Privacy Policy

Old North State Trust, LLC takes seriously our responsibility to keep the information you provide to us in the strictest confidence. Federal privacy laws regulate what investment advisors are allowed to do with the confidential personal information that they collect in connection with their financial service activities. Our standards have always been in the interest of protecting our clients’ confidentiality.

OLD NORTH STATE TRUST, LLC PRIVACY POLICY Old North State Trust, LLC (“ONST”), a North Carolina based trust company, recognizes its customers’ expectations of financial privacy; WHEREAS, preserving its customers’ trust is one of the core values of ONST; WHEREAS, ONST has adopted the privacy pledge attached as Exhibit A; WHEREAS, ONST is subject to Subtitle A of Title V of the Gramm-Leach-Bliley Act (the “Act”), which requires financial institutions to disclose their privacy policies, limit their disclosure of certain information, give customers an opportunity to “opt out” of some disclosures to third- parties subject to a variety of significant exceptions, and protect the security of their customers’ records and information; and WHEREAS, ONST desires that its current and former customers’ personally identifiable financial information is kept confidential in accordance with standards outlined in the following policy (“Policy”) approved and adopted by the ONST Board of Directors. 1. Nonpublic Personal Information. All nonpublic information that a consumer provides to ONST to obtain a financial product or service from ONST, about a consumer resulting from any transaction involving a financial product or service between ONST and a consumer, and from which ONST otherwise obtains about a consumer in connection with providing a financial product or service to the consumer, including personally identifiable financial information, shall be considered Nonpublic Personal Information. The following types of information shall be considered “Nonpublic Personal Information”: • any information a consumer provides to ONST in connection with opening an account or establishing and maintaining a continuous relationship with ONST, whether in writing or oral; • any account balance information, securities or other assets held in such consumer’s account, payment information, and trading history; • the fact that a consumer is or has been one of ONST’s customers or has obtained a financial product or service from ONST; • any information about an individual if it is disclosed in a manner that indicates that the individual is or has been a consumer of ONST; • any information ONST collected through an Internet “cookie” (an information collecting device from a web server); and • information from a consumer 2. Collection of Nonpublic Personal Information. ONST may collect Nonpublic Personal Information from: • information a consumer provides to ONST in connection with opening an account or establishing and maintaining a continuous relationship with ONST, whether in writing or oral; • information about consumer transactions with ONST and its affiliates; • information ONST receives from third parties such as a consumer’s accountants, attorneys, life insurance agents, family members, financial institutions, custodians, and trustees. Nonpublic Personal Information is collected at the onset of, and during, the client relationship and shall be included in the Client’s file. Such information shall be maintained either on the premises of ONST or off-site in accordance with the applicable record keeping requirements of the Office of the North Carolina Commissioner of Banks. When Nonpublic Personal Information is stored off-site, ONST shall ensure, through proper contractual arrangements, that the Nonpublic Personal Information shall be kept confidential. Nonpublic Personal Information shall be managed by designated staff services personnel, who shall organize and maintain such information as described in Section 11. Each Customer shall have the opportunity to update his/her Nonpublic Personal Information on the Customer statement, which ONST shall provide in accordance with the regimen in the Customer’s account arrangement. 3. Disclosure of Nonpublic Personal Information. All employees that need to know certain Nonpublic Personal Information to provide products and services to Customers shall have access to such information. No employee, officer, director, or agent of ONST shall disclose Nonpublic Personal Information to anyone, except disclosures of Nonpublic Personal Information allowed under the Act (as amended from time to time), including disclosures that are: • necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes; • in connection with processing or servicing a financial product or service that a consumer requests or authorizes; • to protect the confidentiality or security of ONST’s records pertaining to the consumer, service, product, or transaction; • to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability; • for required institutional risk control or for resolving consumer disputes or inquiries; • to persons holding a legal or beneficial interest relating to the consumer; • to persons acting in a fiduciary or representative capacity on behalf of the consumer; • to the extent specifically permitted or required under other provisions of law and in accordance with the Right to Financial Privacy Act of 1978 (12 U.S.C. 3401 et seq.), to law enforcement agencies (including a federal functional regulator, the Secretary of the Treasury, with respect to 31 U.S.C. Chapter 53, Subchapter II (Records and Reports on Monetary Instruments and Transactions) and 12 U.S.C. Chapter 21 (Financial Recordkeeping), self-regulatory organizations, or for an investigation on a matter related to public safety; • to a consumer reporting agency in accordance with the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.), or from a consumer report reported by a consumer reporting agency; • to comply with federal, State, or local laws, rules and other applicable legal requirements; • to comply with a properly authorized civil, criminal, or regulatory investigation, or subpoena or summons by federal, State, or local authorities; • to respond to judicial process or government regulatory authorities having jurisdiction over ONST for examination, compliance, or other purposes as authorized by law; or • to a non-affiliated third party to perform services for or functions on behalf of ONST, including marketing of ONST’s own products or services; provided that ONST enters into a contractual agreement with the third party that requires the third party to maintain the confidentiality of such information. 4. Identifying and Monitoring Customers. A consumer will be considered a “Customer” if he or she: • has an account agreement with ONST (whether written or oral); or • is a participant that holds an investment product through ONST, such as when ONST acts as a custodian for securities or for assets in an Individual Retirement Arrangement. In addition, a consumer shall be considered a “Customer” if ONST regularly effects or engages in securities transactions with or for a consumer even if ONST does not hold any assets of the consumer. ONST shall keep a current list of Customers, which is not required to include individuals that have not yet become Customers (i.e., “work in progress” individuals). 5. Identifying and Monitoring Nonaffiliated Third Parties. A Nonaffiliated Third Party is any company that does not have the power to exercise a controlling influence over the management or policies of ONST, whether through ownership of more than 25 percent of the voting securities of ONST, by contract, or otherwise. A Nonaffiliated Third Party is also any company in which ONST does not have the power to exercise a controlling influence over, whether through ownership of more than 25 percent of the voting securities of such company, by contract, or ONST shall obtain, and review annually, each Nonaffiliated Third Party that has access to Nonpublic Personal Information through the Vender Management Process. 6. Sharing of Nonpublic Personal Information. ONST shall not disclose any Nonpublic Personal Information to anyone, except as permitted by law. ONST is permitted to disclose Nonpublic Personal Information to Nonaffiliated Third Parties in certain circumstances, as described in Section 3. For example, ONST may share Nonpublic Personal Information with Charles Schwab, Reich and Tang, and any other third- party providers that assist us with servicing your account(s). ONST reserves the right to disclose all of the Nonpublic Personal Information it collects from consumers, as listed under Section 2 of this Privacy Policy, to Nonaffiliated Third Parties which perform services for, or functions on behalf of, ONST (“Third Party Service Providers”); provided that ONST shall enter into a contractual agreement with each Third Party Service Provider to which it discloses Nonpublic Personal Information which prohibits the Third Party Service Provider from disclosing or using the information other than to carry out the purposes for which the information is disclosed. Such Third-Party Service Providers may include financial or non- financial companies, which perform administrative, customer service, or marketing functions on behalf of ONST. If a customer decides to close its account(s) or become an inactive Customer, ONST will adhere to the privacy policies and practices as described in this Policy. 7. Third Party Confidentiality. To ensure the responsible use and protection of Nonpublic Personal Information by Nonaffiliated Third Parties, ONST requires each Nonaffiliated Third Party who has access to Nonpublic Personal Information to agree to maintain the confidentiality of any Nonpublic Personal Information they may receive concerning ONST’s Customers and to only redisclose or reuse such information to another Nonaffiliated Third Party under the processing and servicing exception codified at 17 CFR §248.14 or the miscellaneous exceptions codified at 17 CFR §248.15, but only in the ordinary course of business to carry out the activity covered by the exception under which the Nonaffiliated Third Party received the information in the first instance. In addition, each contract between ONST and a Nonaffiliated Third Party shall contain similar language like in the form attached hereto as Exhibit B. 8. Delivery of Privacy Notices. ONST will (i) hand deliver, (ii) mail a printed copy of a summary of this Policy, or (iii) email via DocuSign, substantially in the form attached hereto as Exhibit C, (the “Notice”) to a consumer at the time he or she executes an account agreement with ONST. 9. Retention of Privacy Notices. ONST will retain a form of Exhibit 2.6A (2), the Privacy Notice, and a list of who received the Notice in an easily accessible place so that each Customer can obtain another copy in the form of Exhibit 2.6A (3) Privacy Notice Receipts. 10. Annual Review. The ONST Board of Directors will annually review this Policy to ensure it is adequate to protect Nonpublic Personal Information. If the Board of Directors determines that its Policy is not being adhered to, it will take whatever corrective measures are necessary, including revising its compliance procedures. If ONST desires to disclose Nonpublic Personal Information in a way that is not accurately described in the Notice, ONST will provide each Customer and consumer a revised Notice before disclosing that information. This Policy may be amended from time to time by the ONST Board of Directors in order to comply with applicable laws and regulations. 11. Security Procedures. ONST shall restrict access to Nonpublic Personal Information to those who need to know that information to provide products and services to Customers. Employees who violate these standards will be subject to disciplinary measures. ONST shall maintain physical, electronic, and procedural safeguards that comply with federal standards to guard Nonpublic Personal Information, including the following: • use of MAUI and features to organize and retain Nonpublic Personal Information; • requiring employee use of user ID numbers and passwords to access Nonpublic Personal Information stored electronically; • use of backup and off-site storage of Nonpublic Personal Information to ensure proper recovery; • use of intruder detection devices and fire and burglar resistant storage devises at physical locations containing Nonpublic Personal Information, including off-site premises; and • employee background checks, training and segregation of duties for employees with responsibilities for or access to Nonpublic Personal Information. Exhibit A PRIVACY PLEDGE ONST recognizes its customers’ expectation of financial privacy; and whereas preserving our customers’ trust is one of the core values of ONST and the financial community; ONST pledges to follow these guidelines as to the responsible use and protection of our customers’ information: • We will always value the trust of our customers and the importance of keeping their personal financial information confidential. • We will provide our customers with our policy on using their personal financial information responsibility and protecting it. • We will hold our employees to the highest standard confidentiality of our customer information. • We will use information responsibly in order to provide our customers with significant benefits, including fraud prevention, improved products, and services and to comply with the law. • We will establish procedures to maintain accurate information and respond in a timely manner to our customers’ request to change or correct information. • We will use a combination of safeguards to protect our customers against the criminal use of their information and to prevent unauthorized access to it. • We will require the companies we do business with to abide by our privacy policy to maintain the confidentiality of our customers’ information. Exhibit B SAMPLE THIRD PARTY CONTRACT LANGUAGE [Old North State Trust, LLC] and [Third party] agree to take all steps necessary to comply with applicable regulations protecting the privacy of consumers’ nonpublic personal information. To the extent [Old North State Trust, LLC] provides [Third party] with any nonpublic personal information as necessary to effect, administer, or enforce a transaction that a customer of [Old North State Trust, LLC] requests or authorizes, or in connection with processing or servicing a financial product or service that a customer of [Old North State Trust, LLC] requests or authorizes, [Third party] agrees not to disclose or use any such information for any purpose other than to carry out the purposes for which [Old North State Trust, LLC] disclosed the information or as permitted by law in the ordinary course of business to carry out those purposes. [Old North State Trust, LLC] and [Third party] agree to adopt policies and procedures that address administrative, technical, and physical safeguards for the protection of customer records and information. Exhibit C PRIVACY POLICY NOTICE Old North State Trust, LLC takes seriously our responsibility to keep the information you provide to us in the strictest confidence. Federal privacy laws regulate what investment advisors are allowed to do with the confidential personal information that they collect in connection with their financial service activities. Our standards have always been in the interest of protecting our clients’ confidentiality. Old North State Trust may obtain nonpublic personal information about your family and business, assets, income and expenditures, risk tolerance, estate, insurance coverage or other personal information in the course of providing the advisory services for which you have engaged the firm. This information may come from account forms, investor profiles, tax, or legal documents that you provide to us or that you authorize us to obtain from others. Information may also come from discussions with you or with others that you authorize. We only collect information which is necessary to manage your accounts, abide by all laws and regulations, and review and develop new services and products that may be of benefit to you. Old North State Trust uses the information responsibly so that your privacy is protected. We do not disclose any nonpublic personal information about our current or former clients to anyone, except as required by law or per the client’s authorization. We do not participate in releasing this nonpublic information to other entities for independent telemarketing, direct mail, or any other purpose. Access to nonpublic personal information about our clients is restricted to those professionals and staff who need to know such data in order to provide financial services on that account. Strict internal company policies and an employee conduct code ensure that your personal and financial information will be protected. We maintain physical, electronic, and procedural safeguards to comply with federal regulations and professional requirements in order to preserve the confidentiality of your personal information. In order to help fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. What this means for you: when you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying document. Old North State Trust maintains a policy to ensure that we appropriately deal with alternative forms of remuneration. This policy seeks to ensure that our accounts are dealt with in an equitable manner and that all applicable regulations are adhered to. In the course of normal transactions, we receive due diligence and marketing allowance payments from certain alternative investment sponsors. If you would like a list of these companies, one can be provided to you at no cost.