Legal Notices CLIENT RELATIONSHIP SUMMARY AT ONE CAPITAL MANAGEMENT, LLC WE RESPECT YOUR PRIVACY This privacy notice is being sent on behalf of One Capital Management, LLC and its Investment Advisory Representatives (collectively called OCM.) We recognize our obligation to keep information about you secure and confidential. It’s important for you to know that we do not sell your information to anyone. We restrict access to non-public personal information about you to those Investment Advisory Representatives and employees who need to know that information to provide products or services to you. We also maintain physical, electronic, and procedural safeguards to guard your non-public personal information. This notice describes how we handle your financial information that we collect while conducting our business. We collect information about you (such as your name, address, social security number, assets and income) from our discussions with you, and from documents that you may deliver to us in the course of providing services to you. We may use this information to open an account for you or to process a transaction for your account. In order to service your account and effect your transactions, we may provide your personal information to firms (such as a custodial broker-dealer) that assist us in servicing your account and have a need for such information, as permitted by law and to third parties who are referring parties and with whom OCM has entered into a written referral agreement. We may also disclose such information to the Securities & Exchange Commission, and any other governmental or quasi-governmental agency that oversees or has any jurisdiction over our activities, including a court of law, an arbitration panel, or any securities regulator. Some of OCM’s Investment Advisory Representatives independently provide insurance, securities brokerage and other services to you. All of the information that OCM collects through its Investment Advisory Representatives who are also employed in other businesses will be available to them in those other business capacities. Investment Advisory Representatives will not disclose the information if you notify us that you do not want the information used in any capacity other than the one in which you have dealt with the Investment Advisory Representative. If you prefer that we not disclose non-public, personal information about you to non-affiliated third parties, (other than those disclosures permitted by law) or to OCM Investment Advisory Representatives for use in their other businesses, you may opt out of those disclosures that is, you may direct us not to make those disclosures. If you wish to opt out of disclosures to non affiliated third parties, you may write to the following address: 3075 Townsgate Road Suite 350. Westlake Village, CA 91361 DISASTER PREPAREDNESS & BUSINESS CONTINUITY PLAN OCM has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan. Responsibility

The Chief Compliance Officer (CCO) is responsible for creating and maintaining OCM's immediate and long-term contingency planning and recovery procedures that are appropriate to the scale and scope of OCM's business.
Notification of Proper Authorities

After an emergency has been declared, the CCO, or designee, will notify the proper regulatory authorities of the nature of the emergency, and the temporary location of the firm. Additionally, the same party will notify the local public utilities, the telephone company, the post office and any other vendor as deemed necessary.  
Telephone Service

In the event am emergency has been declared, our phone system will still be fully functioning. You can reach us at our regular phone number:   805-409-8150
  Temporary Operation Location/Recovery Site

If the primary office is inaccessible, OCM will relocate temporarily to a remote office outside of the affected emergency area.
  Client data is easily accessible at any remote location with Internet access as client data, including e-mail correspondence and pertinent books and records are backed up every 15 minutes to an archive disk on premises. Additionally, a full backup is made every 24 hours to our service provider, Infrascale, to allow for retrieval of client records when the primary office location is not accessible.  
   Client Contact

If a disaster occurs, every effort will be made by OCM to contact all clients. This will either be done by phone calls, emails, general mailing, and/or posting a message on OCM website. A list of all clients is maintained in OCM's account management system and can also be received by contacting the relevant account custodian.  
  Updates and Annual Review

OCM will update this plan whenever there is a material change to OCM's operations, structure, business or location or to those of our custodian (or any other critical service providers). In addition, OCM will test and update the plan, at least annually, to ensure the plan remains consistent with OCM's policy and overall business operations.
A full version of the Disaster Recovery Plan is available upon request. Custodian Contacts

If, after a significant business disruption, you cannot contact us directly as you usually do please call directly to your custodian as follows:
For Charles Schwab Accounts
www.schwab.com
1-800-435-4000

For TD Ameritrade Accounts
www.tdainstitional.com
1-800-669-3900

For Merrill Lynch Accounts
www.ml.com
1-800-637-7455

For NBIN Accounts
www.nbcn.com
1-416-869-6695

For Pershing Accounts
www.pershing.com
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.