Privacy

Pacific Oak Capital Advisors LLC and Pacific Oak Capital Markets Group LLC

GRAMM-LEACH-BLILEY ACT PRIVACY NOTICE

Pacific Oak Capital Advisors LLC and Pacific Oak Capital Markets Group LLC are providing this notice and acting on behalf the offerings they advise and/or distribute.

Categories of Non-Public Information We Collect

The type of information we collect from you (“non-public information” or “NPI”) depends on the product or service you have with us. NPI may include:

Information you provide to us, such as application information, contact information, investment information, income information, Social Security number, date of birth, citizenship, and financial account balances, as well as information you provide to us via online forms.

Information about your transactions with us and our affiliates, such as transaction and investment history and account balances, as well as information about your interactions with our websites.

How We Collect Non-Public Information

We collect your personal information, for example, when you:

We also collect your personal information from others, such as: broker-dealers, financial advisors, IRA and other custodians and other similar entities; our affiliates; and other companies.

Categories of Non-Public Information That We Disclose

We may disclose any of the categories of NPI that we collect to non-affiliated companies as permitted by law and for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations, or report to credit bureaus, as well as to non-affiliated third parties who perform services for us or functions on our behalf. This includes third parties that perform marketing services on our behalf.

We may also disclose any of the categories of NPI that we collect to affiliates so that they may market products and services and to non-affiliated third parties for those third parties’ own marketing purposes.

How We Use and Disclose Non-Public Information That We Collect

The Pacific Oak network of affiliated companies and unaffiliated third-party service providers work together to maintain an efficient and effective network of products and services. We collect, use and share NPI about you in order to make you aware of our products and services, to provide you with products and services that you request, and to comply with legal and regulatory requirements.

By sharing your NPI with our companies and service providers, we are better able to serve your investment needs and also suggest services, products, or educational materials that may be of interest to you.

We may use the NPI that we collect in the following ways:

For example, we may seek to determine the most common ZIP code among the users of our websites and customers and disclose this information to other parties.

Parties to Whom We Disclose NPI

In addition to the types of third parties referenced under “Categories of Non-Public Information That We Disclose,” we may disclose NPI about you to the following types of third parties:

Your Right to Opt-Out of Disclosure of Non-Public Information to certain Non-affiliated Third Parties

If you prefer that we not disclose NPI about you to non-affiliated companies in connection with the marketing of those non-affiliated companies’ products and services, you may opt out of these disclosures. You may direct us not to make such disclosures (except where such disclosures are permitted by law). If you wish to opt out of disclosures of NPI to non-affiliated third parties for marketing purposes, you may send the enclosed form to:

Pacific Oak – Privacy Notice
3200 Park Center Drive, Suite 600
Costa Mesa, CA 92626

How We Protect Your Information:

We maintain administrative, electronic, and technical safeguards that comply with federal regulations and that are designed to protect the confidentiality and security of your NPI. We also restrict access to NPI to those employees who have a legitimate business need for the information.

Notification of Changes to Our Privacy Policy:

If we decide to change our privacy policy, we will provide a new notice that reflects our new policy. Additionally, we will provide a new opt out notice and an opportunity to opt out of disclosures of NPI to non-affiliated third parties.

Former Customers

NPI of former customers will be treated as described in this policy.

NOTICE REGARDING PRIVACY OF FINANCIAL INFORMATION OPT-OUT FORM

Instructions: Complete and return this form ONLY if you want to opt-out of the disclosure described in the privacy notice.

Name: ___________________________________________________________________________

Account Number(s): ________________________________________________________________

Signature: ________________________________________________________________________

Printed Name: ____________________________________________________________________

Telephone Number: ________________________________________________________________

Date: ___________________________________________________________________________

IF THIS FORM IS COMPLETED, PLEASE RETURN IT TO THE FOLLOWING ADDRESS:

Pacific Oak – Privacy Notice
3200 Park Center Drive, Suite 600
Costa Mesa, CA 92626