Privacy Statement

PRIVACY POLICY

Black Point Capital Management takes seriously the confidentiality and security of the personal and financial information of its clients, BPCM’s Privacy Policy is reviewed on a regular basis to ensure that it is current and reflects the concerns of our constituents.

This Privacy Policy will be distributed annually and is available upon request.

OUR POLICY

Information We Collect

BPCM collects and maintains personal information essential to properly service your account(s) and fulfill its legal obligations. Additionally, in the course of doing business, we may gather non-essential personal information that would nonetheless fall under our Privacy Policy.

Information is collected in various ways, including:

·       Personal and financial information that you or your representatives (such as Fiduciaries, Tax, Legal, or other advisors) provide,

·       Holdings and transactional activity in your account(s),

·       Additional information that you provide to us, either verbally or in writing,

·       Other information from third parties with the consent of you or your representatives.

How We Utilize Information

Information that we collect is used primarily for the purpose of servicing and managing your account(s).

Information may be provided to companies that help us process or service your account and/or transactions, including custodial banks and brokers. Additionally, information may be provided to certain government or regulatory agencies to fulfill our legal obligations, including providing tax-related information to federal and/or state agencies and providing certain information to organizations empowered to protect national security and eliminate fraud.

In all of the above situations, BPCM will make a good faith effort to determine that only necessary information is provided, and that all information provided is covered by the privacy policy of that company or organization, and that its policy meets or exceeds BPCM’s own privacy policy.

In addition, information may be provided to outside individuals and organizations with your consent.

Other than as indicated above, no personal information about any client will be made public or distributed to any third party.

Who will have access to your Personal Information?

At BPCM, all employees, and any subcontracted employees, will have access to your personal information. Additionally, the Board of Directors will know that you are a client and the size of your account.

Unless you specifically allow it in the client agreement, BPCM will assume that the fact that you are a client of BPCM is confidential, known only to BPCM employees, subcontracted employees, and Board Members.

All BPCM employees, subcontracted employees, and Board Members are expressly prohibited from discussing any client information not specifically allowed by the Client with anyone other than each other.

How We Protect Information

Paper records are confined to the BPCM office or, as necessary, transported for the sole purpose of reviewing the information with the Client.

Electronic records are stored at an offsite server, and are only accessible via a password known only to BPCM employees and the Chairman of the BPCM Board. Additionally, backups of electronic records are kept at the BPCM offices, and are only accessible via a password known only to BPCM employees and the Chairman of the BPCM board.

When asked about the personal information of a public BPCM client, or whether a person is a BPCM Client, BPCM’s policy is to neither confirm nor deny the information.

An employee education program, whereby all BPCM employees are required to understand the Policy and their role in ensuring that it and related internal procedures are properly understood, enhances the effectiveness of BPCM’s Privacy Policy.

Internal control procedures are reviewed periodically and updated to incorporate changes in technology and the external environment.  In addition, BPCM’s senior management monitors employee adherence to the Policy.

Should you ever decide to cease being a client of BPCM, we will continue to adhere to this privacy policy.

If you have any concerns about the privacy or security of your personal information, please feel free to contact us at any time. We welcome the input of our clients on all issues related to this Policy and will gladly consider your suggestions for both its policies and related procedures.

Black Point Capital Management

1 Canal Plaza, Suite 801

Portland Maine 04101

207-358-7585

www.blackpointcapitalmanagement.com