PRIVACY POLICY

We appreciate the importance of maintaining the confidentiality of information that you have shared with us. We take seriously the responsibility of safeguarding your privacy while we assist you in achieving your financial objectives. In this Privacy Notice, the terms "we," "our" and "us" refer to Kipling Capital, Inc., a broker-dealer registered with FINRA (formerly the National Association of Securities Dealers, Inc.), our registered principals, and our registered representatives, whether such individuals are engaged directly by us as employees or as independent contractors. The terms "you" and "your" in this Privacy Notice refer broadly to all of our individual clients (including prospective and former individual clients).

This Privacy Notice is being delivered to you now in order to satisfy the federal law that requires broker-dealers to inform their clients of the broker-dealer's policies regarding the privacy of client information. The purpose of this Privacy Notice is to describe the types of non-public information we collect about you, explain to you what we will do with this information, and explain the ways that we protect your privacy.

If we change our information practices, we will provide you notice of any material changes. If you become an inactive client, we will continue to adhere to the privacy policies and practices as described in this notice. This Privacy Notice supersedes all previous notices or statements with respect to subject matters described in this Privacy Notice.

If you are comfortable with our handling of information we collect, you do not need to take any action at this time. Please read this Privacy Notice and keep it for your records.

Types of Non-Public Personal Information that We Collect

To help the Government fight the funding of terrorism and money-laundering activities, Federal Law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

When you indicate an interest in investing through Kipling Capital, we will ask for your name, address, date of birth, social security number or employer identification and other information that will allow us to identify you. We will also ask to see your driver's license, passport or other identifying documents that contain your photograph.

In the conduct of our business, we may also collect and maintain:

• Your name, address, telephone/fax numbers and electronic addresses
• Social Security numbers
• Information regarding your status as an accredited investor, such as your assets, liabilities, employment, income and expenses that you may provide to us in a certification of your status as an accredited investor.
• Investment activity information such as the specific investment opportunities or transactions that you have chosen to participate in; and
• Information regarding your financial situation which permits us to assess your investment objectives.

How We Use Your Personal Information

We use your non-public personal information only for legitimate business purposes that are consistent with broker-dealer practices and are in compliance with applicable laws and regulations including:

• To select and close on transactions in which you have chosen to invest. For example, we use information that you provide to us regarding your interest in a particular offering in order to gauge whether sufficient interest exists to fund a particular investment opportunity.
• To comply with applicable laws and regulations. For example, we use information gathered in your accredited investor questionnaire to insure that we are offering our investment opportunities consistent with the requirements of federal and state securities laws and regulations and the rules and requirements of the Financial Industry Regulatory Authority.
• To help us inform you of investment opportunities. For example, we use information about your prior investments to assist us in determining subsequent offerings in which you may be interested.

Information We Disclose to Third Parties

In order to conduct our business on your behalf, we are sometimes required to disclose your personal information to companies or entities that are not affiliated with us. On those occasions when it is necessary for us to share your personal information with non-affiliated companies, we do not disclose this information to these companies except as permitted by law.

While we never sell your personal information, it is often necessary for us to provide your personal information to third parties to provide you with better service or to third parties that we have engaged to assist us in closing a particular transaction. It is also sometimes necessary to share information related to a specific transaction with third parties who are only involved with that transaction.

We will not share your non-public personal information with third parties to be used for promotion or marketing purposes.

Protecting Your Information

We restrict access to non-public personal information about you to those representatives and employees who need to know this information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

Business Continuity Plan

In accordance with federal requirements, Kipling Capital maintains a Business Continuity Plan that describes what steps will be taken to ensure the continuity of our business operation in the event of an unanticipated disaster. The plan has been designed with procedures to ensure that client documentation will be accessible and that contact between Kipling and its clients will be sustained. If you would like a copy, please contact our office.

Questions or Concerns

If you have any other questions or concerns regarding our privacy policies or regarding any matters set forth in this Privacy Notice, please feel free to contact Sandy Williams at (415) 339-4083 or