M3SIXTY CAPITAL, LLC - PRIVACY POLICY 

As general policy, M3Sixty will not disclose personal financial information about any client to non-affiliated third parties except as necessary to establish and manage the client’s account(s) or as required by law.  In these situations, personal financial information about a client may be provided to the custodian maintaining these accounts.

In addition, M3Sixty restricts access to clients’ non-personal financial information to those employees who need to know such information in order to provide products or services to clients. M3Sixty maintains physical, electronic, and procedural safeguards that comply with federal standards to guard each client’s personal financial information.  Such safeguards include, among other things, restricting information contained in any client documentation supporting the written agreement only to staff members that are deemed access persons per the firms Code of Ethics or such other persons as the CCO deems as needing to know the information.  

A copy of client personal financial information is maintained in M3Sixty’s central files and is secured (locked) after normal business hours.  Electronic access to client personal financial information is restricted to the client’s account manager handling the account through M3Sixty’s local area network (LAN). Electronic LAN access is also available to the manager’s supervisor and M3Sixty’s CCO.

On a periodic basis (no less than annually), the CCO will test M3Sixty’s systems for safeguarding customer non-public information. This shall include, but is not limited, testing firewalls and password security. The CCO is responsible for ensuring that passwords are changed immediately when persons with access to client information leave the firm. 

In addition, the CCO is responsible for ensuring that any new software or services outsourced to third-party vendors does not jeopardize privacy of client information. The results of this process will be reviewed and included in the annual review.