M a r i n C a p i t a l M a r k e t s

MARIN CAPITAL MARKETS PRIVACY POLICY

Policy

Marin Capital Markets ("MCM") has the responsibility to protect and safeguard the confidentiality of nonpublic personal information of its customers. It is MCM’s policy not to share any nonpublic personal information regarding current, prospective or former customers to any nonaffiliated third parties, unless necessary to process transactions, provide services or as otherwise permitted by law. These policies and procedures apply to all MCM employees concerning their handling of information regarding customers who obtain financial products or services from MCM primarily for personal, family or household purposes.

Using and Safeguarding Personal Information

It is MCM’s policy to safeguard any Personal Information provided to it by its customers. Personal Information will only be disclosed to employees and affiliates on a "need-to-know" basis in order for them to process transactions, service customers or otherwise carry out business. All employees are required to use their best efforts to maintain and protect the confidentiality of Personal Information. Under no circumstances shall employees use Personal Information for their own personal use or otherwise outside of their employment with MCM. Access to all electronic databases or documents containing Personal Information is provided only to those employees who require access to perform their job functions. All such electronic databases or documents are safeguarded by password protection and passwords are changed periodically. Furthermore, computers with access to Personal Information shall not be left unattended, unless they are password protected through logon screens, screen savers, etc. Any Personal Information not otherwise maintained electronically will be maintained in a locked file cabinet. Personal Information regarding customers that is being discarded, such as printouts of lists or account information must be destroyed in a manner that ensures that the information cannot be retrieved. Every employee handling Personal Information is required to maintain the confidentiality of such information and take all necessary precautions to protect Personal Information from any unauthorized use or potential loss.

Sharing Client Information with Third Parties

Under no circumstances, unless prior authorization is provided by the Compliance Officer, shall Personal Information regarding MCM’s customers including their names, be disclosed to nonaffiliated third parties other than as further described herein. Personal Information may be provided to non-affiliated third party financial institutions, such as broker-dealers and administrators, or other third party entities, as necessary, to process transactions, service customers or as otherwise permitted by law. In addition, Personal Information may be shared with nonaffiliated third parties, if such third party entity is under contract to perform certain services on behalf of MCM or as instructed by the customer. Any such contract entered into by MCM will include provisions designed to ensure that the third party will uphold and maintain privacy standards when handling Personal Information. MCM may also disclose Personal Information to regulatory authorities or as otherwise required or permitted by applicable law. The Compliance Officer must be immediately informed of any request for Personal Information from anyone outside of MCM, other than as described above. The Compliance Officer also must be consulted before responding to subpoenas, court orders, regulatory inquiries or other similar requests for information.

Accuracy of Personal Information

We strive to keep our customer files complete and accurate. We encourage you to review any correspondence from MCM and notify us if you believe any information is inaccurate and should be corrected or updated. If you have questions or concerns about your personal information or this privacy notice, please contact MCM at 415-924-1600 or via e-mail. MCM will take reasonable steps to ensure it is corrected in a timely manner.