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Privacy Policy

 

Privacy Policy

NCM Capital respects and is committed to protecting the privacy of our clients. As part of our strategic investment management process, we gather a large amount of confidential information about our clients and their financial situation. It is our policy not to disclose any nonpublic confidential information about our clients or former clients to unaffiliated third parties; however, in order to facilitate your investment management process, it may be necessary to provide certain specific information to your account custodian(s), accountant(s) or others. These disclosures may include confidential information such as your account name, tax identification number, assets and income. Furthermore, regulatory authorities and law enforcement agencies may periodically review this information in order to determine compliance with securities laws. If you prefer that we not disclose such information to unaffiliated third parties, you may opt out of those disclosures and direct us to contact you in advance each time we feel it is necessary to disclose confidential or financial information to unaffiliated third parties as part of the strategic investment management process.

If NCM Capital, or one of our lines of business, is sold, merged with, or otherwise acquired by a third party, your information may be (i) disclosed, under duty of confidentiality, to a potential purchaser or merger partner as part of the pre-closing due diligence process or (ii) included among the transferred assets.

NCM Capital is committed to protecting your privacy. We restrict access to client information to ensure that your nonpublic information remains secure and confidential. We also maintain physical, electronic and procedural safeguards that comply with federal standards to protect your privacy.

However, no security system is perfect. Therefore, NCM Capital is not responsible if someone manages to circumvent our security measures and gain access to the database, including information pertaining to individual users, nor can we be responsible for any use, reproduction, or disclosure they may make of it.

Privacy issues related to site usage

NCM Capital may collect, analyze, and disclose to others aggregated information (which includes users' specific information but only as an unidentifiable part of the aggregate) gathered from overall use of this web site or particular features or area of this web site. Among other purposes, this information allows us to analyze usage trends so that we can maintain an effective, responsive site.

NCM Capital may revise this Privacy Policy from time to time. Unless stated otherwise, such changes will become effective immediately upon their posting. If you have any questions about this Privacy Policy, please contact Andrea Johnson.