Paradigm Capital Management

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Paradigm Capital Management, Inc.
Privacy Policy

The Information We Collect About You
You typically provide personal information when you complete our account application and when you request a transaction that involves Paradigm or one of our affiliated companies. This information may include:

Name
Social security or taxpayer identification number
Assets
Income
Account balance
Investment objectives and activity
Accounts at other institutions

How We Handle Your Personal Information
We do not sell information about current or former clients or their accounts to third parties. Nor do we share such information, except when needed to complete transactions at your request or to make you aware of related financial products and services that we offer. Here are the details:

• In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information to companies or individuals that are not affiliated with us. For example, if you ask to transfer assets from another financial institution to us, we will need to provide certain information about you to that company to complete the transaction.
• In order to alert you to other financial products and services that we offer, we may share your information within our affiliated companies. This would include for example, sharing your information within Paradigm to make you aware of PCM Partners L.P. or arranging the safekeeping of your cash and securities with our affiliated qualified custodian, C.L. King & Associates, Inc.
• In certain instances, we may contract with non-affiliated companies to perform services for us (such as independent auditors or non-affiliated broker-dealers for execution of trades). Where necessary, we will disclose information we have about you to these third parties. In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. And, we require these third parties to treat your private information with the same high degree of confidentiality that we do.
• Finally, we will release information about you if you direct us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to protect your account from fraud).

How We Safeguard Your Information
We restrict access to information about you to our employees who need to know the information to provide products and services to you. We maintain strict physical, electronic and procedural safeguards to protect your personal information.

What You Can Do
For your protection, we recommend that you do not provide your account information to anyone. If you become aware of any suspicious activity relating to your account, please contact us immediately.

We Will Keep You Informed
As required by financial law, we will notify you of our privacy policy annually. We reserve the right to modify this policy at any time, but rest assured that if we do change it, we will tell you promptly.

Our Commitment To You
As a Paradigm investor, you have entrusted to our care not only your hard-earned money but your personal and financial data as well. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interest.

Because your personal and financial data is your private information, we hold ourselves to the highest standards in its safekeeping and use. This means that we do not sell client information to anyone. Instead, your information is used primarily to complete transactions that you request or to make you aware of other financial products and services that we offer.