Privacy Policy

What Does Exchange Capital Management, Inc. Do
With Your Personal Information?

The Law

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

Our Policy

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Income
• Employment and residential information
• Social security number
• Cash balance•Security balances
• Transaction detail history
• Investment objectives, goals, and risk tolerance

When you are no longer a client, we continue to share your information as described in this notice.

Your Rights

All financial companies need to share customers’ personal information to run their everyday business. We list below the reasons financial companies can share their customers’ personal information; the reasons ECMchooses to share; and whether you can limitthis sharing.

Definitions

• Everyday Business Purposes - The actions necessary by financial companies to run their business and manage customer accounts, such as providing investment advisory and financial planning advice, processing securities transactions, and otherwise providing financial services to you.

• Affiliates - The actions necessary by financial companies to run their business and manage customer accounts, such as providing investment advisory and financial planning advice, processing securities transactions, and otherwise providing financial services to you.

• Non-Affiliates - Companies not related by common ownership or control. They can be financial and non-financial companies. Exchange Capital Management does not share information with non-affiliates for marketing purposes.

• Joint Marketing - A formal agreement between nonaffiliated financial companies that together market financial products or services to you. ECM does not engage in joint marketing with non-affiliates.

Sharing Practices

• How often does Exchange Capital Management notify me about their practices?

We must notify you about our sharing practices when you become a client or if we change our information sharing policies and procedures.

• How does Exchange Capital Management protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

• How does Exchange Capital Management collect my personal information?

• Why can't I limit all sharing?

If you wish to modify or impose reasonable restrictions concerning the management of your account, or if your financial situation, investment objectives, or risk tolerance have changed, please contact your Exchange Capital Management investment advisor representative or contact the firm’s CCO at 734-761-6500 or by email at cco@exchangecapital.com. We will contact you at least annually to determine if your investment goals, objectives, and risk tolerance have changed.

We urge that you advise us immediately if you have not received your custodian or brokerage statement, which is required to be delivered to you no less frequently than quarterly. In addition, please compare any account information provided by us with account statements from your broker-dealer or custodian and to advise us of any discrepancies. The official record of your account is maintained by your broker-dealer or custodian. Thank you.