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The GKM Funds Privacy Policy

The following is a description of the Fund's policies regarding disclosure of nonpublic personal information that you provide to the Fund or that the Fund collects from other sources. In the event that you hold shares of the Fund through a broker-dealer or other financial intermediary, the privacy policy of your financial intermediary would govern how your nonpublic personal information would be shared with nonaffiliated third parties.

  • What type of Information does the Fund collect?
  • How does the Fund use the Information it collects?
  • How does the Fund protect your Information?
  • Who does this privacy notice apply to?
  • Opt-Out Provision
  • Who should I contact if I want more information?

What type of Information does the Fund collect? The Fund collects nonpublic personal information ("Information") directly from you when you become a shareholder. For example, the Fund will retain any Information that you provide during the account opening process or after you become a shareholder and any correspondence or communications that you have with the Fund or the third parties that perform services on its behalf. The Fund also will have access to Information about your shareholder account, such as account balances and transaction activity.

How does the Fund use the Information it collects? The Fund uses all of the Information that it collects (as described above) to provide you with the financial products and services that you request and to fulfill legal and regulatory requirements. The Fund may share your Information with affiliated and unaffiliated persons, including service providers or other third parties that (i) provide business services to, or on behalf of, the Fund; (ii) facilitate the processing of transactions that you request; (iii) assist the Fund in servicing your account or offering products and services to you. The Fund may disclose your Information when we believe disclosure is required by law or to protect the Fund's rights or property. For example, we may disclose your Information for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies. The Fund also may share personal information with your designated agent or other parties that you authorize.

How does the Fund protect your Information? The Fund restricts access to your Information to those persons that need the Information to perform the services described above. The Fund also maintains physical, electronic and procedural safeguards that comply with federal standards to guard your Information.

Who does this privacy notice apply to? This privacy notice applies to individual shareholders (and former shareholders) who use the Fund primarily for personal, family or household purposes. The examples contained in this privacy notice are illustrations and are not intended to be comprehensive. This notice complies with recently enacted federal law and SEC regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.

Opt-Out Provision. It is not a policy of GKM to share nonpublic personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service client accounts or is mandated by law, there are no allowances made for clients to opt out.

Who should I contact if I want more information? Please contact the Fund at 888-456-9518 if you have any questions regarding this privacy policy.



First Western Investment Management is a registered investment advisor with the U.S. Securities and Exchange Commission (SEC). In addition, First Western Investment Management is currently registered with the states of Arizona, California, Colorado, Hawaii, Illinois, Louisiana, Massachusetts, Nevada, New York and Pennsylvania. We will register with additional states whenever our client count in any particular state meets registration requirements. Please read our full regulatory information.



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