Introduction

Parsonex Advisory Services, Inc. ("PAS" or "the firm") respects the privacy of our clients and is committed to safeguarding the information you share with us. This Privacy Policy describes the categories of nonpublic personal information ("customer information") we collect about you, the circumstances under which we may share it, the measures we take to protect it, and the steps we will take to notify you if we become aware that your sensitive customer information has been accessed or used without your authorization.

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We deliver this notice when you open an advisory account with us and annually thereafter, as required by SEC Regulation S-P. We will also deliver an updated notice if our practices change in a way that requires us to do so.

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Information We Collect

We collect customer information from the following sources:

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• Information you provide on advisory agreements, account applications, and other forms — for example, your name, address, Social Security number, date of birth, employment information, financial circumstances, investment objectives, and risk tolerance.

• Information about your transactions with us, our affiliates, or others — for example, account balances, holdings, and transaction history.

• Information from consumer reporting agencies and other third parties, where authorized — for example, credit history and identity verification information.

• Information from interactions with the firm — for example, communications you send to us, recordings of phone calls where applicable and disclosed, and information generated when you use systems we provide.

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Information We Share

PAS does not sell customer information. We share customer information only as permitted by law and only as necessary to:

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• Provide and service your advisory accounts, including with the custodian or product sponsor holding your account

• Comply with legal and regulatory obligations, including responses to subpoenas, court orders, and regulatory inquiries

• Protect against fraud, unauthorized transactions, and security threats

• Provide services to you through our affiliates and through service providers acting on our behalf under written agreements that require them to safeguard your information

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We may share customer information with our affiliates — companies related to PAS by common ownership or control that operate under the Parsonex name — where the sharing supports services we or they provide to you. You have the right to limit certain affiliate sharing as described below.

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Service Providers

The firm engages service providers to assist with operations, technology, recordkeeping, communications, custody, and other functions. Where a service provider receives customer information in connection with these services, we require by written agreement that the service provider implement reasonable safeguards to protect that information, use the information only for the purposes for which it was provided, and notify the firm promptly of any incident involving unauthorized access to or use of that information.

The firm maintains an inventory of service providers that receive customer information and conducts periodic reviews of their security practices commensurate with the sensitivity of the information they handle.

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How We Protect Your Information

PAS maintains administrative, technical, and physical safeguards reasonably designed to protect customer information from unauthorized access, use, alteration, or disposal. Depending on the systems involved and the sensitivity of the information, these safeguards may include:

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• Access controls limiting which firm personnel may access customer information to those with a legitimate business need

• Authentication requirements, including multi-factor authentication for access to systems holding customer information

• Encryption of customer information in transit and at rest using industry-standard methods

• Monitoring of firm systems for unauthorized access attempts and unusual activity

• Periodic testing of safeguards and remediation of any deficiencies identified

• Training of firm personnel on information security responsibilities

• Written incident response procedures

• Proper disposal of customer information when it is no longer required to be retained

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Notification of Unauthorized Access

If we become aware that an unauthorized party has accessed or used your sensitive customer information — information such as your Social Security number, financial account number, or similar identifiers that could create a risk of harm if exposed — and that such access or use has occurred or is reasonably likely to have occurred, we will notify you as soon as practicable, and in any event no later than thirty (30) days after becoming aware.

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We will provide this notice unless we determine, after a reasonable investigation, that the sensitive customer information has not been, and is not reasonably likely to be, used in a manner that would result in substantial harm or inconvenience to you. We may delay notification if a law enforcement agency advises us in writing that notification would interfere with a criminal investigation or pose a threat to national security, for the period specified by that agency.

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The notification will describe in general terms the incident, the type of sensitive customer information involved, the steps the firm has taken in response, the steps you can take to protect yourself, and contact information for further inquiries.

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Your Choices

Affiliate Sharing. You may limit our sharing of certain customer information with our affiliates for marketing purposes. To opt out, contact us at the address or telephone number below. If you have previously made an opt-out election, that election remains effective until you revoke it.

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Email and Marketing. You may opt out of marketing communications from the firm at any time by contacting us or by following the unsubscribe instructions in any marketing email.

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Access and Correction. If you believe customer information we hold about you is inaccurate, contact us using the information below and we will work with you to verify and correct as appropriate.

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Disposal of Customer Information

When customer information is no longer required to be retained by applicable law or by the firm's records retention policies, the firm disposes of it in a manner reasonably designed to prevent unauthorized access, including secure deletion of electronic records and destruction of paper records.

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Former Clients

We continue to apply the protections described in this Privacy Policy to information we retain about former clients for the period during which we are required to retain it.

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Changes to This Policy

The firm may update this Privacy Policy from time to time. We will provide a revised notice when required by law or where the changes are material. The current version is always available at parsonex.com and is delivered with new account paperwork.

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Contact Information

For questions about this Privacy Policy, to exercise your choices described above, or to report a concern about your information:

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• Mail: Parsonex Advisory Services, Inc., Attn: Compliance, 8310 S. Valley Highway, Suite 110, Englewood, CO 80112

• Phone: (303) 662-8700

• Email: compliance@parsonex.com

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