FavorPoint Capital LLC
Disclosure Document

Privacy Policy

We collect non-public information about FavorPoint Capital's clients from the following sources:

• Information we receive from you in the course of our business arrangement with you and/or your organization; and
• Information about your transactions with us, our affiliates, or others.

We do not disclose any non-public information about our clients or former clients to anyone, except as required or permitted by law. Moreover, we will not release information about our clients or former clients unless one of the following conditions are met:

• We receive your prior written consent;
• We believe the recipient to be you or your authorized representative; or
• We are required by law to release information to the recipient.

We only use information about you and your organization to help us better serve your financial services needs, or to suggest services or educational materials that may be of interest to you and/or your organization.

To further protect your privacy, our website uses security programs and devices, which we believe to be in accordance with current business practices, including data encryption and other tools. We maintain electronic, and procedural safeguards to guard your non-public information. We also restrict access to your non-public information and financial data to authorized FavorPoint Capital associates who have a need for these records. We advise you not to send such information to us in non-secure emails.

Confidentiality and Security

We maintain electronic and procedural safeguards to guard your personal information. We require all nonaffiliated organizations to conform to our privacy standards and they are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we continue to adhere to the privacy policies and practices described in this notice even after your engagement is closed or becomes inactive.

We continue to conduct our business in a manner that conforms with our pledge to you, your expectations, and all applicable laws.

Anti-Money Laundering

It is the duty of the Firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. To this end, FavorPoint Capital will need to verify your identity. Additionally, we are required to conduct a check against the Treasury's Office of Foreign Assets Control (OFAC) to ensure compliance with federal anti-money laundering laws.

Business Continuity Plan

In compliance with Rule 4370, FavorPoint Capital will ensure that the Firm's Business Continuity Plan includes procedures relating to an emergency or significant business disruption. These procedures must be reasonably designed to enable FavorPoint Capital to meet its existing obligations to clients.

To obtain a summary of our procedures, please contact us at [email protected].