Alpenglow Capital Privacy Policy

Last Updated: May 12, 2022

This Privacy Policy Statement (the “Privacy Policy”) contains the policies, procedures and practices to be followed by Alpenglow Capital LP (“Alpenglow Capital” or the “Company”) pertaining to the collection, use and disclosure of personal information of an identifiable person that is a present, future, or former user of the company’s services, as discussed below. This privacy policy (this “Policy”) outlines how we gather, process, and store your personal information. For the purpose of this Privacy Policy, the term “Personal Information” has the meaning of any information or collection of information in any form, whether oral, electronic, or written that pertains to the individual excluding information that is publicly available in its entirety. Personal Information will also include any publicly available information that is combined with non-publicly available information.

What do we collect?

We collect data to improve our client experience and provide authentication for our clients. We collect your personal information when you:

• open an account;
• when you provide employment information;
• seek investment advice;
• make a wire transfer;
• or enter into an investment management agreement.

The specific types of data we collect and share depend on the products or services you have with us. This personal information collected by the Company can include, but is not limited to:

• social security number;
• Annual income;
• account balances and transaction history;
• assets and investment experience;
• your name;
• address; and
• driver’s license information.

We use cookies to authenticate you. We also use Google Analytics to track user metrics and usage patterns. You are free to use extensions and tools to block those methods, in which case we make no guarantee that the site and its data will be available to you in the same way that it would if those methods were not blocked.


Device and Usage information.
We may collect data about your device and how you and your device interact with the Site. For example, we may collect your interactions on our website, your feature usage patterns, location data, and your interactions with the Company. We may also collect data about your device and the network you use to connect to our Site; this may include data such as your IP address, browser type, operating system, and referring URLs.

How do we use your information?

All financial companies have an obligation and a need to share clients’ personal information to effectively run their institution. The reasons we collect this information include:

• Routine everyday business purposes- such as to process your transactions, maintain your accounts, respond to court orders and legal investigations, or to report to credit bureaus;
• For direct marketing purposes
• For joint marketing purposes with other financial institutions

The Company, in its sole discretion, may use Personal Information for a purpose other than originally disclosed where the new purpose is required by law or where the Company has obtained consent in writing from the affected Individual for each new purpose.

How is your information protected?

All supplied information is transmitted via Secure Socket Layer (SSL) technology and stored in our cloud service provider’s database only to be accessible by those authorized with a need-to-know access to such systems.

Are cookies used?

Yes. Cookies are stored on your computer through your Web browser that enables our Site to recognize your browser and capture and remember certain information. You are free to disable cookies, but if you do, access to certain parts of the Site may be affected. Cookies may also contain information from third parties such as Google Analytics.

Other instances where Alpenglow may disclose any information to outside parties:

We may disclose your personal information as part of a corporate transaction such as a merger, acquisition, reorganization, dissolution, or similar event. We will access, transfer, disclose, and/or preserve personal data, when we have a good faith belief that doing so is necessary to:

• comply with applicable law or respond to valid legal process, judicial orders, or subpoenas;
• respond to requests from public or governmental authorities, including for national security or law enforcement purposes;
• protect the vital interests of our users, customers, or other third parties;
• operate and maintain the security or integrity of our Site, including to prevent or stop an attack on our computer systems or networks;
• protect the rights, interests, or property of third parties;
• prevent or investigate possible wrongdoing in connection with the Site; or
• enforce our Terms of Use.
• We may use and share aggregated non-personal information with third parties for marketing, advertising, and analytics purposes. We do not sell or trade your personal information to third parties.

How to Limit the Sharing of Personal Data:

Federal law gives you the right to limit only
• sharing for 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 individual companies may give you additional rights to limit sharing. See below for more on your rights

Third-Party Links

At our discretion, we may include links to third-party websites on the Site. If you access those websites using the links provided, the operators of these websites may collect information from you that will be used by them in accordance with their privacy policies. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites.

Where Data is Stored

Personal information collected by the Company may be stored and processed anywhere our service providers maintain facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect is processed according to the provisions of this Policy and the requirements of applicable law wherever the data is located.

Data Retention

We reserve the right retain your personal information from when you enter into a client relationship with the Company, as well as when you are no longer a customer with the Company. Alpenglow Capital retains personal information for any additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

Changes to our Privacy Policy

The Company will update this Policy when necessary to reflect changes in rules and regulations, as well as changes to our site, if applicable. If there are material changes to the Policy or in how Alpenglow Capital will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by sending you a notification directly.

For California Residents CalOPPA— CalOPPA requires our website to feature a conspicuous privacy policy stating exactly what information is collected and with whom it is shared. CalOPPA defines “personally identifiable information” as:
• First and last names
• Physical addresses
• Email addresses
• Telephone numbers
• Social Security numbers
• Any other contact information, both physical or online
• Birthdays
• Details of physical appearance (height, weight, hair color)
• Any other information stored online that may identify an individual

Arbitration

In the event a dispute arises out of or in connection with this Privacy Policy, the parties will first attempt to resolve the dispute through friendly consultation. However, if the dispute is not resolved within a reasonable period, then any or all outstanding issues may be submitted to final and binding arbitration in accordance with the laws of the State of New York. The arbitrator’s award will be final, and judgment may be entered upon it by any court having jurisdiction within the State of New York.

Contacting Us

If you have any questions or concerns, please contact jdean@a-glowcap.com.