Privacy Policy (Regulation S-P)

Effective Date: December 23, 2025

Prime Advantage Capital, Inc. ("the Company") prioritizes protecting non-public personal information (NPI) of clients and potential clients under the Gramm-Leach-Bliley Act (GLBA) and Regulation S-P. This policy applies to current and former clients' NPI collected during advisory activities.

Responsibility

The Chief Compliance Officer (CCO) oversees policies to safeguard NPI. All Associated Persons must:

Protect client NPI.
Share NPI only consistent with this Policy and Privacy Notice.
Limit access as specified.
Not sell NPI.

Violations follow Company disciplinary procedures. Questions on NPI handling go to the CCO.

Information Practices

We collect, use, and retain NPI only as needed for business, services, or client opportunities. NPI includes name, address, phone, SSN/TIN, DOB, employment, income, net worth—from account documents, agreements, custodians, or representatives (e.g., attorneys, accountants).

Permitted Disclosures (Exceptions):

To effect, administer, or enforce client-authorized transactions or services.
With service providers (e.g., attorneys, auditors, brokers, custodians) bound by confidentiality; we ensure they maintain safeguards.
For processing/servicing: Carry out transactions, maintain accounts, provide confirmations/statements.
As permitted/required by law (e.g., subpoenas, fraud probes, audits, public records).

Disclosure to Affiliated Third Parties

We may share NPI with affiliates for business purposes, disclosing types and categories in the Privacy Notice.

Privacy Notice Delivery

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Initial: Provided upon establishing client relationship (e.g., agreement execution).
Annual: Sent to existing clients; evidence maintained in records.
Revised: If practices change, we amend and distribute promptly.

For joint accounts, one notice satisfies requirements.

Security

We do not share NPI with non-affiliates unless exempted. No opt-out is needed currently; if practices change, we'll implement opt-out and notify clients.