Eolas Capital LLC ("Eolas Capital" or the “Company”) 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. This privacy policy notice informs you on what information we collect and how we use and safeguard that information.

Information We Collect

We may collect certain non-public personal 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, 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 and service providers).
• 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 to you and services.

If you decide to become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time.

Information We Disclose to Affiliates and Unaffiliated Third Parties

Eolas Capital has business relationships with our affiliates and with non-affiliated third parties (such as attorneys, auditors, accountants, brokers, custodians, investment advisers and other consultants), who, in the ordinary course of providing their services, may require access to your Customer Information. Eolas Capitals’s engagement with un-affiliated third-party service providers may be necessary for the Company to provide investment advisory services to you. In addition, the Company selects and retains service providers that it believes are capable of maintaining appropriate safeguards for Customer Information, and the Company will require written agreements from its service providers to maintain such safeguards.

We do not disclose Customer Information we collect about you except (i) to furtherance of our business relationship and only to those persons necessary to effect the transactions and provide the authorized services; (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); and (iii) to our attorneys, accountants, and auditors.  

Eolas Capital may disclose information to non-affiliated third parties as required or allowed by law. For example, this may include disclosures in connection with a subpoena or similar legal process, a fraud investigation or a regulatory audit or examination.

We do not sell any Customer Information to any third party.

Opt-In Rights

Eolas Capital follows an “opt-in” provision as required by Massachusetts State General Laws. The Massachusetts Securities Division has published a policy notice on this matter that is available on their website at http://www.sec.state.ma.us/sct/sctgbla/gblaidx.htm.

Eolas Capital will not share non-public personal information with non-affiliated third parties unless a customer opted in of certain sharing through a signed statement in which you will make an affirmative declaration of permission to disclose such information.

There is no opt-in requirement for any disclosure of Customer Information to service providers or joint marketers, but Eolas Capital must disclose the nature of any information to be shared with a service provider or joint marketer and must enter into contractual arrangements to require the third party to maintain confidentiality of the information.

The opt-in requirement also does not apply to disclosure of confidential information in the following circumstances:

• For resolving consumer or customer disputes or inquiries;
• To persons holding a legal or beneficial interest relating to the consumer or customer;
• To persons acting in a fiduciary or representative capacity on behalf of a consumer or customer;
• To provide information to agencies assessing the Company's compliance with industry standards, and to the Company's attorneys, accountants, and auditors;
• In connection with a proposed or an actual sale or merger of the Company;
• To respond to a regulator’s examination of the Company; or
• To comply with a civil, criminal, or regulatory investigation by federal, state, or local authorities.

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