Disclosure

The information contained herein reflects, as of the date hereof, the views of Orion Capital Management LLC (Orion) and sources Orion believes to be reliable. No representation or warranty is made concerning the accuracy of any data compiled herein. In addition, there can be no guarantee that any projection, forecast or opinion in these materials will be realized. Past performance is neither indicative of, nor a guarantee of, future results. The views expressed herein may change at any time subsequent to the date of issue hereof. These materials are provided for informational purposes only, and under no circumstances may any information contained herein be construed as investment advice. Orion does not provide tax, legal or accounting advice. The information contained herein does not take into account your particular investment objectives, financial situation, or needs, and you should, in considering this material, discuss your individual circumstances with professionals in those areas before making any decisions. Any information contained herein may not be construed as any sales or marketing materials in respect of, or an offer or solicitation for the purchase or sale of, any financial instrument, product or service sponsored or provided by Orion or an agent thereof. References to specific securities are presented solely in the context of industry analysis and are not to be considered Orion recommendations. Orion may have positions in, and may affect transactions in, the markets, industry sectors and companies described herein.

Privacy Policy

Orion Capital Management LLC considers the privacy of its clients to be of fundamental importance and has established procedures to maintain the confidentiality of client information. In providing investment management services to you, we collect certain nonpublic information about you. Our policy is to keep this information confidential, and to use or to disclose it only as needed to provide services to you or as required by law.  Our privacy policy applies to anyone, or any entity, who is or has ever been a client of Orion.

Information we collect

The personal information we collect includes that required to communicate with you and to assist us in effectively managing your investments. It may include:

• Your name and address
• Your email address and phone number(s)
• Investment objectives and experience
• Income and tax history
• Financial circumstances and history
• Account balance and account transactions
• Social security number and/or Employment Identification Number
• Employment information and income

How we collect information

In delivering our investment services to you, we may collect your information from:

• Applications and other forms and statements you submit to us, either in writing, in person or electronically
• Tax or other financial records that you provide to us
• Firms such as custodians, broker/dealers, accountants, legal entities and other companies
• Other professionals who provide services to you, such as attorneys, accountants and fiduciaries, if you have authorized those parties to communicate with us

How information is used

For the sole purpose of providing our services to you, we may share some client information with third-party companies including custodians and companies that provide data management and software services to us. We may also, if directed by a client, provide client information to accounting and/or legal firms. We do not otherwise provide any client data to anyone for any purpose.

We may disclose client information to third-parties as permitted by law such as:

• Broker/dealers, custodians or other companies used to provide our services to you
• Accounting or law firms or other third-party representatives as directed by you
• Regulatory authorities

We only disclose non-public client information to non-affiliated third-parties without prior client consent when we believe it is necessary for the conduct of our business or as required by law, such as:

• If you request or authorize the disclosure of the information
• To provide client account services or account maintenance
• To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities
• To perform services for the firm or on its behalf to develop or maintain proprietary trading or other software
• In connection with a proposed or actual sale, merger, or transfer of all or a portion of our business or an operating unit
• To help prevent fraud
• Persons assessing our compliance with industry standards
• Attorneys, accountants and auditors of Orion
• To comply with federal, state or local laws, rules and other applicable legal requirements
• Pursuant to any other exceptions enumerated in the California Information Privacy Act

How information is safeguarded

We have procedures in place that we believe are reasonably designed to protect the security and confidentiality of your information. These include confidentiality agreements with companies we hire to help us provide services to you, password-protected user access to our software services, and strict confidentiality policies that apply to all employees.

Opt-Out Provision

If it is ever necessary to disclose any client personal information in a manner that is inconsistent with our privacy policy, Orion Capital Management LLC will give its clients advance notice of the proposed disclosure. Clients will have the opportunity to either opt-in or opt-out of such disclosure, as required by applicable law.

Clients are advised that Orion believes that sharing client private information under the circumstances noted above is either mandated by law or necessary for the Firm to conduct its business and to best service clients. Clients desiring to opt out of any third-party disclosures should contact us.

Other Information

We reserve the right to change our privacy policy at any time as needed and clients will be notified if any changes occur.

Firm Contact

Peter C. Thoms, CFA

Managing Member

Orion Capital Management LLC

Email : thoms@orioncapitalmgmt.com

Tel: 619-435-1701