PRIVACY POLICY OF MORTON CAPITAL MANAGEMENT, LLC

As a registered investment adviser, Morton Capital Management, LLC complies with SEC Regulation S-P, which requires registered advisers to adopt policies and procedures to protect the “nonpublic personal information” of clients and to disclose to such clients the policies and procedures for protecting that information. Morton Capital Management (MCM) is committed to protecting the privacy of its clients. All information provided to MCM is held in the strictest of confidence. It is MCM’s policy not to release non-public personal information about our clients, except as permitted by law or at the specific request of the client.


Information that MCM Collects

MCM collects non-public personal information (such as date of birth, address, level of income, etc.) about its clients from: (1) applications, questionnaires and other forms completed by the client; (2) transactions (such as purchases, sales, etc.) with MCM and with outside custodians; and (3) other outside sources such as accountants or lawyers.

Parties To Whom We May Disclose Information

As a matter of policy, MCM does not disclose the nonpublic personal information we collect about our clients to anyone except as permitted by law or with the client’s prior consent to certain affiliated and non-affiliated third parties. MCM may provide information to: (1) “financial service providers,” such as another investment adviser, a broker-dealer, and outside custodians (such as Charles Schwab & Co.) when required to maintain or service your account; (2) our auditors and legal counsel; (3) a third-party data reconciliation service and (4) MCM’s Independent Contractors who serve as your Advisor. This disclosure is necessary for the everyday conduct of our business.

With your prior consent or at your request, we may also share information with nonaffiliated third parties such as estate planning attorneys, insurance agents, and accountants. We will only share information with these parties for the specific purpose of providing you with information or services you may be interested in as part of our comprehensive financial planning services. We may also disclose your information without prior consent if required or permitted by law, such as to a regulatory authority, or to respond to a subpoena, court order, or judicial process.

In all such cases, we will provide third parties with only the information necessary to carry out their assigned responsibilities. If any non-public personal information is released by MCM to non-affiliated third parties, we require those parties to hold the information in the strictest of confidence.

We Protect Your Information

MCM has implemented specific policies and procedures to ensure the safety of your personal information. Employees are trained to maintain confidentiality of all client information. MCM’s privacy safeguards apply to former clients as well as current clients equally. MCM will notify clients of our privacy policy at the inception of our business relationship and annually thereafter.

Confidentiality and Security

We restrict access to non-public personal information about you to those employees who need to know that information to provide financial products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information.

If you have any questions on the Privacy Policy of Morton Capital Management, please contact:

Eric Selter, Esq.

Chief Compliance Officer

Email: clientservices@mortoncapital.com

Phone: (818) 222-4727