Privacy Notice

FACTS: WHAT DOES NORTHERN CAPITAL MANAGEMENT, INC. AND NORTHERN CAPITAL RETIREMENT SERVICES, INC. DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the
right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with
us. This information can include:

• Social security number and date of birth

• Address, email address, and phone number

• Account numbers and account balances

How?

All financial companies need to share clients' personal information to run their everyday business. In the
section below, we list the reasons financial companies can share their clients' personal information; the
reasons Northern Capital Management, Inc. and Northern Capital Retirement Services, Inc. (collectively
“Northern Capital”) chooses to share; and whether you can limit this sharing.

To limit our sharing

• Call 800.826.9803 —our menu will prompt you through your choice(s) or

• Email invest@northernwelcome.com or fill out the form below

• If you have previously notified us that you do not wish to have your information shared, that request

  remains in effect until you notify us otherwise. You do not need to request annually.

Please note: If you are a new customer, we can begin sharing your information from the date we send 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.

Questions?

Call 800.826.9803 or go to our website at www.northernwelcome.com

Who we are

Who is providing this notice? Northern Capital Management, Inc. and Northern Capital Retirement
Services, Inc. (collectively “Northern Capital”)

What we do

How does Northern Capital protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These
measures include computer safeguards and secured files and buildings.
Access to information is limited to authorized individuals who are
trained to safeguard your personal information.

How does Northern Capital collect my personal information? We collect your personal information, for example, when you:

• Seek financial advice or financial planning

• Complete an application to open an account

• Execute a Financial Advisory Agreement

• Make deposits and withdrawals

Why can’t I limit all sharing? Federal law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes—information about your creditworthiness

• Affiliates from using your information to market to you

• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account, unless you instruct us otherwise.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Northern Capital Management, Inc.

• Northern Capital Retirement Services, Inc.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Northern Capital does not share with nonaffiliates.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Northern Capital does not jointly market.