Simran Capital collects nonpublic personal information about you that is provided by you or obtained by Simran Capital with your authorization. Simran Capital may collect nonpublic personal information about you from the following sources:

• Information Simran Capital receives from you on applications or other forms, and

• Information about your securities transactions with Simran Capital or other advisers and broker/dealers which may be providing financial services to you.

It is the policy of Simran Capital that we do not disclose any nonpublic personal information about our clients or former clients to unaffiliated third parties, except as permitted by law. When necessary to provide all of the services you request for your account, Simran Capital may provide nonpublic personal information about you to certain third parties, such as clearing firms that serve or may serve as the custodian of your account, or that may effect securities transactions on your behalf, or insurance companies. Such disclosure is only made to fulfill our duties to you in fully servicing your account. Under no circumstances do we sell your name or other information to anyone.

Simran Capital retains records relating to professional services that we provide so that we are better able to assist you with your needs. Simran Capital restricts access to your personal and account information to those employees who need to know that information to provide products or services to you. Simran Capital maintains physical, electronic, and procedural safeguards to guard your non-public personal information. If you decide to close your account(s) with Simran Capital or become an inactive customer, Simran Capital will adhere to the privacy policies and practices as described in this notice.