Welton Street – PRIVACY POLICY

Our Commitment to You

When you become a client of or donor to Welton Street Holdings, LLC or its affiliates (the “Company” or “we” or “us”), you entrust us with personal and financial information. We recognize the importance of this information and hold ourselves to the highest standards in its safekeeping and use.

This means, most importantly, that we do not sell client or donor information — whether it is your personal information or the fact that you are a client or donor of ours — to anyone.

Instead, we use your information primarily to provide services to you, complete transactions that you request or to make you aware of other financial products and services offered by us or our affiliates.

If the laws, rules or regulations of any applicable jurisdiction require privacy-related measures that exceed those provided for in this Privacy Policy (the “Policy”), we will follow such laws, rules or regulations.

The Information We Collect About You

In the course of our relationship with you, we may collect personal information about you that is relevant and appropriate under the circumstances. You typically provide personal information when you complete client or donor applications and forms, when you communicate with us via electronic or other means, and when you enter into transactions with us and/or our affiliates. This “personal information” includes (1) information which relates to you and (2) nonpublic personal information about you, which may include:

• Name and address
• Social Security number or taxpayer identification number
• Income, Assets or Financial Condition
• Financial Goals
• Capital Contributions or Donations
• Source of funds
• Other information about your prior investment history

Also, when you visit our website, we may gather information about your computer and operating systems, discussed further below in “Our Website Practices.”

How We Utilize Your Personal Information

We use personal information for a variety of purposes which allow us to provide you the high level of service you expect and deserve from us. Such uses include evaluation of your financial needs or objectives; determination of suitability; delivery of services; verification of relevant financial information needed to complete transactions; resolution of disputes; prevention of fraud; and the management of risk.

How We Handle Your Personal Information

As emphasized above, we do not sell information about current or former clients or donors or their accounts to third parties. Nor do we share such information, except when necessary to complete transactions at your request or to make you aware of related financial products and services offered by us or our affiliates. Here are the details:

• To complete certain transactions or changes that you direct, we may be required to provide identifying information to companies, individuals, or groups that are not affiliated with us (e.g., custodians, banks, accountants and lawyers).
• To alert you to other financial products and services, we may share your information within our family of affiliated companies.
• In certain instances, we may contract with nonaffiliated companies to perform services for us. Where necessary, we will disclose information we have about you to these third parties. In those situations, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose.
• We may disclose information about you to government entities, in response to subpoenas or orders or otherwise to comply with applicable laws or regulations.
• Finally, we will release information about you if you direct us to do so, if we are compelled by law to do so, or in other legally limited circumstances (e.g., to protect you from fraud).

How We Safeguard Your Personal Information

We restrict access to information about you to those of our employees or agents who need to know the information to provide products or services to you. We maintain strict physical, electronic, and procedural safeguards to protect your personal information.

Information obtained through employment with us must be used for the proper performance of each employee’s duties. Sensitive information must only be discussed within the Company on a “need to know” basis, and must never be discussed outside the Company. Upon joining our Company, employees are required to sign a declaration or agreement undertaking to protect the confidentiality of the Company and client information.

Our Website Practices

We may use “cookies” to allow us to gather information about users of our website such as visitors, clients and donors. Cookies are small pieces of data containing a unique identification number that is sent to your browser from a web server, and is stored on your hard drive. The unique ID number identifies your browser to our computers whenever you use our website services. Cookies allow us to customize your experience on our website so that it meets your interests and needs, but they do not allow us to access personally identifiable information that you have not already given to us.

Cookies are part of the technology implemented by your browser. You may adjust your internet browser so that it accepts or rejects all cookies, or to notify you when a cookie is added. To find out more about cookies, to accept or disable cookies, please visit the website of your browser provider. Cookies allow you to take full advantage of some of our most important features, and we recommend that you leave them turned on. For example, if you reject cookies and are using a password-protected feature of our site, you may be repeatedly asked to re-enter your password.

If you utilize our website for transactions, we will store your e-mail address in a cookie. We may also save your credit card number or other financial information in a secure location at your request.

Policy Towards Children

We do not provide services to children, and we encourage all parents to supervise their children's use of the internet. In compliance with the Children's Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly request personally identifiable information from anyone under the age of 13 without prior verifiable parental consent.

Governing Law

This Policy and your use of our website and any disputes relating thereto will be governed by and construed in accordance with the laws of the State of Colorado, without giving effect to its conflict of laws provisions or your actual state or country of residence. Any dispute relating to this Policy shall be resolved solely in the state or federal courts located in Denver, Colorado. If for any reason a court of competent jurisdiction finds any provision or portion of the Policy unenforceable, the remainder of the Policy will continue in full force and effect.

We'll Keep You Informed

If required by applicable law, we will notify you of our Policy annually. We reserve the right to modify this Policy at any time, but rest assured that if we do change it at any time, we will make it available to you. You will also be able to access our Policy from our website.

If you have any questions regarding this Policy or any of our privacy-related procedures, please contact us at (888) 569-1031, or by e-mail at compliance@weltonstreet.com. We may also be reached by mail at Welton Street Holdings, LLC, Attention: Compliance, 4600 South Syracuse Street, Suite 530, Denver, CO 80237.