Privacy Policy

Policy

As a registered investment adviser, Grass Capital must comply with SEC Regulation S-P (or other applicable regulations), which requires registered advisers to adopt policies and procedures to protect the "nonpublic personal information" of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information.

Grass Capital must also comply with state financial privacy acts in those states where Grass Capital conducts business.

Procedure

Grass Capital has adopted various procedures to implement the firm's policy and conducts reviews to monitor and ensure the firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Non-Disclosure of Client Information

Grass Capital maintains safeguards to comply with federal and state standards to guard each client's nonpublic personal information ("NPI"). Grass Capital does not share any NPI with any nonaffiliated third parties, except in the following circumstances:

• As necessary to provide the service that the client has requested or authorized, or to maintain and service the client's account;
• As required by regulatory authorities or law enforcement officials who have jurisdiction over Grass Capital, or as otherwise required by any applicable law;
• As necessary for broker dealers to supervise registered representatives that are also investment adviser representatives of Grass Capital; and
• To the extent reasonably necessary to prevent fraud and unauthorized transactions.

Employees are prohibited, either during or after termination of their employment, from disclosing NPI to any person or entity outside Grass Capital, including family members, except under the circumstances described above. An employee is permitted to disclose NPI only to such other employees who need to have access to such information to deliver our services to the client.

Security of Client Information

Grass Capital restricts access to NPI to those employees who need to know such information to provide services to our clients.

Any employee who is authorized to have access to NPI is required to keep such information in a secure compartment or receptacle on a daily basis as of the close of business each day. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving NPI, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.

Privacy Notices

Grass Capital will provide each natural person client with initial notice of the firm's current policy when the client relationship is established. Grass Capital shall also provide each such client with a new notice of the firm’s current privacy policies at least annually. If, at any time, Grass Capital adopts material changes to its privacy policies, the firm shall provide each such client with a revised notice reflecting the new privacy policies.

Former Clients

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Email Marketing

Grass Capital will comply with applicable state privacy laws and automated opt-out opportunities for existing and prospective advisory clients.

Review

Grass Capital has adopted a review procedure that is reasonably designed to implement the Firm’s procedures and can be summarized as follows:

• The Grass Capital CCO, or other designated officer, will conduct a review of applicable state laws on an annual basis to confirm there has been not changes made that require a change in policy or disclosures. In the event a material policy change occurs, Grass Capital will distribute an appropriate notice to clients.

The Firm will distribute its privacy policy to all clients of the firm via letter, or by email if email correspondence of this type is agreeable as a substitute for physical notices, on an annual basis.