Fairbanks Capital Management, Inc. (“FCM”) may collect nonpublic information to process and administer clients’ business and to ensure that we are satisfying their financial needs. This includes:

• Information provided to FCM, such as on applications, questionnaires, contracts, or other forms.
• Transactions, account balances, account history, and transactions with us, affiliates or third parties.
• Information provided by clients and their representatives.

Security Measures:

It is the policy of FCM to restrict access to nonpublic information to those employees, agents, representatives or third parties that need to know the information to provide products and services to its clients. This includes:

• Physical safeguards including restricted access to its offices and full-time staffed reception desk to check people who arrive at the office.
• Electronic safeguards including firewalls for shared drive protection, passwords for computer login for on-site computers, and limited access to the off-site computer room.
• Restricting access to client information to those required to have access in order to service client needs.
• Employee privacy compliance training.

Sharing of Nonpublic Information:

FCM does not share nonpublic information about its customers with anyone except:

• As permitted by law.
• Affiliated FCM companies, brokers, banks, agents, employees, and third parties who need to know this information in order to perform services on the client’s behalf.
• Other financial institutions with whom we have a relationship, which may include banks, attorneys, trustees, third-party administrators, registered broker/dealers, auditors, regulators, and transfer agents, in order to service client accounts.

Updated 2019