Privacy Notice

Column Capital Advisors LLC (“Column Capital”, “firm”, “we”, or “our”), as a Registered Investment Adviser, is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P”).

This “Privacy Notice” describes how we collect, store, use, disclose and protect your personal information that may directly, or indirectly, identify you during and after your working relationship with us and/or through our “Website.” We use the term “Personal Information” to describe information that can be associated with you and can be used to identify you. Personal Information does not include information that does not identify a specific person or that is publicly available. In particular, this Privacy Notice describes the basis upon which and for what purposes we process your Personal Information, how we share your Personal information and how we protect and safeguard your Personal Information.

 The staff of Column Capital realizes that providing Personal Information is an act of trust. Column Capital values its clients’ trust and confidence. We will never sell or share the nonpublic personal information obtained from or in reference to clients. Additionally, we will not sell or share your Personal Information for marketing purposes. All information provided by clients to Column Capital and its staff, and information and advice furnished to clients by us, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the firm via an unaffiliated financial services provider, or as required by any rule, regulation or law.

Commitment to Your Private Information. Column Capital is committed to safeguarding the confidential information of its clients. Column Capital holds all Personal Information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients. Except as permitted or required by law, Column Capital does not share confidential information about clients with nonaffiliated parties. It is our policy 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 Column Capital. Column Capital permits only authorized employees and affiliates who have acknowledged receipt and understanding of our Privacy Policy (by acknowledging and accepting our firm’s Compliance Policies and Procedures) to have access to client information. Employees violating Column Capital’s Privacy Policy will be subject to our disciplinary process. If there are any changes to this policy, we will provide clients with written notice and clients will be provided an opportunity to direct Column Capital as to whether such changes are permissible.

Why We Collect and How We Use Personal Information. To conduct regular business, Column Capital may collect Personal Information from sources such as:

• Information reported by the client on applications or other forms the client provides to the firm
• Information about the client’s transactions implemented by the firm or others
• Information developed as part of financial plans, analyses, or investment advisory services

To administer, manage, service, and provide related services for client accounts, it is necessary for Column Capital to provide access to client information within the firm and to nonaffiliated companies, with whom we have entered into agreements.

The disclosure of Personal Information contained in any document completed by the client for processing and/or transmittal by Column Capital to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Column 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 of Column Capital (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third-party service provider.

Sharing Information with Other Companies Permitted Under Law. Column Capital may disclose the client's information: (1) to individuals and/or entities not affiliated with Column 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, proxy management service provider, etc.) that may be recommended or engaged by Column Capital in furtherance of the client's engagement of Column Capital ; (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. Since Column Capital shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s customers or former customers to anyone, except as permitted by law. In the event that the firm has a change to its client privacy policy that would allow it to disclose non-public information not covered under applicable law, the firm will allow its clients the opportunity to opt out of such disclosure. Finally, Column Capital strives to only recommend financial services providers that share its privacy policies; however, clients are encouraged to request each specific firm’s written policy for review.

Procedures to Protect Confidentiality and Security of Your Personal Information

Column Capital has procedures in place that limit access to Personal Information to those employees who need to know such information in order to perform business services. In addition, Column Capital maintains physical, electronic and procedural safeguards to guard your Personal Information.
Column Capital has also adopted the following policies in order to safeguard the Personal Information of our clients in accordance with applicable law:
1. Column Capital is committed to protecting the confidentiality and security of the Client Information it collects and will handle Personal Information about clients only in accordance with all applicable laws, rules and regulations. We shall ensure: (a) the security and confidentiality of client records and information; (b) that client records and information are protected from any anticipated threats and hazards; and (c) that unauthorized access to, or use of, client records or information is protected against. These security measures include computer safeguards and secured files and buildings.
2. Column Capital will maintain policies and procedures that are reasonably designed to safeguard Personal Information about clients and only permit appropriate and authorized access to, and use of, Personal Information about clients through the application of appropriate administrative, technical, and physical protections.
3. To the extent required by applicable law, we shall direct each of our service providers to adhere to the Column Capital’s Privacy Policies with respect to all Personal Information about provided to such service providers.
4. Column Capital shall not disclose any Personal Information about its clients or former clients to anyone, except as permitted or required by law.
5. Column Capital shall issue notices of its Privacy Notice to its clients initially and on an annual basis thereafter to the extent required by applicable law.

By disclosing your Personal Information to Column Capital, you consent to the collection, storage, and processing of this information by us in a manner consistent with this Privacy Policy and Notice.

Linking to Third Party Websites. We may provide links to third party websites. If you follow links to third-party websites not affiliated or controlled by Column Capital, you should review that third-party’s privacy and security policies and other terms and conditions, as they may be different from our Privacy Policies and Notice. We do not guarantee and are not responsible for the privacy or security of these third-party websites, including the accuracy, completeness, or reliability of their information.

Children. Our Website is not directed or intended for individuals under the age of thirteen (13), and we request that these individuals do not provide personal information through the Website. We do not knowingly collect or retain information from children under the age of 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children's Online Privacy Protection Act (COPPA).

Former Clients. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you, and we will continue to treat your nonpublic information with strict confidentiality.

Changes to this Policy. Column Capital will provide each client with initial notice of the firm's current privacy policy when the client relationship is established. We will also provide each client with a new notice of the firm’s current privacy policy at least annually. If, at any time, Column Capital adopts material changes to its privacy practices, the firm shall provide each client with a revised notice reflecting the new privacy practices.

Contact Us: Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Jeffrey J. Yu, Chief Compliance Officer of Column Capital Advisors.  Contact information: or 317-663-6500.