PRIVACY POLICY

Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information

ALPHYN CAPITAL MANAGEMENT LLC

100 DUFFY AVENUE STE 510 HICKSVILLE, NY 11801

516-500-1033 - SAMER@ALPHYNCAP.COM

TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of Income, and Credit Card Numbers or Information. When you are no longer our customer, we may continue to share your information only as described in this notice.

PARTIES TO WHOM WE DISCLOSE

INFORMATION

All Investment Advisers may need to share personal information to run their everyday business. In the

section below, we list the reasons that we may share your personal information:

Ø For everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus;

Ø For our marketing – to offer our products and

services to you;

Ø For joint marketing with other financial companies;

ACML does NOT engage in this activity.

Ø For our affiliates’ everyday business purposes –

information about your transactions and

experiences and information about your

creditworthiness; ACML does NOT engage in

this activity.

Ø For non-affiliates to market to you. ACML does

NOT engage in this activity

If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing

PROTECTING CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building.

FEDERAL & STATE LAW ALLOWS YOU TO LIMIT SHARING – OPTING OUT

Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for non-affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or

non-affiliates who use your information to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.

DEFINITIONS:

Affiliates – companies related by

common ownership or control. They can be financial and non-financial companies;

Non-affiliates –

companies not related by common ownership or

control. They can be financial and non-financial

companies;

Joint marketing – a formal agreement

between non-affiliated financial companies that

together market financial products or services to you.