"Personal information" is any kind of information that allows us to identify you or your household, directly or indirectly, such as your name, contact details, or address. We may collect and process the following personal information about you when you visit the Claro Portal or when you engage with us as an advisory client:

• Contact information, such as your name, mailing address, email addresses, and telephone numbers;
• Identifiers, such as your signature, date of birth, gender, driver's license, passport, or other government identification and numbers;
• Professional or employment information, such as your job title, employment status, and place of work;
• Background information, such as information revealed in know-your-customer (KYC) and anti-money laundering (AML) due diligence, investor accreditation and consents;
• Financial information, such as information relating to your assets, income, net worth, amounts and types of investments, capital account balances, capital commitments, capital contributions, account data, other investment participation information, funds transfer information, beneficiaries, positions, percentages of fund, share or option numbers and values, vesting information, investment history, transaction information, tax information, or billing information;
• Internet or other electronic network activity information, such as your internet protocol (IP) address, login data, unique device identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile device carrier and other technology on the devices you use to access the Claro Portal; as well as usage information, such as information about how you use the Claro Portal and our products and services, referring/exit web pages, date/time stamps, error logs, and the frequency of your use of the Claro Portal; and
• Marketing and communications information, such as your preferences in receiving marketing communications from us, or information that we exchange when you contact us with questions, feedback or otherwise; and
• Notes, summaries, and other content generated through your interactions with Claire by Claro™ or other AI-powered tools we use to support your advisor relationship, as described further in Section V below.

We also collect, use and share aggregated information such as behavioral, statistical or demographic data for any purpose. This information could be derived from your personal information but will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific Claro Portal feature. However, if we combine or connect information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this Privacy Policy.

Where you choose to enable biometric login (such as Face ID) on our mobile application, that authentication takes place entirely on your device using controls provided by your device manufacturer. Claro does not receive, transmit, or store your biometric data.

We collect personal information from you via the following:

A. Personal Information You Provide to Us

• Forms that you complete (or which are completed by your authorized representatives on your behalf) on the Claro Portal or otherwise;
• Your transactions with us or others; and
• Your correspondence and interactions with us, including by letter, email and telephone.

B. Personal Information Collected from Third Parties and Service Providers

We may collect personal information about you from third parties and service providers, such as business partners or vendors, or from publicly available information. The conditions under which we may obtain such information are governed by the third-party source.

C. Information Collected Automatically

We may automatically collect certain information about the devices you use to access the Claro Portal, and/or information on how you interact with the Claro Portal, through tools, scripts, software, cookies, web server logs, utilities and other similar tracking technologies. This information may include the IP address used to connect your computer to the Internet; computer and connection information such as your browser type and version; operating system and platform; screen resolution; confirmation when you open email that we send you; and the URLs which lead you to and around the Claro Portal including the pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, and the date, time and duration of access. We may use third-party service providers to help collect and analyze this information. We reserve the right, but are not obligated, to access, collect, and archive this information.

1. Cookies and Other Data Collection Technologies

"Cookies" are a feature of web browser software that allows web servers to recognize the computer used to access a website. They are small text files that are stored by a user's web browser on the user's hard drive. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies last longer and are used to recognize your computer when you return to the Claro Portal.

"Software Development Kits" or "SDKs," are used to incorporate third-party computer code into our Claro Portal and allow our third-party service providers or advertising partners to collect data directly from our Claro Portal for a variety of purposes, including to provide us with analytics regarding use of the Claro Portal, to integrate with social media, add features or functionality, or to facilitate online advertising of our services and products to you at our direction.

Web server logs are files that store the activity on a certain website. Information gathered through cookies and web server logs may include the date and time of visits, pages viewed, time spent on the Claro Portal, and websites visited just before and just after. We use cookies and web server logs to manage your login session, help you move between pages in a smooth and secure manner, and to gather information about browsing activities of users of the Claro Portal in order to continually improve it. We do not link cookies to personally identifiable information.

Most web browsers automatically accept cookies. You can change your browser settings to notify you of cookies being set or updated, and to block cookies. If you turn off all cookies, some features of the Claro Portal may not be available to you or may not function as intended. To learn more about managing cookies, you can visit www.allaboutcookies.org .

A web beacon is a web page element (such as a clear gif, pixel tag or single-pixel gif) that may be embedded into our Claro Portal or email messages, newsletters, and other electronic communication. They help us determine whether a message has been opened and to analyze and personalize our interactions with you. Instructions on how to unsubscribe are included in each email.

We use, or may use, the following categories of cookies on the Claro Portal:

• Essential cookies: necessary to provide the services available through the Claro Portal and some of its features.
• Performance, functionality and customization cookies: improve performance and functionality but are not essential to use.
• Analytics cookies: help us understand how you use our services and customize the Claro Portal and our services for you.
• Targeting cookies: record your visit, the pages you have visited, and the links you have followed; recognize you as a previous visitor and track your activity on the Claro Portal as well as other websites you visit.

2. "Do Not Track" Browser Settings

We do not currently use technology that recognizes "do not track" signals from your web browser. To find out more about "do not track," please visit allaboutdnt.com .

We will only use your personal information when and how the law allows. Any of the personal information we collect about you may be used in one of the following ways:

• Where the processing is necessary for us to enter into or perform a contract with you, or to take steps at your request prior to entering into a contract — for example, to provide information you have requested or to respond to your questions;
• For our everyday business purposes, such as to process your transactions, maintain or service your account(s), communicate with you, pay funds, manage records, respond to court orders and legal investigations, and administer and provide services to you, including onboarding, marketing, research and due diligence;
• Where necessary for the purposes of the Company's legitimate interests, including to operate and facilitate our business and services, communicate with you, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain the Company's core records, protect the Company's rights and interests, ensure the security of the Company's assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, and enforce our terms and conditions;
• Where required by applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions; and
• Where the processing is necessary for the establishment, exercise or defense of legal claims.

In some circumstances, we may also process your personal information where we have received your consent — for example, depending on where you are located, to send you marketing materials or to place cookies or similar tracking technologies on your devices. Where processing is based on your consent, you have the right to withdraw that consent at any time.

We are committed to maintaining the confidentiality, integrity and security of your personal information and take precautions to protect such information. These precautions include physical, electronic, and procedural safeguards and procedures designed to maintain and secure your personal information from inappropriate disclosure in accordance with applicable laws and regulations.

Our policies require that access to personal information be restricted to those employees and agents of the Company who need to know that information to provide the Company's products or services. We may disclose such information to our service providers (including financial, technical, marketing and professional service providers and consultants) and financial institutions that provide services to the Company. We require such third-party service providers and financial institutions to protect the confidentiality of your personal information and to use the information only for the purposes for which it is disclosed to them.

Claro may use artificial intelligence–powered tools, including Claire by Claro™ AI Chief of Staff and other tools we develop internally, to support the services we provide to you — for example, to help your advisor prepare for meetings, organize notes, or manage administrative tasks. These tools are reviewed and approved internally before use. We do not use your personal information to train third-party AI models, and outputs generated by these tools are always reviewed by a (human) member of our team before being relied upon. Where an AI tool is used to record or transcribe a conversation with you, we will tell you in advance and ask for your consent.

We do not sell personal information obtained about you to any third parties, and have not done so in the twelve (12) months preceding the effective date of this policy.

We do not disclose any personal information to anyone other than our affiliates, service providers and relevant counterparties without your consent, or as required by applicable law or regulation. This means that we may disclose your personal information to other third parties, including:

• Any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over the Company or its affiliates, if (i) the Company determines that such disclosure is necessary or advisable pursuant to or in connection with any U.S. federal, state or local, or non-U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law and the USA PATRIOT Act and (ii) such disclosure is not otherwise prohibited by law, rule, regulation, executive order or policy;
• Service providers who, on our behalf or for your benefit, provide services to Claro;
• Employees and service providers who have a reasonable need to know the information in connection with the conduct of Claro's business;
• Persons acting in a fiduciary or representative capacity on behalf of an investor, such as an IRA custodian or Trustee of a grantor trust; and
• Certain other persons to the extent authorized by you.

On all occasions when it is necessary for us to share your personal information with other parties, we will require that such information only be used for the limited purpose for which it is shared and will advise such third parties not to further share your information with others except to fulfill that limited purpose.

Consistent with our Privacy Notice , we do not disclose your personal information to non-affiliated third parties for marketing purposes, and, where required under applicable state law (including Massachusetts), we obtain your opt-in consent before sharing non-public personal information with non-affiliated third parties for purposes beyond servicing your account.

We may aggregate survey responses for publication. However, this will not include any non-public personal information or any information identifiable to a particular Claro Portal user.

If Claro sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger, restructuring or business transfer, you agree that Claro may transfer your personal information to a third party as part of that due diligence and transaction process.

Please see our Privacy Notice for additional information about how your information may be shared.

We may send you e-mail communications from time to time with information that may be useful to you, including information about our products and services. Our email communications will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from us.

We provide additional information about Claro's products and services on our social media sites such as LinkedIn and Facebook. Information that you share on these social media sites may be accessible to other participants and is subject to the privacy policies and terms of use of the respective social media site, as discussed below in Section X.

We will retain your personal information only for as long as we deem it necessary for the purposes set out in this Privacy Policy, or as long as we are legally required or permitted to do so. Under certain circumstances, you may have the right to have your personal information erased.

When deciding how long to retain your personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, and the purposes for which we process your personal information described above. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

The Claro Portal may contain links to third-party websites, products and services. These third-party websites and services have separate and independent privacy policies, which we encourage you to read. We have no responsibility or liability for the content and activities of such linked sites. However, we want to protect the integrity of our Claro Portal and thus welcome any feedback you may have about third-party sites we link to.

The Claro Portal is not directed toward children under the age of 18. We do not promote our products or services online to minors, and we do not intentionally collect any personally identifiable information from any person under 18. If we become aware of having collected personal information from children under the age of 18 without valid consent from their respective parents or guardians, we will delete it as soon as practicable.

You are not required to supply any of the personal information that we may request, except where such information is necessary for the performance of (or to enter into) a contract with you or is otherwise required by applicable law. However, failure to do so may result in our being unable to accept your business or provide services to you. We will make reasonable efforts to ensure that all information that we hold about you is accurate, complete and up to date. You can help in this regard by promptly notifying us or logging into your account and updating your personal information if it changes.

We may update this Privacy Policy periodically, without prior notice, so please review it frequently. If we decide to change our Privacy Policy, we will post those changes on the Claro Portal so that you are aware of what kinds of personal information we collect, use, share and otherwise process. If we make material changes to this Privacy Policy, we will notify you on the Claro Portal, update the effective date above, and provide you with notice as required by applicable law.

Individuals in California and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal information; (ii) restrict or object to the processing of their personal information; (iii) obtain a copy of their personal information in a portable format; and (iv) opt out of the sale or sharing of their personal information. We are open to dialogue to resolve issues short of formal disputes. If your concerns cannot be resolved, we can enter into appropriate third-party neutral dispute resolution. If you need to reach us about a privacy or data protection issue, please contact us using the details below.

If you wish to exercise any of these rights, please email compliance@claroadvisors.com or call us at (800) 604-2838 . The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your personal information only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.

The California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), prohibits covered businesses from discriminating against you for exercising applicable rights.

If you make a request related to personal information about you, we will need to verify your identity and California residency. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

If you are a California resident, you have the right to request information about how we share certain categories of Personal Information with third parties. California law gives you the right to send us a request at the address below to receive the following information:

• Categories of information we disclose to third parties for their direct marketing purposes during the preceding calendar year; and
• Names and addresses of the third parties that received that information; and, if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.

If you have any questions or concerns about this Privacy Policy, please contact us at:

Claro Advisors Inc.
Attn: Privacy
100 High Street, Suite 950
Boston, MA 02110
Toll Free: (800) 604-2838
Email: compliance@claroadvisors.com