Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this “Privacy Policy Notice” carefully to understand what we do.

Pacific Way Capital Management LLC (the “Firm”) does not disclose nonpublic personal information about its prospective, existing or former clients to third parties other than as described below.

This notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws.

Personal information we collect. The Firm collects personal information about you in connection with providing advisory services to you. This information includes your social security number and may include other information such as your:

• Assets;
• Investment experience;
• Transaction history;
• Income; and
• Wire transfer instructions.

How the Firm collects this information. The Firm collects this information from you through various means. For example, when you give the Firm your contact information, enter into an investment advisory contract with the Firm, buy securities (i.e., interests in a fund) from the Firm, tell the Firm where to send money, or make a wire transfer. The Firm also may collect your personal information from other sources. The Firm maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information which the Firm believes are adequate to prevent unauthorized disclosure of such information.

How the Firm uses this information. All financial companies need to share customers’ personal information to run their everyday business and the Firm uses the personal information collected from you for everyday business purposes. These purposes may include for example:

• To provide advisory services to you.
• To open an account for you.
• To process a transaction for your account.
• To market products and services to you.
• To respond to court orders and legal investigations.

Disclosure to others. The Firm may provide your personal information to firms that assist the Firm in servicing your account and have a need for such information, such as a broker or fund administrator. The Firm may also disclose such information to service providers and financial institutions with whom the Firm has joint marketing arrangements (i.e., a formal agreement between financial companies that together market financial products or services to you, such as placement agents). The Firm requires third-party service providers and financial institutions with which the Firm has joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which the Firm discloses the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. The Firm notes that the Federal privacy laws only give you the right to limit the certain types of information sharing that the Firm does not engage in (e.g., sharing any personal information with others in order for them to market to you).

How the Firm protects your personal information. To protect your personal information from unauthorized access and use, the Firm maintains physical, electronic, and procedural safeguards that comply with Federal law to safeguard nonpublic personal information which the Firm believes are adequate to prevent unauthorized disclosure of such information. These measures include computer safeguards and secured files and buildings.

Clients have the right to opt out of the registrant sharing their nonpublic personal information with nonaffiliated third parties.

Who to contact with questions or to Opt Out. If you have any questions about this Privacy Notice or to Opt out, please contact Peter Vasiliadis CCO by email at Peter.Vasiliadis@pacificwaycapital.com.