Privacy Policy

Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand
how we protect your privacy when we collect and use information about you, and the steps that we take to
safeguard that information. This notice is provided to you on behalf of Cooper Financial Group dba “Cooper
Information We Collect: In connection with providing investment products, financial advice, or other services, we
obtain non-public personal information about you, including:
• Information we receive from you on account applications, such as your address, date of birth, Social Security
Number, occupation, financial goals, assets and income;
• Information about your transactions with us, our affiliates, or others;
• Information about your visit to our website. We store that information in web server logs, which are records
of the activities on our sites. The servers automatically capture and save the information electronically. The
information we collect in web server logs helps us administer the site, analyze its usage, protect the website
and its content from inappropriate use and improve the user’s experience.
Categories of Information We Disclose: We may only disclose information that we collect in accordance with this
policy. Cooper McManus does not sell customer lists and will not sell your name to telemarketers.
Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account at
Cooper McManus, except under the following circumstances:
• To entities that perform services for us or function on our behalf, including financial service providers, such
as a clearing broker-dealer, investment company, or insurance company, other investment advisers;
• To comply with broker-dealer firms that have regulatory requirements to supervise certain representatives’
• To third parties who perform services or marketing, client resource management or other parties to help
manage your account on our behalf;
• To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
• To our attorneys, accountants or auditors; and
• To government entities or other third parties in response to subpoenas or other legal process as required
by law or to comply with regulatory inquiries.
How We Use Information: Information may be used among companies that perform support services for us, such
as data processors, client relationship management technology, technical systems consultants and programmers, or
companies that help us market products and services to you for a number of purposes, such as:
• To protect your accounts/non-public information from unauthorized access or identity theft;
• To process your requests such as securities purchases and sales;
• To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer
providing services to you and/or Cooper McManus;
• To service your accounts, such as by issuing checks and account statements;
• To comply with Federal, State, and Self-Regulatory Organization requirements;
• To keep you informed about financial services of interest to you.
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility
information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use
of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has
been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and

(3) the consumer has not opted out. Cooper McManus does not receive information regarding marketing eligibility
from affiliates to make solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that controls
reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft. We have
developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate identity theft.
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need
to know that information to provide products or services to you and perform their respective duties. We maintain
physical, electronic, and procedural security measures to safeguard confidential client information.
Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy is
available upon request.
Departing Investment Adviser Representatives (“IARs”): Cooper McManus recognizes that your relationship
with your IAR is important. If your IAR leaves Cooper McManus to join another firm or elects to sell or transfer some
or all of his or her business, your IAR might retain copies of your personal information so that your account can
continue to be serviced or to contact you regarding your options. Subject to legal and regulatory requirements, your
personal information maintained on Cooper McManus systems and those of Cooper McManus’s service providers
may be shared with your new financial service provider. If you do not want your IAR to take your information should
he or she leave or transfer his or her business from Cooper McManus, you have the right to opt out of such disclosure.
You may opt out now or at any time in the future. If you have a joint account, Cooper McManus will treat an opt out
by any joint customer as applying to all joint customers. If you wish to exercise your right to opt out under this section,
please contact us at 1(800) 516-5333 or by mail.
Certain states have adopted a requirement for you to approve the sharing of information in advance, otherwise
known as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts, Maine, Alaska, North
Dakota or Vermont), then Cooper McManus will require your consent to share your information with unaffiliated
third parties who are not servicing your account. State requirements vary and may change without notice.
Succession Planning: In the event that the owner(s) of Cooper McManus retire, become incapacitated or perish
unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating a
business succession plan. A change in control of ownership of Cooper McManus would require your consent, as
dictated by your signed agreement with Cooper McManus, in order to continue providing services to you.
Your Right to Opt Out: Federal privacy laws give you the right to restrict some sharing of your personal financial
information. These laws balance your right to privacy with Cooper McManus’s need to provide information for
normal business purposes. You have the right to opt out of some information sharing with companies that are (1)
Part of the same corporate group as your financial company (or affiliates); or (2) Not part of the same corporate
group as your financial company (or non-affiliates). Choosing to restrict the sharing of our personal financial
information will not apply to (1) Information about you to firms that help promote and market the company's own
products or products offered under a joint agreement between two financial companies; (2) Records of your
transactions--such as your loan payments, credit card or debit card purchases, and checking and savings account
statements--to firms that provide data processing and mailing services for your company; (3) Information about you
in response to a court order; and (4) Your payment history on loans and credit cards to credit bureaus. If you opt out,
you limit the extent to which Cooper McManus can provide your personal financial information to non-affiliates.
Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy
Policy will continue to apply to you.
Complaint Notification: Please direct complaints to: Arthur Cooper at Cooper McManus, 9870 Research Drive,
Irvine, CA 92618; 1(800) 516-5333.
Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate confidential
information, we will notify you. If you have any questions concerning this Privacy Policy, please contact us at: Cooper
McManus, 9870 Research Drive, Irvine, CA 92618; 1(800) 516-5333.