Unless required by law, Orca Capital Securities, LLC will not disclose any non-public personal information about our clients or former clients to any person or entity not directly affiliated with our firm. However, non-public information that we collect about you may be disclosed to our affiliates and employees who need to know such information and to certain service providers (including accountants, auditors and attorneys) in connection with the administration and execution of the services we will provide for you. Also, authorized under the terms of our engagement agreement, we may disclose non-public information about you to potential investors as part of our services.

We may share some public information such as names and addresses to non-affiliated entities to enable them to provide business services on our behalf. These services could include assisting us in copying documents, mailing sales literature, processing a transaction, and performing general administrative activities for us. These types of services sometimes are necessary in order for us to conduct business. Any and all service providers that we do business with are contractually obligated to ensure that none of our client information will be disclosed, except as required by law.

To ensure that all non-public information is treated in a confidential manner, we have adopted a code of ethics and internal policies and controls which require our employees to protect the confidentiality of our clients’ information. We also have physical, electronic, and procedural safeguards to protect all non-public information.