PRIVACY POLICY

Commitment to Your Private Information:  Apex Capital Management, LLC, along with Arsement, Redd, & Morella, LLC, our CPA practice, has a long-standing policy of protecting the confidentiality and security information we collect about our clients.  We do not, and will not, share nonpublic personal information about you (“Information”) with outside third parties without your consent, except for the specific purposes described below.  This notice has been provided to you to describe the Information we may gather and the situations under which we may need to share it. 

Why We Collect and How We Use Information.  We limit the collection and use of Information within our firm to only those individuals associated or employed with us that must have Information to provide financial services to you.  Such services include maintaining your accounts, processing transaction requests, providing financial planning, financial consultation, and other services described in our Form ADV.

How We Gather Information.  We get most Information directly from you when you provide us with information from any of the following sources:

• Applications or forms (for example: name, address, social security number, birth date, assets, income, financial history)
• Transactional activity in your account (for example: trading history and account balances)
• Information services and consumer reporting sources (for example: to verify your identity or to assess your credit history)
• Other sources with your consent (for example: your insurance professional, attorney, or accountant)

How We Protect Information.  Our employees and affiliated persons are required to protect the confidentiality of Information and to comply with our stated policies.  They may access Information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services.  Employees who violate our Privacy Policy are subject to disciplinary action, up to and including termination from employment with us.  We also maintain physical, electronic, and procedural safeguards to protect information, which comply with applicable SEC, state, and federal laws.