At Niles Investment Management, LLC, maintaining the trust and confidence of our investors is of paramount importance. This Privacy Notice describes how we collect, share, and protect nonpublic personal information furnished to us by our clients and investors.

This Privacy Notice replaces all previous statements of our consumer Privacy Notice and may be amended by us at any time. We will provide you with revised policies if there are any changes in how we handle your nonpublic personal information. If you end your relationship with us, we will continue to adhere to the policies and practices described in this Privacy Notice. If you have any questions about this Privacy Notice you may call us at (305) 813-0487.

Information That We Collect. In connection with providing you with our services, we obtain nonpublic personal information about you that may include the following:

• Information that we receive from you in subscription documents or other forms, including your name, address, social security number, assets and income.

• Information about your investments with us and our affiliates.

We also use Google Analytics and other analytics tools to analyze user behavior on our website. Here’s what you need to know:

• Data Collection: Google Analytics collects information such as your IP address, browser type, device type, and interactions with our site. This data helps us understand user preferences and improve our content.

• Cookies: We use cookies (small text files) to track user sessions. These cookies are stored on your device and allow us to analyze user behavior anonymously.

• Purpose: We use Google Analytics to enhance user experience, optimize content, and make informed decisions about our website.

• Opt-Out: You have the option to opt out of Google Analytics tracking. You can adjust your browser settings or use Google’s opt-out browser add-on.

• Third-Party Disclosure: We do not sell, trade, or transfer your data to third parties unless required by law.

  Information That We Share. We, along with our affiliates, use or share information in a limited and carefully controlled manner. We do not disclose any nonpublic personal information about our investors or former investors to anyone, except as permitted by law. Instances in which we may be required to share such information include:

• Disclosure to companies that provide services necessary to effect a transaction that you request or to service your account, such as prime brokers, accountants, attorneys or administrators.

• Disclosure to government agencies, courts, parties to lawsuits, or regulators in response to subpoenas. In such cases, we share only the information that we are required or authorized to share.