PRIVACY POLICY NOTICE

This Privacy Policy Notice is intended solely for individuals and entities acting as their functional equivalents (e.g., revocable grantor trusts, IRAs, or certain estate planning vehicles).
Broad Run Investment Management, LLC (the “firm”) respects the privacy of all customers and prospective customers, both past and present. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. We are providing you with this notice (the “Privacy Policy Notice”) to help you better understand why and how we collect and disclose certain personal information, the care with which we treat that information, and how we use that information.

The firm collects personal information about customers from the following sources:
  • Information customers provide to complete our investment questionnaire;
  • Information customers provide in engagement agreements, account applications, and other documents completed in connection with the opening and maintenance of their accounts;
  • Information customers provide verbally; and
  • Information received from service providers, such as custodians, about customer transactions.
The firm does not disclose nonpublic personal information about our customers to anyone, except in the
following circumstances:
  • When required to provide services our customers have requested;
  • When our customers have specifically authorized us to do so;
  • When required during the course of a firm assessment (i.e., independent audit); or
  • When permitted or required by law or regulation (i.e., periodic regulatory examination).
Within the firm, access to customer information is restricted to staff that need to know that information. All
supervised persons and service providers understand that everything handled in firm offices are confidential and they are instructed to not discuss customer information with someone else that may request information
about an account unless they are specifically authorized in writing by the customer to do so. This includes,
for example, providing information about a spouse’s IRA account or to adult children about parents’
accounts, etc.

In accordance with privacy regulations, we maintain nonpublic personal information of our former customers and apply the same policies that apply to current customers.

To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to
protect the privacy of customer information.

The firm reserves the right to change our privacy policies and this Privacy Policy Notice at any time. In the event that we update this Privacy Policy Notice, we will make an updated version available to you. This Privacy Policy Notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act. You may have additional rights under other foreign or domestic laws that apply to you.

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If you have additional questions about our Privacy Policy, you may contact us at the office phone number below or via email to Bryan H. Adkins, CCO at badkins@broadrunllc.com.

Broad Run Investment Management, LLC
1530 Wilson Boulevard | Suite 530 | Arlington, Virginia 22209
O: (703) 260‐1260 | F: (703) 574-4312 | www.broadrunllc.com

June 2026