Privacy Policy

This Privacy Policy is presented to you in conformity with Regulation S-P, 17 CFR 248.1-248.3, under section 504 of
the Gramm-Leach-Bliley Act. If you would like to receive this notice via regular mail instead, please reply to this e-
mail and a copy will be provided to you.  In the absence of a reply, the recipient affirmatively consents to receipt of
this notice electronically.

Information We Collect

We collect information using documentary and non-documentary methods including inquiries to consumer reporting agencies and data mining on publicly available websites to verify your identity in the account-opening process. The information we collect includes, but is not limited to, your legal name, legal address, telephone number, email address, Tax Identification or Social Security number or other national identification numbers and date of birth (individual accounts only), copies of identification documents as well as details about your investment interests, investment holdings, investment objectives and investment experience.

Once an account is open with us, we collect and maintain information about your account activity, including your
transactions, balances, positions and history. This information allows us to administer your account and continue to provide the services requested.

We may collect information from information services and consumer reporting agencies to verify your identity,
employment, or creditworthiness, or to better understand your financial needs.

Sharing of Nonpublic Information / “Opt-out” Provision

SGS does not disclose non-public information relating to current or former customers with any unaffiliated third
parties, except as required or permitted by law. This may include sharing your information with non-affiliated companies that perform support services for your account or process your transactions with us. We may disclose information to regulatory authorities and law enforcement officials who have jurisdiction over us or if we are required to do so by applicable law, rule, or regulation and to provide information to protect against fraud.

SGS may share your non-public personal information with its affiliates. However, you can contact us at any time to
limit our sharing by calling the Compliance Department at 212-616-7700 or emailing Compliance@seaportglobal.com.

Information Security

SGS protects your nonpublic information from access by third parties by maintaining physical, electronic and procedural safeguards. Independent parties we use to provide support services are not authorized to use information about our clients for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of information to the performance of the specific services for which they are contracted and limit informational access to those employees who are trained in the proper handling of nonpublic client information and who need access in the performance of their responsibilities.

Data Breach Response Plan

SGS maintains a robust Cybersecurity Plan which provides a framework for protecting the technology and information assets of the Firm. Upon discovery of an incident of unauthorized access to or use of customer information that could result in substantial harm or inconvenience to any customer, the Firm will notify each affected customer whose sensitive information was, or is reasonably likely to have been, accessed or used without authorization within 72 hrs after becoming aware that such a breach has occurred. SGS will “become aware” once it has a “reasonable degree of certainty” that a personal data breach has occurred.

California Consumer Privacy Act (CCPA)

Under the CCPA, California residents have the following rights and may make requests in accordance with the below:

(1) The right to know what personal information is being collected
(2) The right to know whether their personal information is sold or disclosed and to whom
(3) The right to opt-out of the sale of personal information
(4) The right to access their personal information
(5) The right to equal service and price, even if privacy rights are exercised

Please reference the “Information We Collect” and “Sharing of Nonpublic Information/Opt-out Provision” Sections above for details on the categories of information collected, the Firm’s purpose and usage of the collected data.

SGS does not engage in the activity of selling personal information as defined under the CCPA and does not share client personal information with third parties for their own direct marketing purposes.

If you are a California resident and would like more information on the CCPA or to assert any of your rights in accordance with the CCPA, please contact SGS Compliance at Compliance@seaportglobal.com or your SGS representative.

Nevada Privacy Law information for Nevada Residents

Under the Nevada privacy law, residents have the right to opt out of the sale of their personal information collected online. The law also empowers consumers to know what information is collected, means of collection and its intended use.  SGS does not engage in the activity of selling personal information and does not share personal information with third parties for their own direct marketing purpose but may share your nonpublic information with its affiliates. Please refer to the “Information We Collect” and “Sharing of Nonpublic Information / “Opt-out” Provision” sections of this policy for details on what information is collected and how it is used by the firm.

Additional Information

For more information pertaining to our clearing agent’s privacy policy, please reference Pershing LLC and Mirae Privacy Policy.

The privacy policy for Seaport Research Partners LLC can be downloaded here.