Privacy Policy

Zurich Awes Financial Management, LLC (“ZAFM” or the “Firm”) has adopted this privacy policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information.

Information We Collect: We collect certain nonpublic information about you (“Customer Information”). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:

• Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
• Identifying information such as your name, age, address, social security number, etc.
• Information about your transactions with us, or others (e.g. broker/dealers, clearing firms, or other chosen investment sponsors).
• Information we receive from consumer reporting agencies (e.g. credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill a service request.

Security of Your Information: We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

Information We Disclose: We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.

We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited from using or sharing the information for any other purpose. If you decide at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time.

We may use artificial intelligence as part of our investment management and planning processes: We may use certain artificial intelligence (“AI”) technologies, machine-learning models, and automated analytical tools in the course of providing advisory services and operating our business. These tools may assist with tasks such as data analysis, portfolio construction support, risk monitoring, market research, client service workflows, and internal operational functions. AI tools are used to enhance our capabilities; they do not replace the fiduciary judgment of our advisory personnel, who remain responsible for all investment recommendations and decisions.

Information Shared With AI Tools

In operating these tools, our firm may provide limited client information to third-party AI service providers. Any client information shared with such providers is restricted to what is reasonably necessary for the tool’s intended function. We take commercially reasonable steps to ensure that any third-party AI providers maintain appropriate confidentiality, cybersecurity, and data-use controls consistent with applicable privacy laws and regulatory requirements. We do not authorize AI service providers to use client information for their own marketing, training, or unrelated commercial purposes.

How Client Information Is Used

Client information processed by AI tools may be used for purposes including, but not limited to:

• Portfolio monitoring and data analytics.
• Risk assessment and scenario modeling.
• Automating administrative tasks (e.g., trade surveillance alerts, data reconciliation, client communications).

AI tools are used as an aid to our advisory process. They do not independently make investment decisions, open accounts, execute transactions, or generate personalized advice without human review and approval.

Data Protection and Security

We implement controls designed to protect client information processed by AI systems, including encryption, access restrictions, vendor due diligence, and ongoing monitoring of service-provider practices. We require that AI vendors maintain information-security programs consistent with industry standards and applicable legal requirements.

Client Choice and Questions

Clients may contact us at any time with questions about our use of AI technologies or to request additional information about how their data is handled. Where legally required or where a client so requests, we may offer alternatives to the use of certain AI-supported processing tools.

Changes to Our Privacy Policy: Except as required or permitted by law, we do not share confidential information about you with non-affiliated third parties. In the unlikely event there were to be a change in this 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 acceptable.

Questions: If you have questions about this privacy notice or have a question about the privacy of your customer information, call our main number 763-577-1900 and ask to speak to the Chief Compliance Officer.

Effective date of this document is December 1, 2025.