PRIVACY POLICY

Scala Capital LLC ("Scala") believes it is essential that we maintain the privacy of the nonpublic personal information that you provide to us and that we obtain in connection with providing our products and services to you.

Scala limits the use, collection, and retention of such information to what we believe is necessary or useful to conduct our business and to provide and offer you quality products and services, as well as other opportunities that may be of interest to you. Information collected may include, but is not limited to name, address, and telephone number, tax identification number, date of birth, employment status, annual income, and net worth.

In providing products and services to you, we collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms (e.g. investment/insurance applications, new account forms, and other forms and agreements);

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

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

  Scala places strict limits on who receives specific information about your account(s) and other personally identifiable data. As a rule, we do not disclose nonpublic personal information we collect to others. However, because we rely on certain third parties for services that enable us to provide our advisory services to you, such as our attorneys, auditors, other consultants, brokers, and custodians who, in the ordinary course of providing their services to us, may require access to information, we may share non-public personal information with such third parties. Additionally, we will share such information where required by legal or judicial process, such as a court order, or otherwise to the extent permitted under the federal privacy laws.

  We restrict access to nonpublic personal information about you to those persons associated with Scala, who need access to such information in order to provide our products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

  If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

  Scala reserves the right to change these Privacy Principles, and any of the policies or procedures described above, at any time without prior notice. However, you will be promptly provided with a current copy of our privacy notice upon material changes or upon request. So long as you remain an active customer, you will receive a current copy of our privacy notice at least annually. These Privacy Principles are for general guidance and do not constitute a contract or create legal rights, and do not modify or amend any agreements we have with you.

  If you have questions about this privacy policy, or if you wish to amend or rescind your written instructions below at any time, please call Alberto Siblesz at 305-539-3850 or via e-mail at emailus@scala-capital.com.