Privacy Notice Regarding Client Privacy As Required By
Regulation S-P & Regulation S-AM

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 Miramontes Capital, LLC.

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.

Categories of Information We Disclose: We may only disclose information that we collect
in accordance with this policy. Miramontes Capital, LLC 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 Miramontes Capital, LLC, 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, other advisers;
• 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 process 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 broker-dealer providing services to you and/or Miramontes Capital, LLC;
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.

Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection
Program (ITPP) that controls reasonably foreseeable risks to customers or to the safety and
soundness of our firm from identity theft. We have developed an ITPP to adequately
identify and detect potential red-flags to prevent and mitigate identity theft.

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
Miramontes Capital, LLC’s 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 Miramontes Capital, LLC can provide
your personal financial information to non-affiliated companies.

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.

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: Isidro Z. Miramontes, Chief
Compliance Officer at Miramontes Capital, LLC, 4701 Teller Ave. Newport Beach, Newport
Beach, CA, 92660; 1-800-460-1595.

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: Miramontes Capital, LLC, 4701 Teller Ave. Newport Beach, CA, 92660; 1-800-460-1595