Privacy Statement of ZUNA LLC

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Please read this notice carefully to understand what we do with your personal information and/or the plan’s information, including participant information.

ZUNA, LLC (“ZUNA”) is an SEC registered investment advisory firm, committed to safeguarding the confidential information of its clients. If required for the services we perform, we may collect nonpublic personal information in order to open and administer your accounts with us and to provide you with accurate and pertinent advice. We hold all nonpublic personal information you provide to us in the strictest confidence. If we were to change our firm policy, we would be prohibited under the law from doing so without advising you first.

INFORMATION COLLECTED

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number and employment information

  • Account balances and transaction history

  • Financial goals and investment experience

When you are no longer our customer, we continue to share your information as described in this notice.

METHOD OF COLLECTION

ZUNA collects information about you and/or the plan from the following sources:

  • Applications or other forms

  • Information about your transactions with us or others, including the plan’s recordkeeper or third party administrator

  • The website of the plan’s recordkeeper, third party administrator or other third party service provider

USE OF PERSONAL INFORMATION

ZUNA uses your information and/or the plan’s information in the following manner:

  • We do not sell your personal information to anyone.

  • We limit employee access to information only to those who have a business reason for knowing; for parties that are not affiliated with ZUNA, we limit access to that which is permitted and required by law. For example, federal regulations permit us to share a limited amount of information about you and/or the plan with a brokerage firm in order to execute securities transactions on your behalf.

  • We do not make disclosures (other than disclosures required by law) regarding nonpublic personal information to unaffiliated third parties, unless such disclosures are necessary for the services.

  • For unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors, we also require strict confidentiality in our agreements with them and expect them to keep this information private. We have policies and procedures in place to review the privacy procedures of unaffiliated third parties. Federal and state regulators also may review firm records as permitted under law.

  • We will provide notice of changes in our information sharing practices. If, at any time in the future, it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so you will have the opportunity to opt out of such disclosure.

  • We maintain your information in a secure environment to ensure that your information is not placed at unreasonable risk.

  • For so long as such disclosure remains to be true and accurate and provided such disclosure is agreed to by you and ZUNA in writing, ZUNA may disclose your name and status as a client in ZUNA’s marketing or other promotional materials. However, we do not otherwise sell or provide your personally identifiable information to mailing list vendors or solicitors for those purposes.

  • Personally identifiable information about you will be maintained during the time you are a client, and for the required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.

COMPLIANCE WITH STATE LAWS

You may have privacy protections under applicable state laws, including those for California residents. To the extent the state laws apply, we will comply with them when we share information about you or the plan, and in some case may be limited by you or your employees.

CALIFORNIA RESIDENTS

The California Information Privacy Act provides additional protections to control whether we share some of your personal information or that of the plan’s participants. In accordance with California law, we will not share information we collect about California residents with outside companies, except as permitted by law, such as with the consent of the individual or to service the plan.