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PRIVACY NOTICE REGARDING CLIENT PRIVACY

Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Applied Capital Management, Inc. (“we”, “us” or “our”).

Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, which may include:

  • Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;
  • Information about your transactions with us, our affiliates, or others; and
  • Information received from credit or service bureaus or other third parties, such as your credit history or employment status.

Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account with us, except to the parties listed below and under the following circumstances, as referenced below:

  • To the broker-dealer with which our advisory representatives are affiliated, SagePoint Financial, Inc., its parent companies or affiliates, to the extent permitted by law;
  • To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company;
  • To consumer reporting agencies;
  • To third parties who perform services or marketing on our behalf;
  • To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
  • To our attorneys, accountants or auditors; and
  • To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries.
  • We do not sell customer lists or customer information to third parties.

How We Use Information: Information may be used among the affiliate companies that perform support services for us, such as data processors, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, such as:

  • To protect your accounts from unauthorized access or identity theft;
  • To process your requests such as securities purchases and sales;
  • To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or Applied Capital Management, Inc.;
  • To service your accounts, such as by issuing checks and account statements;
  • To comply with Federal, State, and Self-Regulatory Organization requirements; and
  • To keep you informed about financial services of interest to you.

Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain procedural security measures to safeguard confidential client information.

Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to you.

Complaint Notification: Please direct complaints to: Applied Capital Management, Inc., 50 Nashua Rd, Suite 200, PO Box 1437, Londonderry, NH 03053

Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.

If you reside part-time or full-time in a state that requires your affirmative consent before we provide your non-public personal information to certain third-parties, we will obtain such consent as required.