Privacy Policy

---

A privacy policy statement is given to clients at the initial signing of a client contract and mailed or emailed with client consent once annually, if the policy is updated. The CCO will document the date the privacy policy was delivered to each client for each year if an annual delivery is required. Cedar River Capital, LLC (CRCLLC) collects non-public personal information about clients from the following sources:

➢ Information it receives from them on applications or other forms;

➢ Information about their transactions with CRCLLC or others; and

➢ Information it receives from a consumer reporting agency.

Below are the reasons for which CRCLLC may share a client’s personal information.

➢ For everyday business purposes – such as to process client transactions, maintain client account(s), respond to court orders and legal investigations

➢ For marketing by CRCLLC – to offer CRCLLC’s products and services to clients;

➢ For joint marketing with other financial companies;

➢ For affiliates’ everyday business purposes – information about client transactions and experience; or

➢ For non-affiliates to market to clients (only where allowed).

If a client decides to close his or her account(s) or becomes an inactive customer, CRCLLC will adhere to the privacy policies and practices as described in this Policies and Procedures manual, as updated.

CRCLLC restricts access to clients’ personal and account information to those employees who need to know that information to provide products or services to its clients. CRCLLC maintains physical, electronic, and procedural safeguards to guard clients’ non-public personal information.

The names of CRCLLC’s current access persons are Paul Latta and Baltej Kochar.

In addition to CRCLLC’s listed access persons, any IT persons or other technical consultants employed at the firm may also have access to non-public client information at any time. An on-site or off-site server that stores client information, third-party software that generates statements or performance reports, or third-party client portals designed to store client files all hold the potential for a breach of non-public client information.