GLOBAL KANDOR ADVISORS, LLC

Global Kandor Advisors LLC Form ADV Part 2A – Disclosure Brochure Effective: April 16, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Global Kandor Advisors LLC (“Global Kandor” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (786) 558-0391. Global Kandor is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Global Kandor to assist you in determining whether to retain the Advisor. Additional information about Global Kandor and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 308452. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 http://GlobalKandor.com/  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Global Kandor. For convenience, the Advisor has combined these documents into a single disclosure document. Global Kandor believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Global Kandor encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on March 6, 2024. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or our CRD# 308452. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (786) 558- 0391. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................ 1 Item 2 – Material Changes ...................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Services..................................................................................................................................... 4 A. Firm Information ..............................................................................................................................................................4 B. Advisory Services Offered ...............................................................................................................................................4 C. Client Account Management ...........................................................................................................................................5 D. Wrap Fee Programs ........................................................................................................................................................5 E. Assets Under Management .............................................................................................................................................6 Item 5 – Fees and Compensation .......................................................................................................................... 6 B. Fee Billing ........................................................................................................................................................................6 C. Other Fees and Expenses...............................................................................................................................................7 D. Advance Payment of Fees and Termination ...................................................................................................................7 E. Compensation for Sales of Securities .............................................................................................................................7 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 7 Item 7 – Types of Clients ........................................................................................................................................ 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 7 A. Methods of Analysis ........................................................................................................................................................7 B. Risk of Loss .....................................................................................................................................................................8 Item 9 – Disciplinary Information .......................................................................................................................... 9 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 9 A. Code of Ethics .................................................................................................................................................................9 B. Personal Trading with Material Interest .........................................................................................................................10 C. Personal Trading in Same Securities as Clients ...........................................................................................................10 D. Personal Trading at Same Time as Client.....................................................................................................................10 Item 12 – Brokerage Practices ............................................................................................................................. 10 A. Recommendation of Custodian[s] .................................................................................................................................10 B. Aggregating and Allocating Trades ...............................................................................................................................11 Item 13 – Review of Accounts.............................................................................................................................. 11 A. Frequency of Reviews ...................................................................................................................................................11 B. Causes for Reviews.......................................................................................................................................................11 C. Review Reports .............................................................................................................................................................11 Item 14 – Client Referrals and Other Compensation ......................................................................................... 12 A. Compensation Received by Global Kandor...................................................................................................................12 B. Compensation for Client Referrals ................................................................................................................................12 Item 15 – Custody.................................................................................................................................................. 12 Item 16 – Investment Discretion .......................................................................................................................... 13 Item 17 – Voting Client Securities ....................................................................................................................... 13 Item 18 – Financial Information ........................................................................................................................... 13 Form ADV Part 2B – Brochure Supplement[s] ................................................................................................... 14 Privacy Policy ........................................................................................................................................................ 21 Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 3  Item 4 – Advisory Services A. Firm Information Global Kandor Advisors LLC (“Global Kandor” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Global Kandor was is organized as a Limited Liability Company (“LLC”) under the laws of the State of Florida in June 2020. Global Kandor is an owned subsidiary of Global Kandor Holdings, LLC. The Principal Officer of Global Kandor is Guillermo E. Vernet (Chief Executive Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Global Kandor. For information regarding this Disclosure Brochure, please contact Guillermo E. Vernet (Chief Compliance Officer) at (786) 558-0391 or via email to Guillermo.Vernet@kandorglobal.com. B. Advisory Services Offered Global Kandor offers wealth management services to individuals, high net worth individuals, and trusts (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. Global Kandor’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Global Kandor provides customized wealth management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary or non-discretionary investment management and related financial planning services. Global Kandor works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy. Global Kandor will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds, private/alternative investments and/or other types of investments, as appropriate, to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Global Kandor’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Global Kandor will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Global Kandor evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Global Kandor may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Global Kandor may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against the market movement. Global Kandor may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Global Kandor accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 4  Financial Planning Services – Global Kandor will typically provide a variety of financial planning and consulting services to Clients. Financial planning services are typically included in an overall wealth management engagement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals, and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Global Kandor may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. Global Kandor doesn’t receive compensation for such referrals. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging Global Kandor to provide wealth management services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Global Kandor, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Global Kandor will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. • Portfolio Construction – Global Kandor will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Global Kandor will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Global Kandor does not manage a wrap fee program. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 5  E. Assets Under Management As of December 31, 2024, Global Kandor manages $415,082,545 in Client assets, $20,071,926 of which are managed on a discretionary basis and $395,010,619 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the agreement. Wealth management fees can be calculated as a percentage, which can range from 0.50% to 2.00% annually of the value of assets under management. As well as fixed fees that are based on several factors, including the complexity of the services to be provided, the inclusion of financial planning services, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions, and other complexities may be charged a higher fee. The annual fixed fee will be adjusted on January 1st of each year by the inflation rate published by CPI (“Consumer Price Index”) as reported by the U.S. Bureau of Labor Statistics. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. Clients may be offered a fixed rate fee schedule. All securities held in accounts managed by Global Kandor will be independently valued by the Custodian or applicable third-party. Global Kandor will conduct periodic reviews of the Custodians valuations to ensure accurate billing. Clients may make additions to and withdrawals from their account[s] at any time, subject to Global Kandor’ right to terminate an account. Additions may be in cash or securities provided that Global Kandor reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to Global Kandor, subject to the usual and customary securities settlement procedures. However, Global Kandor designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. Global Kandor may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. B. Fee Billing Wealth management fees are calculated by the Advisor and may be deducted from the Client’s account[s] at the Custodian or directly invoiced to the Client, pursuant to the terms of the Management and Advisory Agreement. For fees deducted from the Client’s account[s], the Advisor will send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] following the start of each calendar quarter. Client fees that are directly invoiced to the Client are due upon receipt of the Advisor’s invoice. Asset-based fees are calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Global Kandor at the end of the previous quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the wealth management fee. Clients are urged also to review and compare any statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. When fees are being directly deducted, Clients provide written authorization permitting advisory fees to be deducted by Global Kandor to be paid directly from their account[s] held by the Custodian as part of the Management and Advisory Agreement and separate account forms provided by the Custodian. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 6  C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and custody fees charged by the Custodian, if applicable. In addition, all fees paid to Global Kandor for wealth management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. The Client should review both the fees charged by the fund[s] and the fees charged by Global Kandor to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Global Kandor may be compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the Management and Advisory Agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the Management and Advisory Agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five- day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s Management and Advisory Agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Global Kandor does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the wealth management fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Global Kandor does not charge performance-based fees for its investment advisory services. The fees charged by Global Kandor are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Global Kandor does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Global Kandor offers wealth management services to individuals, high net worth individuals, trusts, estates, charitable organizations and businesses. The amount of each type of Client is available on Global Kandor’ Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Global Kandor generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Global Kandor primarily employs a fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Global Kandor are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. The fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria generally consists of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 7  potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Global Kandor will be able to predict such a reoccurrence accurately. As noted above, Global Kandor generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Global Kandor will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Global Kandor may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Global Kandor will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 8  may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bonds time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investors rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving Global Kandor or its Supervised Persons. Global Kandor values the trust Clients place in the Advisor. The Advisor encourages you to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 308452. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Global Kandor is to provide investment advisory services to its Clients. Neither Global Kandor nor its Advisory Persons are involved in other business endeavors. Global Kandor does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Global Kandor has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Global Kandor (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client, our Client. Global Kandor and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Global Kandor’ Supervised Persons to adhere not only to the specific Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 9  provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (786) 558-0391. B. Personal Trading with Material Interest Global Kandor allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Global Kandor does not act as a principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Global Kandor does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Global Kandor allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Global Kandor requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Global Kandor allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Global Kandor, or any Supervised Person of Global Kandor, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Global Kandor does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Global Kandor to direct trades to the Custodian as agreed upon in the Management and Advisory Agreement. Further, Global Kandor does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Global Kandor does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost associated with using a custodian not recommended by Global Kandor. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Global Kandor may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Global Kandor will often recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Global Kandor maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. In addition, Clients may have assets held at other Custodians. Following are additional details regarding the brokerage practices of the Advisor: Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 10  1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Global Kandor does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – Global Kandor does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where Global Kandor will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Global Kandor will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Global Kandor will execute its transactions through the Custodian as authorized by the Client. Global Kandor may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Global Kandor and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Global Kandor if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic, or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 11  Item 14 – Client Referrals and Other Compensation A. Compensation Received by Global Kandor Global Kandor is a fee-based advisory firm that is compensated solely by its Clients and not from any investment product. Global Kandor does not receive commissions or other compensation from product sponsors, broker- dealers or any unrelated third party. Global Kandor may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Global Kandor may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform Global Kandor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Global Kandor. As a registered investment advisor participating on the Schwab Advisor Services platform, Global Kandor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client –. In addition, the Advisor has the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Item 15 – Custody Global Kandor does not accept or maintain custody of any Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Global Kandor exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Global Kandor to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Global Kandor to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Money Movement Authorization - For instances where Clients authorize Global Kandor to move funds between their accounts, Global Kandor and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 12  Item 16 – Investment Discretion Global Kandor often has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Global Kandor. Certain Client engagements may be provided on a non-discretionary basis. The discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a Management and Advisory Agreement containing all applicable limitations to such authority. All discretionary trades made by Global Kandor will be in accordance with each Client's investment objectives and goals. For non-discretionary accounts, the Advisor maintains regular and continuous supervisions and/or management over the accounts, but may be limited in its ability to implement investment decisions without the approval and assistance of the Client. Item 17 – Voting Client Securities Global Kandor does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies. However, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Global Kandor, nor its management, have any adverse financial situations that would reasonably impair the ability of Global Kandor to meet all obligations to its Clients. Neither Global Kandor, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Global Kandor is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 13  Form ADV Part 2B – Brochure Supplement for Guillermo E. Vernet Chief Executive Officer Chief Compliance Officer Effective: April 16, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Guillermo E. Vernet (CRD# 2748034) in addition to the information contained in the Global Kandor Advisors LLC (“Global Kandor” or the “Advisor”, CRD# 308452) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Global Kandor Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (786) 558-0391. Additional information about Mr. Vernet is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2748034. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 14  Item 2 – Educational Background and Business Experience Guillermo E. Vernet, born in 1964, is dedicated to advising Clients of Global Kandor as its Chief Executive Officer and Chief Compliance Officer. Mr. Vernet earned Masters of Business Administration from Cornell University School of Management in 1990. Mr. Vernet also earned a Bachelor of Science from Universidad Metropolitana in 1988. Additional information regarding Mr. Vernet’s employment history is included below. Employment History: Chief Executive Officer, Chief Compliance Officer, Global Kandor Advisors LLC Principal, Kandor Global Consultants LLC Registered Representative, Insigneo Securities LLC Investment Advisor Representative, Insigneo Wealth Advisors LLC General Manager, Compass Group LLC, Miami Office Investment and Private Banking, Chase Manhattan Bank Investment Analyst, Hewlett-Packard Investment Analyst, Banco Industrial de Venezuela 10/2020 to Present 10/2020 to 09/2021 07/2014 to 10/2020 09/2011 to 10/2020 03/2000 to 6/2010 07/1991 to 02/2000 6/1990 to 5/1991 8/1986 to 7/1987 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Vernet. Mr. Vernet has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Vernet. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Vernet. However, we do encourage you to independently view the background of Mr. Vernet on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2748034. Item 4 – Other Business Activities Global Kandor Services LLC Global Kandor Services LLC is an internal support organization for Global Kandor Advisors LLC. Clients are not provided services through Global Kandor Services. Mr. Vernet spends less than less than 5% of his time with this entity. Item 5 – Additional Compensation Mr. Vernet has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Vernet serves as the Chief Executive Officer and Chief Compliance Officer of Global Kandor. Mr. Vernet can be reached at (786) 558-0391. Global Kandor has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Global Kandor. Further, Global Kandor is subject to regulatory oversight by various agencies. These agencies require registration by Global Kandor and its Supervised Persons. As a registered entity, Global Kandor is subject to examinations by regulators, which may be announced or unannounced. Global Kandor is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 15  Form ADV Part 2B – Brochure Supplement for Paola A. Bernal Cuevas, CFA® Chief Investment Officer Effective: April 16, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Paola A. Bernal, CFA® (CRD# 7530552) in addition to the information contained in the Global Kandor Advisors LLC (“Global Kandor” or the “Advisor”, CRD# 308452) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Global Kandor Disclosure Brochure or this Brochure Supplement, please contact us at (786) 558-0391. Additional information about Ms. Bernal is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7530552. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 16  Item 2 – Educational Background and Business Experience Paola A. Bernal, CFA®, born in 1982, is dedicated to advising Clients of Global Kandor as the Chief Investment Officer. Ms. Bernal earned a Masters in Business Administration from University of Toronto in 2010. Ms. Bernal also earned a Bachelors in Business Administration from University of Miami in 2003. Additional information regarding Ms. Bernal’s employment history is included below. Employment History: Chief Investment Officer, Global Kandor Advisors LLC Investment Officer, Insigneo Wealth Advisors LLC Advisor, Organizacion Luis Carlos Sarmiento Equity Derivatives Associate, Scotiabank Global Banking and Markets 10/2020 to Present 10/2014 to 10/2020 10/2012 to 10/2014 08/2010 to 10/2012 Chartered Financial Analyst™ (“CFA®”) The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA® Institute. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Ms. Bernal. Ms. Bernal has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Ms. Bernal. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Ms. Bernal. However, we do encourage you to independently view the background of Ms. Bernal on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7530552. Item 4 – Other Business Activities Ms. Bernal is dedicated to the investment advisory activities of Global Kandor’s Clients. Ms. Bernal does not have any other business activities. Item 5 – Additional Compensation Ms. Bernal is dedicated to the investment advisory activities of Global Kandor’s Clients. Ms. Bernal does not receive any additional forms of compensation. Item 6 – Supervision Ms. Bernal serves as the Chief Investment Officer of Global Kandor and is supervised by Guillermo Vernet, the Chief Compliance Officer. Mr. Vernet can be reached at (786) 558-0391. Global Kandor has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Global Kandor. Further, Global Kandor is subject to Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 17  regulatory oversight by various agencies. These agencies require registration by Global Kandor and its Supervised Persons. As a registered entity, Global Kandor is subject to examinations by regulators, which may be announced or unannounced. Global Kandor is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 18  Form ADV Part 2B – Brochure Supplement for Ana M. Rebora Business Development Director Effective: April 16, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Ana M. Rebora (CRD# 4709058) in addition to the information contained in the Global Kandor Advisors LLC (“Global Kandor” or the “Advisor”, CRD# 308452) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Global Kandor Disclosure Brochure or this Brochure Supplement, please contact us at (786) 558-0391. Additional information about Mrs. Rebora is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 4709058. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 19  Item 2 – Educational Background and Business Experience Ana M. Rebora, born in 1965, is dedicated to advising Clients of Global Kandor as the Business Development Director. Mrs. Rebora earned a Bachelor’s Degree in Business Administration from the University of Texas at Austin in 1988. Additional information regarding Mrs. Rebora’s employment history is included below. Employment History: Business Development Director, Global Kandor Advisors LLC Director - Business Development, Activa Capital Group Regional Leader, Primerica Financial Services (PFS Investments, Inc.) 04/2023 to Present 10/2022 to 04/2023 06/2002 to 09/2022 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mrs. Rebora. Mrs. Rebora has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mrs. Rebora. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mrs. Rebora. However, we do encourage you to independently view the background of Mrs. Rebora on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 4709058. Item 4 – Other Business Activities Mrs. Rebora is dedicated to the investment advisory activities of Global Kandor’s Clients. Mrs. Rebora does not have any other business activities. Item 5 – Additional Compensation Mrs. Rebora is dedicated to the investment advisory activities of Global Kandor’s Clients. Mrs. Rebora does not receive any additional forms of compensation. Item 6 – Supervision Mrs. Rebora serves as the Business Development Director of Global Kandor and is supervised by Guillermo Vernet, the Chief Compliance Officer. Mr. Vernet can be reached at (786) 558-0391. Global Kandor has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Global Kandor. Further, Global Kandor is subject to regulatory oversight by various agencies. These agencies require registration by Global Kandor and its Supervised Persons. As a registered entity, Global Kandor is subject to examinations by regulators, which may be announced or unannounced. Global Kandor is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 20  Privacy Policy Effective: April 16, 2025 Our Commitment to You Global Kandor Advisors LLC (“Global Kandor” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Global Kandor (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Global Kandor does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 21  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Marketing Purposes Global Kandor does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Global Kandor or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Global Kandor does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy The Advisor will send you a copy of this Policy annually for as long as a Client maintains an ongoing relationship with the Advisor. Periodically the Advisors may revise this Policy and will provide Clients with a revised Policy if the changes materially alter the previous Privacy Policy. The Advisor will not, however, revise the Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless the Advisor first notify Clients and provides Clients with an opportunity to prevent the information sharing. Any Questions? Clients may ask questions or voice any concerns, as well as obtain a copy of the current Privacy Policy by contacting the Advisor at (786) 558-0391. Global Kandor Advisors LLC 200 Crandon Boulevard, Suite 325, Key Biscayne, FL 33149 Phone: (786) 558-0391 www.GlobalKandor.com Page 22