Privacy Policy

Updated May 2026

Protecting the confidentiality and security of personal information is an important part of our responsibilities as a financial services firm. Accordingly, we have developed this Policy to help you understand how we collect, use, disclose, safeguard, and manage personal information.

  • Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
  • We will collect and use personal information solely for the purposes identified by us and for other compatible purposes permitted by law.
  • We will retain personal information to fulfill the purposes for which it was collected, provide advisory services, comply with legal, regulatory, and recordkeeping obligations, resolve disputes, and enforce our agreements, including applicable records retention requirements under federal securities laws.
  • We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date.
  • We maintain administrative, technical, and physical safeguards reasonably designed to protect personal information against unauthorized access, use, acquisition, disclosure, alteration, or destruction. We periodically review and update our information security and privacy practices in light of operational, technological, and regulatory developments.
  • We make information regarding our privacy, information security, and information management practices available to clients as required by applicable law and regulation.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

What does Marathon Capital Management, LLC do with your personal information?

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, use, share, and safeguard your personal information. Please read this notice carefully to understand our privacy practices.

The types of personal information we collect and share depend on the product or service you have with us. This information may include Social Security numbers or taxpayer identification numbers, contact information, home address, account numbers, account balances, transaction history, and investment-related information.

All financial companies need to share client personal information to run their everyday business. In the section below, we list the reasons financial companies can share their client’s personal information; the reasons Marathon Capital Management chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information Does Marathon Capital share? Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your accounts, respond to court orders and legal investigations. Yes No
For our marketing purposes – to offer our products and services to you. No We do not share
For joint marketing with other financial companies. No We do not share
For our affiliates’ everyday business purposes – information about your transactions and experiences No We do not share
For our affiliate’s everyday business purposes – information about your creditworthiness No We do not share
For our affiliates to market to you No We do not share
For nonaffiliates to market to you No We do not share

If you have questions, please call us at 410-329-1522.

Please note: When you are no longer our client, we continue to share your information as described in this notice.

Information we collect:

The information we collect from you includes, but may not be limited to, your name, address, Social Security number, date of birth, professional occupation, marital status, personal financial information, and your investment goals and objectives. We may disclose any of this information to nonaffiliates as described below, in order to provide services to you.

We may also collect information from custodians, broker-dealers, financial institutions, service providers, and other third parties involved in maintaining or servicing your accounts and advisory relationship.

When we share your information:

We may share nonpublic personal information with nonaffiliated third parties, including qualified custodians, broker-dealers, technology service providers reasonably necessary to support advisory services, account servicing, regulatory compliance, cybersecurity, technology operations, or other legitimate business purposes permitted by law. We maintain written policies, procedures, and information security controls reasonably designed to safeguard nonpublic personal information and to support compliance with applicable federal privacy and cybersecurity regulations, including Regulation S-P.

Please contact us directly with any questions regarding the protection of your nonpublic personal information.

Who We Are
Who is providing this notice Marathon Capital Management, LLC.
What We Do
How does Marathon 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 access controls, secure systems and technologies, employee confidentiality measures, cybersecurity safeguards, vendor oversight procedures, and physical protections for records and information systems.
How does Marathon Capital Management collect my personal information? We collect your personal information, for example, when you open or maintain an account with us, request advisory services, provide account or financial information, conduct transactions, communicate with us, or otherwise engage with our services.
Why can’t I limit all sharing? Federal law gives you the right to limit only:

  • sharing of affiliates’ everyday business purposes – information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and regulations may give you additional rights regarding the sharing or protection of personal information.
What happens when I limit sharing for an account I hold jointly with someone else? Limits are placed on the account per your request.
Other Important Information
When you are no longer a client, we continue to protect your personal information in accordance with this Privacy Policy and applicable law. We may continue to share information as necessary to service accounts, comply with legal obligations, or as otherwise permitted by law. Examples of such persons or companies could include your accountant or a new custodian of the assets you had invested with Marathon Capital Management.
Definitions
Affiliates Companies related by common ownership or control. They can be financial and non-financial companies. We have no affiliates.
Non-affiliates Non-affiliates may include custodians, broker-dealers, technology service providers, cybersecurity vendors, legal or compliance professionals, and other third parties necessary to support account servicing and business operations.
Joint Marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. We do not engage in joint marketing activities with other financial companies.