Pazera Capital Management, Inc.
Privacy Notice

In connection with providing financial planning, investment advisory services or other services, Pazera Capital Management, Inc. (“PCM”) (hereafter “We”) collects and retains non-public information (“NPI”) about you, including:

• Information we receive from you on any account applications, advisory agreements or other forms to collect personal data;
• Information about your transactions with us or others, including your registered representative; and
• Other information from service bureaus or other third parties.

We will not disclose information regarding you or your account except under the following circumstances:

1. To your registered representative;
2. To establish or maintain an account with an unaffiliated third party, such as a brokerage firm or custodian providing services to you and to provide a limited amount of information to discuss your financial situation with your accountant or lawyer.
3. To government entities or other third parties as required by law:
4. At your specific request

As this is our practice, we are not required to have “Opt-out” provisions or methods per the exemptive relief provided under section 248.13 of the Graham-Leach-Bliley Act.

Only those PCM employees who need NPI to perform their jobs are authorized to have access to confidential client information. We maintain physical, procedural, and electronic safeguards that comply with applicable state and federal regulations to safeguard confidential client information.

Our policy about collecting and disclosing NPI may change from time to time. We will provide you with notice of any material change to this policy before we implement the change.

If you would like to receive a copy of Pazera Capital Management, Inc.’s current summary disclosure statement, please let us know and we will forward a copy to you.

As always, if you have any questions or comments, please do not hesitate to call

Sincerely Yours,

PAZERA CAPITAL MANAGEMENT, INC.