Northern Capital Securities Corporation is required to obtain personal information from you to help meet your investment needs and to assist in making certain decisions and determinations in relation to your account(s) with us. Given the sensitive nature of this information, we understand that concerned clients may have questions about our privacy practices and how we use personal data in our daily operations.

Information We Collect

We collect nonpublic personal information from the following sources:

• Information you provide to us through applications, forms, or other communications

• Information about your transactions with us or through authorized financial institutions with which you maintain accounts or relationships

Use and Disclosure of Information

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law. If you close your account(s) or become an inactive client, we will continue to adhere to the privacy policies and practices described in this notice.

Northern Capital only discloses information about you and your account(s) to others under the following circumstances:

• To maintain records and fulfill regulatory and legal obligations

• When necessary to complete a transaction or service on your behalf

• To comply with legal or regulatory requests, including those from the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), or Internal Revenue Service (IRS)

• To perform required due diligence or background checks

• As otherwise required by applicable laws, rules, or regulations

We do not sell customer information to third parties.

Safeguarding Your Information

Northern Capital Securities Corporation restricts access to your personal and account information to employees who need to know that information in order to provide products or services to you. All employees are required to treat your account information with the highest level of confidentiality and are prohibited from transacting business or disclosing information unless the individual is authorized to act on the account.

We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information.

Your Rights and Our Commitment

Northern Capital supports your right to privacy and is committed to protecting it. Clients can have full confidence in our commitment to handle personal information in a responsible and professional manner.

If you believe any of the personal information we maintain is inaccurate, please contact us. We will promptly investigate and correct any inaccuracies, where appropriate.

We will not revise our privacy policy to permit additional sharing of nonpublic personal information without first notifying you and providing an opportunity to opt out, unless otherwise required by law. As required under Massachusetts privacy laws, investment advisory clients must “opt in” before we share nonpublic personal information with non-affiliated third parties.