CLEARSHARES, LLC PRIVACY NOTICE

This Client Privacy Notice is from ClearShares, LLC, a SEC registered investment advisory firm in the business of providing investment advisory services to clients. We are committed to safeguarding the confidential information of our clients. We hold all personal information provided to our firm in strictest confidence. Except as required or permitted by law, we do not share confidential information about you with nonaffiliated third parties. In the unlikely event there were to be a change in this fundamental policy that would permit or require additional disclosures of your confidential information, we will provide written notice to you, and you will be given an opportunity to direct us as to whether such disclosure is permissible.

AN IMPORTANT NOTICE CONCERNING OUR CLIENTS' PRIVACY

CLIENT INFORMATION WE COLLECT:
In the case of individuals, we get most nonpublic personal information directly from clients or their agents at or about the time the advisory relationship is entered into. We may verify this information or get additional information from consumer reporting agencies or other sources. Such information may relate to finances, employment, or other personal characteristics, such as first and last name, address, phone number, social security number and email address, as well as accounts with us and transactions and interactions by us, with us, through us, or with others. We may also collect information about what clients have entered into, viewed on and/or downloaded from our website.

DATA SECURITY:
We restrict access to Client Information to those representatives and employees who need the information to perform their job responsibilities within our firm. We maintain agreements, as well as physical, electronic and procedural securities measures that comply with federal regulations to safeguard Client Information about you.

USE AND DISCLOSURE OF CLIENT INFORMATION:
To administer, manage and service client accounts, process transactions and provide related services to your accounts, it is necessary for us to provide access to Client Information within our firm and to non-affiliated companies such as other investment advisors, broker-dealers and custodians. We may also provide Client Information outside of our firm as permitted by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.

FORMER CLIENTS:
If the account with our firm is closed, we will continue to operate in accordance with the principles stated in the Client Privacy Notice.

REQUIREMENTS OF FEDERAL LAW:
In November 1999, Congress enacted the Gramm-Leach-Bliley Act (“GLBA”). The GLBA requires certain financial institutions, including broker-dealers and investment advisors, to protect the privacy of Customer Information. To the extent a financial institution discloses Client Information to non-affiliated third parties other than as permitted or required by law, clients must be given the opportunity and means to opt out (or prevent) such disclosure. Please note that we do not disclose Client Information to non-affiliated third parties except as permitted or required by law (e.g., disclosures to service your account or to respond to subpoenas).