Firm”) are required to provide privacy policy notices to their clients and potential clients who are natural persons (collectively, “clients”). The Firm believes that protecting the privacy of clients’ nonpublic Personal Information (“Personal Information”) is of the utmost importance. Personal Information includes nonpublic information about a client that is personally identifiable and that the Firm obtains in connection with providing a financial product or service to the client. For example, Personal Information includes information regarding account balance and investment activity. This notice describes the Personal Information that the Firm collects about the client, and its treatment of that information:

• HonTe collects Personal Information about clients from the following sources: (i) information the Firm receives from a client on the advisory agreement and related forms (for example, name, address, Social Security number, birth date, assets, income, and investment experience); and (ii) information about the client’s transactions with the Firm, its affiliates, or others, including service providers (for example, account activity and balances).
• HonTe does not disclose any Personal Information it collects, as described above, about its clients or former clients to anyone other than in connection with the administration, processing and servicing of customer accounts or to its accountants, attorneys and auditors, and other service providers that are necessary to carry out the Firm’s everyday business or otherwise as permitted or required by law or regulation.
• HonTe restricts access to Personal Information it collects about clients to its employees and agents who have been advised as to the proper handling of such information and who need to know that information in order to provide products or services to clients. The Firm maintains physical, electronic and procedural controls in keeping with federal standards to safeguard your Personal Information.
• HonTe reserves the right to change this Notice, and to apply changes to information previously collected, as permitted by law. The Firm will inform clients of any changes as required by law.

Questions about HonTe’s Notice of Privacy Policy should be directed to Paul Christopher Lutton, CCO at lutton@honteinv.com