PRIVACY POLICY

Regulation S-P, put forth by the SEC in 2000 to safeguard the private, non-public information of advisory clients, is the foundation of the Knightbridge Capital, LLC privacy policy. Under this regulation, associated persons of Knightbridge Capital, and parent affiliate Prentice Wealth Management, LLC are prohibited from disclosing confidential client information to any third party except:

(a) As necessary to provide services requested or authorized by the client or to maintain and provide service to the client’s account;

(b) As required by industry regulatory bodies or law enforcement agencies having jurisdiction over Knightbridge and/or Prentice or as otherwise required by law; or

(c) To the extent reasonably necessary to counter fraud, unauthorized transactions or potential liabilities.

Client confidential information may include, but is not limited to, the following:

(a) Personal and account data;

(b) Allocation of assets within the client’s portfolio;

(c) Specific investments held within a client’s portfolio;

(d) Advice provided to the client by the Firm; and

(e) Analyses prepared for the client based on confidential information.

All associated persons of the Firm are bound to confidentiality regarding client information while associated with the Firm, as well as following their termination, as disclosed in a Confidentiality Agreement each is required to sign upon joining the Firm. Each associated person is also required to review the Firm’s Privacy Policy initially upon joining the Firm and annually thereafter, as evidenced by their signature on a certification form. These certification forms and agreements are maintained by the CCO in conjunction with the Firm’s Written Supervisory Policy and Procedures Manual. Outside vendors employed by Knightbridge and/or Prentice, who in the conduct of their services for the Firm may have access to confidential client information, are required to sign a Confidentiality Agreement as well.