December 31, 2021

volScout LLC is a privately-owned limited liability company located in Westport, CT. volScout is a registered investment advisor with the SEC. volScout is committed to protecting the privacy of personally identifiable information (“PII”) of identifiable individuals who visit www.volScout.com (the “Site”) and inquire about or use services associated with our business available through our Site (the “Service/s”), or express interest in our business. This Privacy Policy discloses the privacy practices for volScout and for its Site, and localized versions of that site, including the type of PII collected and tracked, how the information is used, and with whom the information is shared.

In order to provide you with Services you may request, it is necessary for us to possess some PII of yours. Similarly, without some of that information, we cannot inform you about the Services we have available or that you may request (though if you are currently receiving marketing communications from us, you may opt-out of receiving further communications at any time). This Privacy Policy explains our PII policies and practices. It includes, but is not limited to, explanations of the types of PII we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your PII, and the way to contact us to exercise those rights.

Amendments to this Privacy Policy and/or the Services will be posted to the Site and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendments.

Information We Collect from You

This section explains the PII that may be collected when using our Services, and the other information we may receive from other sources. In this Privacy Policy, the term “PII” refers to the types of information we may collect and use. Some examples are listed below:

• Contact details, such as your name, address, social security number and date of birth;
• Payment and financial information such as your income, assets, investment preferences, etc.;
• Comments, feedback and communication preferences (whether that is electronic, telephone, written or in person)
• Usernames, passwords, and account information such as purchases, sales, account balances, inquiries, etc.; and
• Information to process transactions or to conduct online transactions; or

Information from Third Parties

If needed, we may obtain information from third parties to evaluate your application or verify your identity, including personal and credit information from consumer reporting agencies, or information from other companies about contracts or accounts transferred to us. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, to promote protection of your identity, we also may collect credit or identity information which we use to help prevent and detect fraud.

Restricted Use Regarding Minors

This Site is not intended or designed to be used by children under the age of 13. We do not collect PII from any person we know to be under the age of 13 and instruct children under 13 not to send us any information.

Purposes for Collecting Your PII

You may provide your PII to volScout in order to fulfill a Service. You are then entering a business relationship with volScout and are agreeing to the use of that data by volScout and its applicable worldwide affiliated companies, as stated in this Privacy policy. We request PII for a variety of purposes throughout your interaction with volScout, some of which are listed below:

• Contacting you or your designated representative by phone, email, fax, or mail;
• Providing you or your representative with marketing communications;
• Creating and managing your account with us;
• Sharing information about our Services including investment research;
• Facilitating financial transactions related to your account;
• Fulfilling our legal and regulatory obligations;
• The performance of obligations under any applicable agreements;
• The administrative processes (and related communications) carried out by volScout in preparing its services;
• Ongoing communication with you and/or your designated contacts;
• The ongoing administrative, reporting and other processes and communications required to operate the business in accordance with our client agreements and other related documentation
• Any legal or regulatory requirement to which volScout is subject; or
• Any other purpose of which you have been notified, or has been agreed, in writing.

Lawful Basis

There is a need to process PII for the purposes set out in this privacy policy as a matter of contractual necessity under or in connection with your agreement(s) with us, and in the legitimate interests of volScout to operate its businesses. From time to time, volScout may need to process the PII on other legal bases, including: (1) to comply with a legal obligation; (2) if necessary to protect the vital interests of a client or other data subjects; or (3) if necessary for a task carried out in the public interest. For the purposes listed above, volScout is relying on performance of a contract necessity and legitimate interests.

A failure to provide the PII requested to fulfill the purposes described in this Privacy policy may result in volScout being unable to provide the services in connection with the terms of your agreement(s) with us.

Data Storage and Retention

Your PII will be retained only for as long as the information is needed to fulfill the purposes for which it was collected and processed. We reserve the right to retain and use your PII for as long as necessary to comply with our legal obligations and business requirements and/or to resolve ongoing disputes and enforce our agreements.

Sharing Your PII – What Information We Disclose

We do not disclose your nonpublic personal information except: (i) in furtherance of our business relationship with certain providers necessary to affect transactions and services (broker-dealers, custodians, money managers, etc.); (ii) regulatory bodies; (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. If you either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time.

Opting Out of Third-Party Disclosures

If you prefer that volScout not disclose the nonpublic personal information about you to non-affiliated third parties, you may opt of such disclosures – that is, you may direct us to not make those disclosures, other than those permitted by law. If you wish to so opt out, you may contact our Compliance Department at (888) VOLSCOUT, or send a written request to the firm address below.

Safeguarding of Your Information

We maintain physical, electronic, and procedural security measures that comply with applicable legal and regulatory standards to safeguard your PII. We restrict access to your nonpublic personal information to those employees servicing your account. We train our employees to keep your information safe and confidential. We follow generally accepted standards to protect the PII you submit to us, whether that information is in transit or at rest. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

The following applies only to residents of the State of California:

PII Rights for California Residents

The California Consumer Privacy Act (“CCPA”) requires us to make certain additional disclosures and provides California residents with the ability to request additional information about their PII. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what volScout will do in response.

Please note that the rights under the CCPA do not apply to PII collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).

If you are an individual who resides in California and whose PII is collected and processed by volScout, you may have the right to:

• Request that we disclose, free of charge, the categories and specifics of the PII we collect about California residents, the sources from which the PII was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting PII.
• Choose to opt-out of the sale of PII. Currently, however, volScout does not sell PII.
• Request that we delete the PII we have collected. Following our verification of the request, we will comply with the request and delete any or all the PII in our possession that we collected from the California resident and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.

Non-Discrimination for Exercising Your PII Rights

We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this privacy policy.

Verifying Your Identity

If you choose to contact us with a request, you will need to provide us with identifying information that matches the PII we currently have about you. For example, we may require identifying documents such as a copy of your drivers license, state identification card, passport or similar documentation.

Authorized Agent

You have the right to appoint an authorized agent to exercise your rights on your behalf.

Accessibility Information

For consumers with disabilities who need to access this policy in an alternative format, please contact: info@volScout.com or (888) VOLSCOUT.