Private Capital Management, Inc.

Privacy Notice

Private Capital Management, Inc. (referred to as “PCM”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, PCM attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of PCM 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 to the clients. PCM may disclose the client’s information if PCM is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with PCM, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment advisor, account custodian, etc.); (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. The disclosure of information contained in any document completed by the client for processing and/or transmittal by PCM in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment advisor, account custodian, insurance company, etc.,), including information contained in any document completed and/or executed by the client for PCM (i.e., advisory agreement, client information form, etc.), shall be deemed as having been authorized by the client with respect to the corresponding nonaffiliated third party service provider.

PCM permits only authorized employees and affiliates who have a signed copy of PCM’s Privacy Policy to have access to client information. Employees violating PCM’s Privacy Policy will be subject to PCM’s disciplinary process. Additionally, whenever PCM hires other organizations to provide services to PCM’s clients, PCM will require them to sign confidentiality agreements and/or the Privacy Policy.

Should you have any questions regarding the above, please do not hesitate to contact us.