PRIVACY AND CONFIDENTIALITY POLICY

In its normal course of business, Pearl and its service providers collect nonpublic or confidential information from the following sources:


  • Investment Management Agreement or other forms, such as names, addresses, telephone numbers, social security numbers, assets and income.
  • Written reports and other documents related to Pearl's investment management activities.


Except as stated below, employees are generally prohibited, both during, and after termination of, their employment, from disclosing nonpublic or confidential information regarding (1) general business activities of Pearl, (2) past, prospective and existing advisory clients, and (3) past, current or prospective investments by Pearl to any person or entity outside Pearl, including family members. If an employee has any doubt as to whether certain data constitutes nonpublic or confidential information, he or she shall consult with the CCO.


Pearl will generally only disclose nonpublic or confidential advisory client information under the following circumstances:


  • Pursuant to the advisory client's written request.
  • When required by law or regulation.
  • As necessary to service providers, including, but not limited to, administrators, attorneys, technology and risk management consultants, accountants and auditors that serve Pearl If an advisory client decides to fully terminate a Pearl agreement, Pearl will continue to adhere to this policy with respect to the information it has about the advisory client. Disposal of Non-Public or Confidential Information Employees are required to dispose of all nonpublic and confidential information by shredding it or placing it in the shredding bins.


PRIVACY NOTICE - DELIVERY TO ADVISORY CLIENTS

Pearl is required to deliver a Privacy Notice within each Investment Management Agreement to each advisory client when the relationship is established. Pearl delivers its Privacy Notice to prospective advisory clients by including with other investment materials it sends to prospective advisory clients. Pearl is also required to annually deliver the Privacy Notice to its existing advisory clients. Pearl fulfills its annual obligation by providing the Privacy Notice to all existing advisory clients.


Any questions concerning this privacy notice should be directed to the Advisor:


Pearl Capital Advisors, LLC
505 Montgomery St, STE 1143
San Francisco, CA, 94111
415-341-2115