VIMA, LLC

                                                                               PRIVACY NOTICE

 

          VIMA, LLC (referred to as “VIMA”) maintains physical, electronic, and procedural safeguards
that comply with federal standards to protect its client’s nonpublic personal information
(“information”). Through this policy and its underlying procedures VIMA attempts to secure the
confidentiality of customer records and information and protect against anticipated threats or hazards
to the security or integrity of customer records and information.

          It is the policy of VIMA to restrict access to all current and former clients’ information (i.e.
information and records pertaining to personal background, investment objectives, financial situation,
tax information/ returns, investment holdings, account numbers, account balances, etc.) to those
employees and affiliated/nonaffiliated entities who need to know that information in order to provide
products or services to the client. VIMA may disclose the client’s information if VIMA is: (1) previously
authorized to disclose the information to individuals and/or entities not affiliated with VIMA, including,
but not limited to the client’s other professional advisors and/or service providers (i.e., attorney,
accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to
do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the
parameters of applicable federal and/or state privacy regulations. The disclosure of information
contained in any document completed by the client for processing and/or transmitted by VIMA in order
to facilitate the commencement/continuation/termination of a business relationship between the client
and a nonaffiliated third party service provider (i.e., broker0dealer, investment adviser, account
custodian, insurance company, etc.), including information contained in any document completed
and/or executed by the client for VIMA (i.e. advisory agreement, client information form, etc.), shall be
deemed as having been automatically authorized by the client with respect to the corresponding
nonaffiliated third party service provider. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent;                     this information will not be shared with any third parties. 

          VIMA permits only authorized employees and affiliates who have signed a copy of VIMA’s
Privacy Policy to have access to client information. Employees violating VIMA’s Privacy Policy will be
subject to VIMA’s disciplinary process. Additionally, whenever VIMA hires other organizations to
provide services to VIMA’s clients, VIMA will require them to sign confidentiality agreements and/or the 
Privacy Policy. Should you have any questions regarding the above, please contact Michael Mazzola,
Chief Compliance Officer.