PRIVACY POLICY

GreatOne Digital Holding maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information. Through this policy and its underlying procedures, GreatOne Digital Holding 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 GreatOne Digital Holding 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 to provide products or services to the client. GreatOne Digital Holding may disclose the client’s information if GreatOne Digital Holding is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with the firm, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, 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 GreatOne Digital Holding 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 adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for GreatOne Digital Holding (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

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