Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Onitus Capital, LLC (“Onitus”). Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, including:

• Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;
• Information about your transactions with us, our affiliates, or others;
• Information about your visits to our website. We store records of the activities on our sites in our web server logs, which automatically capture and save the information electronically. The information we collect helps us administer the site, analyze its usage, protect the website and its content from inappropriate use, and improve the user’s experience.
• Information received from credit or service bureaus or other third parties, such as your credit history or employment status. Categories of Information We Disclose: We may only disclose information that we collect in accordance with this policy. Onitus does not sell customer lists and will not sell your name to telemarketers. Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account at Onitus, except under the following circumstances:
• To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company,
• To comply with broker-dealer firms that have regulatory requirements to supervise certain representatives’ activities;
• To third parties who perform services or marketing, client resource management, or other parties to help manage your account on our behalf;
• To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
• To our attorneys, accountants, or auditors; and
• To government entities or other third parties in response to subpoenas or other legal processes as required by law or to comply with regulatory inquiries. How We Use Information: Information may be used among companies that perform support services for us, such as data processors, client relationship management technology, technical systems consultants, and programmers, or companies that help us market products and services to you for a number of purposes, such as:
• To protect your accounts/non-public information from unauthorized access or identity theft;
• To process your requests such as securities purchases and sales; • To establish or maintain an account with an unaffiliated third party, such as a clearing brokerdealer providing services to you and/or Onitus;
• To service your accounts, such as by issuing checks and account statements;
• To comply with Federal, State, and Self-Regulatory Organization requirements;
• To keep you informed about financial services of interest to you.

Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted out. Onitus does not receive information regarding marketing eligibility from affiliates to make solicitations. Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information. Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy is available upon request. Succession Planning: In the event that the owner(s) of Onitus retire, become incapacitated, or perish unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating a business succession plan. A change in control of ownership of Onitus would require your consent, as dictated by your signed agreement with Onitus, in order to continue providing services to you. Your Right to Opt Out: Federal privacy laws give you the right to restrict us from sharing your personal financial information. These laws balance your right to privacy with Onitus’ need to provide information for normal business purposes. You have the right to opt out of sharing certain information with affiliated and unaffiliated companies of our firm. Choosing to restrict the sharing of your personal financial information will not apply to (1) your information that we may share with companies that help promote and market our own products or products offered under a joint agreement with another company; (2) records of your transactions- -such as your loan payments, credit card or debit card purchases, and checking and savings account statements- -to firms that provide data processing and mailing services for our firm; (3) information about you in response to a court order; and (4) your payment history on loans and credit cards to credit bureaus. If you opt out, you limit the extent to which Onitus can provide your personal financial information to non-affiliated companies. You may opt out of the disclosure of nonpublic personal financial information to non-affiliates by contacting Onitus at (860) 918-4904. Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to you. Complaint Notification: Please direct complaints to: Kyle Soucy at Onitus Capital, LLC, 3857 Birch St PMB 5059, Newport Beach, CA 92660; (860) 918-4904. Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate confidential information, we will notify you. If you have any questions concerning this Privacy Policy, please contact us at: Onitus Capital, LLC, 3857 Birch St PMB 5059, Newport Beach, CA 92660; (860) 918-4904.

Onitus Capital, LLC is a Registered Investment Adviser. Advisory services are only offered to clients or prospective clients where Onitus Capital, LLC and its representatives are properly licensed or exempt from licensure. This website is solely for informational purposes. Past performance is no guarantee of future returns. Investing involves risk and possible loss of principal capital. No advice may be rendered by Onitus Capital, LLC unless a client service agreement is in place.

Confidentiality of Personal Information

When visitors access our website, we may ask for personal information such as name, address, email address, telephone number, and company. We also collect information about aggregate site usage. Statistics that we gather about unique visits, referring URLs, repeat visits and page views are all based on IP addresses, and are not associated with your personal information. This information shall be considered confidential information and will be handled in accordance with our Privacy Policy. We take every measure to protect our users' information submitted to us through our website or through any survey.

Children

This site is not targeted towards children under the age of 18, nor does this site knowingly collect personal information about children.

Links

This site may contain links to other sites. When you navigate to any of the websites or posts provided, you are leaving this site. Please be aware that we are not responsible for the privacy practices or content of such other sites. We encourage our users to be aware that when they leave our site they should read the privacy statements of external websites that collect personally identifiable information. Our Privacy Policy applies solely to information collected by this website. We make no representation as to the completeness or accuracy of information provided by external sites, nor are we liable for any direct or indirect technical or system issues or any consequences arising out of your access to or use of third-party technologies, sites, information and/or programs made available through this site. Information and opinions on this site provided by third parties have been obtained from sources believed to be reliable, but accuracy and completeness cannot be guaranteed. It is given for informational purposes only and is not a solicitation to buy or sell any products or services offered. The information is not intended to be used as the primary basis for investment decisions, nor should it be considered as advice of professionals, as appropriate, regarding the evaluation of any specific information, opinion, advice or other content.

Cookies

This site may use cookies to help track usage patterns on our site. A cookie is a piece of data stored on the user's hard drive containing information about the user. The cookie is only on the user’s computer; it is not stored or retained in any form by the Site. Usage of a cookie is in no way linked to any personally identifiable information while on our site. It is used for the sole purpose of identifying a regular user’s preferences, so as to customize the user’s experience. For instance, by setting a cookie for this site, the user would not have to log in a password more than once, thereby saving time. Advertisers and advertising vendors who serve ads onto our websites may use their own cookies or other tracking technologies. We cannot be responsible for the privacy policies or practices of any such advertisers and vendors.

Legal Disclaimer

This site does not make any warranties or representations, express or implied, about the information provided on or accessed through our site. In particular it does not warrant or represent that the information is accurate, up-to-date, comprehensive, verified or complete. Our site does not accept liability for any error, omission or delay in the information or for any reliance placed by any person on the information. Our site shall not be liable for any claims or losses of any nature, arising indirectly or directly from use of the information on or accessed through the Site. You acknowledge that the information is not provided as the basis of any professional advice or for transactional use. Onitus Capital, LLC shall not be responsible or liable for any investment decisions or trading or any other actions taken by you or by third parties based on information contained in this site without an advisory agreement in place.

Contact Us

If you have any questions about this privacy statement, or the practices of this site, please contact us at ksoucy@onituscapital.com.