PRIVACY NOTICE

December 2025

Cannell & Spears LLC (“C&S,” “we,” or “us”) is committed to protecting the privacy and security of the non-public personal information (“NPI”) we obtain about our clients. This notice describes how we collect, use, share, and safeguard your information in accordance with the Gramm-Leach-Bliley Act and Regulation S-P, including the SEC’s 2024 amendments. This notice applies to current and former clients.

1. Information We Collect

We collect personal information needed to provide advisory and related services, which may include:

• Contact information

• Social Security numbers and government identifiers

• Account numbers, balances, and transactions

• Income, assets, investment objectives, and risk tolerance

• Information from applications and agreements

• Information received from custodians, service providers, and your authorized representatives

• Information generated through your use of our secure client systems, including our Black Diamond reporting platform, the eMoney financial planning portal, and the secure client portal on our website (such as login activity, device information, and access records used for authentication and security)

We may also collect information through electronic communications, including email, text messages, and other electronic messages, when such communications relate to business activity.

We do not collect or use mobile numbers or text message opt-in information for marketing or promotional purposes.

2. How We Use and Protect Your Information

We use your information to:

• Provide advisory and financial planning services

• Open, maintain, and service accounts

• Process transactions and communicate with you

• Meet compliance, supervisory, legal, and regulatory obligations

To protect this information, we maintain a Written Information Security Program with administrative, technical, and physical safeguards, including multi-factor authentication, access controls, encryption where appropriate, employee training, monitoring, vendor oversight, and secure record disposal. We review and update these safeguards regularly.

Business-related electronic communications, including business text messages, may be monitored, reviewed and retained to comply with applicable laws and regulations.

3. How We Share Information

We may share information with:

• Custodians, brokers, banks, and other firms servicing your accounts

• Technology, trading, operations, recordkeeping, archiving, cybersecurity, and online-access providers

• Attorneys, auditors, and consultants

• Regulators when required

• Other individuals that you authorize

We may also provide clients with online access to account information and documents through Black Diamond, the eMoney financial-planning portal, and our secure client portal on the C&S website. These platforms are operated by third-party service providers who receive and maintain NPI only as needed to deliver reporting, document access, planning tools, and related services.

Service providers are required to protect your information and use it only for permitted purposes. We do not sell your information and do not share information with non-affiliates for marketing.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

4. Incident Response and Required Notifications

C&S maintains a written Incident Response Program that addresses detecting, investigating, containing, and remediating unauthorized access to NPI.

If we determine that an incident has occurred and that your information was or is reasonably likely to have been accessed or used without authorization, we will notify you within the timeframe required by law and coordinate with any affected service providers and custodians.

5. Your Rights

You may request:

• A copy of this Privacy Notice

• Information about how we maintain and share your data

• Corrections or updates to your information

• Limitations on certain sharing as permitted by law

We may verify your identity before fulfilling requests.