Privacy PolicyGreat Point Capital & Great Point Advisors, LLC

Privacy Policy

BUSINESS CONTINUITY PLAN

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our Business Continuity Plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter- party impact; regulatory reporting; and assuring our customers’ prompt access to their funds and securities if we are unable to continue our business.

While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 2 days. Your orders and requests for funds and securities could be delayed during this period.

VARYING DISRUPTIONS

Significant business disruptions can vary in their scope affecting only our firm, the building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site or sites when needed and expect to recover and resume business within 2 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to sites outside of the affected area and recover and resume business within 2 days. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at 312-356-4400.

COMMITMENT TO YOUR PRIVATE INFORMATION

Great Point has always worked hard to maintain the highest standards of confidentiality and to respect the privacy of our individual client relationships. In that regard, we are providing this Privacy Notice to all of our individual clients who obtain financial products and services from us for personal, family, or household purposes, in accordance with Title V of the Gramm – LeachBliley Act of 1999 and its implementing regulations.

Great Point is committed to safeguarding the confidential information of its clients. Great Point holds all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients.

WHY WE COLLECT AND HOW WE USE YOUR INFORMATION

The non-public personal information Great Point may collect about you (your “Information”) comes primarily from sources such as:

• Information reported by the client on applications or other forms the client provides to the firm
• Information about the client’s transactions implemented by the firm or others
• Information developed as part of financial plans, analyses, or investment advisory services

To administer, manage, service, and provide related services for client accounts, it is necessary for Great Point to provide access to client Information within the firm and to non-affiliated companies, with whom we have entered into agreements. The disclosure of Information contained in any document completed by the client for processing and/or transmittal by Great Point to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Great Point and a non-affiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, recordkeeper, insurance company, etc.), including, but not limited to, Information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of Great Point (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated thirdparty service provider.

INFORMATION SECURITY POLICIES AND PRACTICES

We limit access to your Information to those of our employees and service providers who are involved in offering or administering the products or services that we offer. As required by federal law, we will send you notice of our privacy policy annually, as long as you have an account with us. We will not revise our privacy policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.

If our relationship ends, we will continue to treat the Information as described in this Privacy Notice.