Northern Capital Management, Inc. and W.F.C.G. Securities, Inc. Privacy Policy   Northern Capital Management, Inc. and W.F.C.G. Securities, Inc. operates under the regulatory oversight of the Securities Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA). The Commission periodically establishes rules and policies related to investors.   On June 22, 2000 the Securities Exchange Commission (SEC) issued its final rule regarding the obligation of registered investment advisors to protect the privacy of their clients (referred to as “customers” in the actual SEC regulation). The new rule, Regulation S-P, implements the privacy requirements of year 2000’s financial modernization legislation, the Gramm-Leach-Biley Act (“GLB Act”). The SEC has mandated that investment advisors must formulate and implement privacy policies and have procedures to safeguard client privacy.   The scope of Regulation S-P is broad, as it requires securities firms to adopt policies and procedures that address “administrative, technical and physical safeguards” for the protection of client records and information. In particular, these safeguards must insure the security and confidentiality of information; protect against threats to the integrity of customer records and information; and protect against unauthorized access.   As a consequence of this sweeping mandate, we have provided a definitional expansion of our contractual obligation of confidentiality provided in our investment advisory contract.   With regard to confidentiality, our advisory agreement states “Information and advice furnished by either party to the other, including their agents and employees, shall be treated as confidential and not disclosed to third parties except as agreed upon in writing, required by law or in the course of the normal conduct of business.” It has been the long-standing policy of this firm, that disclosure of any information related to our client accounts, including the existence of our association, is prohibited.    This Privacy Policy is intended to delineate the practical application of our stated contractual commitment and applies uniformly to current and former clients.   At Northern Capital Management, Inc and W.F.C.G. Securities, Inc. (“NCM/WFCG”) our most important asset is our relationship with you. We are honored that you have entrusted us with your financial affairs, and we are committed to safeguarding the privacy of information we maintain about you. Establishing and adhering to an effective privacy policy is an important part of that dedication.   Below, you will find details about NCM/WFCG's commitment to protecting your privacy, including the types of information we collect about you, how we use and share that information both within and outside NCM/WFCG and how you can instruct us to limit certain types of information sharing.   Our privacy policy applies to all clients with whom we have a relationship and is also extended to each of our former clients.   Your Privacy Is Not for Sale: Simply put, we do not and will not sell your personal information to anyone, for any reason, at any time.   How We Collect Information About You: We collect personal information about you in a number of ways.   Application, Financial Advisory Agreement, Client New Account Form and Registration Information: We collect information from you when you open an account or enroll in one of our services. You will also be asked for information when you choose to participate in a NCM/WFCG promotion. We may also collect information from consumer reporting agencies to verify your identity in the account-opening process. The information we collect may include your name, address, phone number, email address, Social Security number and date of birth, as well as details about your interests, investments, tax status, estate planning and investment experience.   Transaction and Experience Information: Once you have opened an account with us, we collect and maintain personal information about your account activity, including your transactions, balances, positions and history. This information allows us to administer your account and provide the services you have requested.   Third-Party Information Providers: We may collect information about you from information services and consumer reporting agencies to verify your identity, employment or creditworthiness, or to better understand your financial needs.   Website Usage: When you visit our website, our computer may use devices known as "cookies," graphic interchange format files (GIFs), or other similar Web tools to enhance your Web experience. These tools enable us to recognize you when you return to our site, maintain your Web session while you browse, as well as help us provide you with a better, more personalized experience at NCM/WFCG.   How We Share Information About You Within Northern Capital Management, Inc. and W.F.C.G. Securities, Inc.: Many clients within NCM/WFCG do business with one or both, creating an efficient, comprehensive financial relationship to meet individual needs. When appropriate, NCM/WFCG may share information we collect about you with each other to: help provide you with better service or perform services on our behalf; respond to communications from you or as you authorize or request; make it more convenient for you to open a new account.   How We Share Information About You Outside of NCM/WFCG: We provide access to information about you to outside companies and other third parties in certain limited circumstances, including: to help us process transactions for your account; when we use another company to provide services for us, such as printing and mailing your account statements; when we believe that disclosure is required or permitted under law. For example, we may be required to disclose personal information to cooperate with regulatory or law enforcement authorities, to resolve consumer disputes, to perform credit/authentication checks, or for risk control.   How to Limit the Sharing of Information About You: Since we do not share information about you to any company other than to facilitate the necessary business of managing your account, there is a very limited ability to restrict information sharing. However, if you have concerns in this regard you are encouraged to contact our office at 1-509-456-2526 or 1-800-826-9803.   Joint account holders may instruct us on behalf of another account holder.   You may make your privacy choice at any time and it will remain in effect until you change it.   We will continue to share information about you with outside companies as required by law.   State Laws: We will comply with state laws that apply to the disclosure or use of information about you.   Safeguarding Your Information, Maintaining Your Trust: We take precautions to ensure the information we collect about you is protected and is accessed only by authorized individuals or organizations.   Companies we use to provide support services are not allowed to use information about our clients for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of information to the performance of the specific services we have requested.   We restrict access to personal information by our employees and agents. Our employees are trained about privacy and are required to safeguard personal information.   We maintain physical, electronic and procedural safeguards to protect personal information.   Identity Theft: Identity theft is a serious concern to all of us. Safeguarding information to help protect you from identity theft is our priority. NCM/WFCG takes steps to protect you from identity theft by: utilizing client identification and authentication procedures before initiating transactions; creating a secure transmission connection to our NCM/WFCG website; ensuring our employees are trained to safeguard personal information about you.   You can also help protect your identity and accounts. Here are a few steps to remember: NCM/WFCG will never request your account number, login password, or Social Security number in either a non-secure or unsolicited email communication; shred documents that contain personal information; check your credit report regularly for unauthorized activity and protect your personal identification numbers (PINs) or personal data.   If you have been a victim of identity theft or to learn more about protecting yourself against identity theft, go to the Identity Theft Prevention Program.   Greater Accuracy Means Better Protection: We are committed to keeping accurate, up-to-date records to help ensure the integrity of the information we maintain about you. If you identify an inaccuracy in this information, or if you need to make a change to it, please contact us promptly by calling 1-509-456-2526 or 1-800-826-9803.   A Commitment to Keeping You Informed: We will provide you with advance notice of important changes to our information-sharing practices.