Legal Disclaimer

Lenora Capital LLC (“Lenora Capital”) is providing this notice both for itself and on behalf of its affiliates and subsidiaries, including Brighton Jones, LLC Lenora Capital maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, Lenora Capital attempts to secure the confidentiality of customer records and information, and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of Lenora Capital to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of Lenora Capital.

In that regard, Lenora Capital may disclose the client’s information: (1) to individuals and/or entities not affiliated with Lenora Capital, including, but not limited to the client’s other professional advisors and/or certain service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

The disclosure of information contained in any document completed by the client for processing and/or transmittal by Lenora Capital to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Lenora Capital and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client’s engagement with Lenora Capital, shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third-party service provider.

Brighton Jones permits only authorized employees and affiliates to have access to client information. Employees violating Lenora Capital’s Privacy Policy will be subject to a disciplinary process. Additionally, whenever Lenora Capital hires other organizations to provide services to its clients, Lenora Capital will require them to sign confidentiality agreements and/or the Privacy Policy.