It is SRO Capital’s policy to protect and safeguard the privacy and security of its existing and prospective clients’ personal information. SRO may collect certain nonpublic information about its clients, from materials provided by its clients or other authorized parties, which is necessary to provide the services SRO has agreed to render.

SRO does not disclose nonpublic personal information it collects about its clients to anyone except: (i) in furtherance of its business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing its compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) its attorneys, accountants, consultants, and auditors; or (iv) as otherwise provided by law.

SRO is permitted by law to disclose the nonpublic personal information about its clients to other third parties in certain circumstances such as third parties that perform administrative or marketing services on its behalf or for joint marketing programs. These third parties are prohibited to use or share the information for any other purpose. If clients decide at some point to either terminate the Firm’s services or become inactive, the Firm will continue to adhere to its privacy policy, as may be amended from time-to-time