Privacy Policy

Our Commitment to Your Privacy

Mercer Island Capital Management, LLC^® (“MICap,” “the Firm,” “we,” or “our”) is committed to safeguarding the confidential information of its clients. We collect nonpublic personal information in order to open and administer client accounts and provide advice, and we hold that information in the strictest confidence.

We have adopted these practices to protect client nonpublic personal information and to align with the privacy and safeguarding standards of Regulation S-P, the FTC Safeguards Rule, and WAC 460-24A-200(1)(bb). The Firm adopts these standards as a matter of policy; this does not represent that the Firm is an SEC registrant.

Information We Collect

We collect information from applications and forms, discussions, questionnaires, tax returns, and estate-planning documents, and from information about client transactions, in order to open and administer client accounts and provide advice.

Information Sharing and Disclosure

The Firm does not sell client information. Nonpublic personal information is treated as confidential and may be disclosed only:

• to employees in connection with the Firm’s business;
• to an affiliate, which may use it only to the same extent as the Firm; or
• to nonaffiliated third parties under a contract restricting use to the authorized service (custodial, brokerage, legal, and similar services).

We limit access to those with a business need; require confidentiality from nonaffiliated third parties that require access (such as custodians, consultants, and auditors); and maintain a secure office and computer environment. The Firm has no joint-marketing arrangements that share client information.

Your Right to Limit Disclosure

Clients may direct the Firm not to make disclosures to nonaffiliated third parties (other than as required by law) by contacting the Firm using the information below. We provide advance notice of any material change in our information-sharing practices, with an opportunity to opt out.

How We Protect Your Information

Employees protect client data and files at all times; client records are stored only in designated locations; third-party tools may not be used with client records without Firm approval; lost or stolen devices are reported immediately; devices are encrypted, password- or biometric-locked, and patched; access is role-based and segregated; and our security measures are tested at least annually.

Annual Notice and Changes to This Policy

The Firm’s Chief Compliance Officer reviews this policy at least annually, provides privacy notices initially and annually, and requires written contracts and appropriate safeguards from service providers. We will notify you of any material change in our information-sharing practices as described above.

Questions

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

This notice is available upon request and is posted at www.micap360.com.

Additional firm information is available in our Form ADV on the Investment Adviser Public Disclosure website at adviserinfo.sec.gov.