Clausen Capital Management, Inc. honors our client's right to privacy and strives to maintain the highest standards of confidentiality. In that respect, we are providing this Privacy Notice to all of our clients in accordance with Regulation S-P as released by the SEC (Securities Exchange Commission).

Privacy Policy - Clausen Capital Management's policy is to protect personal client information. We do not sell or maintain lists for any outside nonaffiliated marketing firms. We are committed to maintaining the physical, electronic, and procedural safeguards to protect any personal information we obtain about our clients.

Information Collected About You - The non-public personal information we collect about our clients comes primarily from the account applications, management agreements, and client profiles you submit to us when opening a managed account. We may also collect information about your transactions and account history for your managed accounts through various nonaffiliated companies, such as mutual funds, life insurance companies, brokerage houses, and trust companies.

Use and Disclosure of Information - Clausen Capital will not disclose personal client information, except as permitted by law under the following circumstances:

• By your written request to provide information to a third party
• To establish or maintain an account with a nonaffiliated third party, such as a clearing broker, life insurance company, trust company, or mutual fund company in which Clausen Capital Management would actively manage
• To sub-advisers contacted by Clausen Capital Management to actively manage specific strategies
• To render services that you have requested (as in completing a wire transfer or other withdrawal from your account)
• To government entities or other third parties in response to subpoenas or other legal processes as required by law

Security Policy - We maintain physical, electronic, and procedural security measures that comply with applicable state and federal regulations to safeguard confidential client information. Access to confidential client information is authorized only for the Clausen Capital Management employees who require information to perform their job functions.

Closed or Inactive Accounts - If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

Changes to this Privacy Notice - If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.

ADV - Part II Offering - Clausen Capital Management offers the ADV Part II Disclosure on the opening of each client account. In addition, the offer is extended on each client on an annual basis. If you desire a copy of our ADV Part II Disclosure, simply click here, call our office, or request a copy by email at gclausen@clausnencap.com.