How We Collect Information About You

To deliver our services and operate effectively, we may collect information from a variety of sources:

• Applications and Agreements – Information such as your name, date of birth, Social Security number, marital status, employment details, income, assets, and investment objectives.
• Transactions and Account Activity – Balances, positions, trades, and account history that help us manage your relationship with us.
• Communications – Information you provide through phone calls, emails, meetings, or via your authorized representatives (e.g., attorneys, accountants).
• Third Parties – Data obtained from custodians, consumer reporting agencies, or other providers for identity verification, account setup, or transaction processing.
• Website and Technology – Limited technical information (IP address, browser type, device, and pages visited) collected through cookies or similar tools to improve site functionality. Cookies do not identify you personally by name or account number.

How We Use Your Information

We use the information we collect for purposes including:

• Opening, maintaining, and servicing your accounts.
• Processing transactions and ensuring accurate recordkeeping.
• Developing investment profiles and delivering tailored advisory services.
• Meeting contractual, legal, and regulatory requirements (including anti-money laundering and "know your customer" obligations).
• Internal operations, audits, and compliance monitoring.
• Improving our services and client communications.
• Evaluating and hiring personnel.
• Providing you with information about services or educational resources that may benefit you.

How We Share Your Information

TCM does not sell your information. We may share information only in limited circumstances necessary to conduct business or as required by law:

• With custodians, broker-dealers, or money managers to process transactions and administer accounts.
• With service providers who support our operations (such as IT support, data processing, printing, mailing, or secure document storage). These providers are bound by confidentiality obligations and may only use the data for the services they provide.
• For legal and regulatory purposes, including cooperation with regulators, auditors, or law enforcement.
• For joint marketing with other financial institutions, but only when we believe the product or service may benefit you. In these cases, the other party must protect your information and use it only as intended.

All service providers with whom we engage are vetted prior to engagement and reviewed at least annually to ensure ongoing compliance with regulatory privacy and security standards.

You may direct us not to share your information with non-affiliated third parties for joint marketing purposes, as explained under "How to Limit the Sharing of Information About You."

How to Limit the Sharing of Information About You

Federal law gives you the right to limit certain types of information sharing. These rights allow you to restrict:

• Affiliate sharing for everyday business purposes – Information about your creditworthiness.
• Affiliate marketing – The use of your information by our affiliates to market financial products or services to you.
• Joint marketing with nonaffiliated companies – Sharing personal information with outside companies so they can market to you.

As noted above, TCM does not currently engage in affiliate sharing or joint marketing. These opt-out categories are disclosed as required by federal law. If TCM's practices change, we will update this notice and provide you an opportunity to opt out before any new sharing begins.

State laws may provide you with additional rights regarding the disclosure and use of your information. We will comply with all applicable state-specific requirements.

You may exercise your privacy choice at any time by calling us at (877) 652-8607 or emailing Compliance@TriumphCapitalManagement.com.

Your election will remain in effect until you notify us otherwise and will apply automatically to you and all accounts you maintain with us.

State-Specific Residents – Your Privacy Rights

California Residents

If you reside in California, you may have additional rights under the California Consumer Privacy Act ("CCPA"). Subject to certain exceptions, you have the right to:

• Request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of that information, and the purpose of its use.
• Request that we delete personal information we have collected, subject to legal and regulatory requirements.
• Direct us not to sell your personal information (note: TCM does not sell client information).

Non-Discrimination – We will not discriminate against you for exercising your rights under the CCPA. This means we will not deny services, charge different prices, provide a different level of service, or suggest you will receive different treatment because you have exercised a privacy right.

You may exercise your privacy choice at any time by calling us at (877) 652-8607 or emailing Compliance@TriumphCapitalManagement.com.

Colorado Residents

If you reside in Colorado, you may have additional rights under the Colorado Privacy Act ("CPA"), which became effective July 1, 2023. Subject to certain exceptions, Colorado residents may have the right to access, correct, delete, and obtain a copy of their personal data, and to opt out of certain processing activities. To exercise these rights, please contact us using the information in the "Questions About This Policy" section below.

Other State Residents

Residents of other states (including Virginia, Connecticut, Texas, Montana, Oregon, and others that have enacted comprehensive privacy legislation) may have similar rights to access, correct, delete, or limit the use of their personal information. TCM will comply with all applicable state privacy laws. To inquire about your rights under applicable state law, please contact our Compliance Department using the contact information below.

How We Safeguard Your Information

Protecting your personal information is a responsibility TCM takes seriously. We are committed to maintaining cutting-edge protections, combining proven industry practices with ongoing enhancements to safeguard client information. We maintain physical, electronic, and procedural safeguards designed to protect your personal information.

Our safeguards include:

• Physical Security – Access to our offices, files, and servers is restricted and monitored, with secure storage for all physical records.
• Electronic Security – Client data is encrypted in transit and at rest, stored on secure servers, and protected through firewalls, intrusion detection, and vulnerability management systems.
• Access Controls – Employee access is role-based and granted only on a need-to-know basis, supported by multi-factor authentication, automatic log-off, and session timeouts.
• Vendor Oversight – All third-party service providers with access to client information are vetted before engagement, contractually bound by confidentiality obligations, and reviewed annually to ensure compliance with Triumph's security standards.
• Training & Awareness – Employees receive regular training on privacy, cybersecurity, phishing awareness, and their duty to protect client data.
• Monitoring & Testing – Our systems are continuously monitored, and periodic audits, penetration tests, and reviews are performed to assess and strengthen safeguards.
• Business Continuity – Redundant systems and secure backups ensure critical data and operations remain protected and recoverable in the event of a disruption.
• Incident Response and Breach Notification – TCM maintains a written incident response program designed to detect, respond to, and recover from unauthorized access to or use of client personal information. In the event of a security breach involving your nonpublic personal information, TCM will notify affected clients within 30 days of discovering the breach, consistent with the requirements of amended Regulation S-P (17 CFR Part 248). Notifications will describe the nature of the incident, the information affected, and the steps being taken to address the breach and protect your information going forward.

Together, these measures are designed to ensure that your information remains confidential, secure, and protected in accordance with applicable laws and regulations.

Identity Theft

Identity theft occurs when someone uses your personal information — such as your name, Social Security number, or account details — without your consent to commit fraud. Protecting against identity theft is an important part of our commitment to safeguarding client information.

You can also take steps to protect yourself. Key reminders include:

• TCM will never request your account number, login credentials, or Social Security number through an unsolicited or non-secure email.
• Do not respond to emails claiming an account will be closed unless you provide billing or personal details — these are fraudulent attempts to obtain your information.
• Always confirm you are entering personal information over a secure connection ("https://").
• Shred documents containing sensitive information before discarding.
• Review your credit report regularly for unauthorized activity and safeguard your PINs and personal data.

If you believe you are a victim of identity theft, contact the fraud departments of the three major credit bureaus and notify TCM immediately so we can take steps to protect your accounts.

Cookie Policy

When you visit our website, we may use cookies or similar technologies to improve site performance, maintain session continuity, and provide a more tailored browsing experience. These tools collect limited technical information such as IP address, browser type, device, and pages visited. Cookies do not identify you by name or account number.

You can control or limit cookies in several ways:

• Browser Settings – Most browsers allow you to block or delete cookies through their settings menu. Instructions are typically located under the headings "Privacy" or "Security."
• Private Browsing – You may use "private" or "incognito" modes to limit cookie storage during a session.
• Cookie Preferences – Some browsers let you choose which types of cookies (e.g., necessary vs. marketing) you accept.
• Third-Party Tools – Cookie-blocking extensions or plug-ins can provide additional controls.

Please note that disabling or blocking cookies may affect the functionality of certain website features and limit your ability to access some online services.

Third-Party Websites

Our website may provide links to other Internet sites controlled by third parties not affiliated with us. Such websites may have privacy statements that differ from this privacy statement. We are not responsible for the content or practices of such third-party websites. You should review the privacy statement of any third-party website you access from our website.

Minors

Our website does not seek to collect personal information from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal information to us via our website.

Keeping You Informed

We will notify you of any material changes to this Privacy Policy. A current copy will also be delivered to you periodically in accordance with applicable regulatory requirements. Continued use of our services after changes are communicated will signify your acceptance of the revised policy.

Updating Your Information with Us

Maintaining accurate records is important. If you are a client and wish to correct, update, or confirm your personal or account information, please contact us at info@TriumphCapitalManagement.com or call (877) 652-8607. We will review your request and update our records as appropriate.

Unsubscribing from Marketing Emails

To stop receiving marketing emails from TCM, use the "unsubscribe" link included in the footer of our emails.

SMS Consent Disclosure

If you provide your mobile phone number and consent to receive text messages, Triumph Capital Management may communicate with you via SMS for purposes such as appointment reminders, account notifications, or service-related communications.

Message frequency may vary. Message and data rates may apply depending on your mobile carrier plan.

You may opt out of receiving SMS communications at any time by replying STOP to any message.

Mobile phone numbers and SMS consent information will not be sold, shared, or disclosed to third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties except as necessary to provide the requested messaging service or as required by law.

Questions About This Policy

If you have any questions or need clarification regarding this Privacy Policy, please contact our Compliance Department:

Additional information about Triumph Capital Management is available on the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching our CRD number 282814.