Alpenglow Capital Privacy Policy
Effective Date: June 2026
This Privacy Policy describes how Alpenglow Capital (“Firm,” “we,” “us,” or “our“) collects, uses, safeguards, and shares nonpublic personal information about its current, former, and prospective clients in accordance with Title V of the Gramm-Leach-Bliley Act and Regulation S-P, as amended, and other applicable federal and state privacy laws.
This Privacy Policy is intended to satisfy the Firm’s notice obligations under Regulation S-P for registered investment advisers and to explain the Firm’s practices with respect to the privacy and protection of personal information.
1. Scope
This Privacy Policy applies to nonpublic personal information that the Firm receives from or about individual clients and consumers in connection with providing advisory, financial, investment management, wealth management, brokerage support, financial planning, consulting, or other related services. This Privacy Policy also applies to former clients to the extent required by applicable law.
This Privacy Policy does not apply to information that is publicly available or otherwise excluded from protection under applicable law.
2. Categories of Information We Collect
The Firm may collect nonpublic personal information about you from the following sources:
Information you provide in account applications, subscription documents, investment management agreements, advisory agreements, questionnaires, financial plans, correspondence, and other forms or communications.
Information about your transactions with us, our affiliates, custodians, administrators, broker-dealers, or other service providers.
Information we receive from consumer reporting agencies, background checks, identity verification providers, or other third parties, to the extent permitted by law.
Information collected through our website, client portal, email communications, mobile applications, or other digital services, including technical and usage information, subject to applicable law and any separate online privacy disclosures.
Depending on the nature of the relationship, the information we collect may include:
Name, address, telephone number, email address, date of birth, Social Security number, taxpayer identification number, driver’s license or passport information, and other government-issued identification data.
Employment information, income, assets, liabilities, net worth, account balances, transaction history, investment objectives, risk tolerance, financial circumstances, and other suitability information.
Bank account information, custodial account information, beneficiary information, trust or estate information, and other financial or ownership data.
Other information necessary to provide services, comply with legal and regulatory obligations, and manage our business.
3. How We Use Information
The Firm uses nonpublic personal information as reasonably necessary to:
Establish, maintain, administer, and service client accounts and advisory relationships.
Provide investment advisory, portfolio management, financial planning, reporting, trading, and related services.
Process transactions and communicate with clients and authorized representatives.
Verify identity, conduct due diligence, detect fraud, prevent unauthorized access, and protect against cybersecurity and other security risks.
Comply with legal, regulatory, tax, accounting, recordkeeping, reporting, and compliance obligations.
Manage operations, perform internal analytics, improve service delivery, and enforce our agreements and policies.
4. Categories of Information We May Disclose
The Firm may disclose the categories of nonpublic personal information described above, to the extent permitted or required by law and consistent with this Privacy Policy.
5. Categories of Persons to Whom We May Disclose Information
The Firm does not disclose nonpublic personal information about current or former clients to nonaffiliated third parties, except as permitted or required by law.
We may disclose nonpublic personal information to the following categories of recipients:
Service providers and vendors that assist us in operating our business and servicing accounts, including custodians, administrators, transfer agents, broker-dealers, proxy service providers, technology providers, cloud hosting providers, cybersecurity providers, auditors, compliance consultants, legal counsel, tax advisers, insurance providers, and other professional advisers.
Affiliates, to the extent permitted by law and as necessary for ordinary business purposes, including servicing accounts, operational support, compliance, risk management, and administrative functions.
Financial institutions and transaction counterparties as necessary to effect, administer, or enforce transactions or provide requested services.
Regulators, governmental authorities, self-regulatory organizations, law enforcement, and courts when we believe disclosure is required or appropriate to comply with applicable law, regulation, subpoena, examination request, legal process, or regulatory inquiry.
Other parties with your consent or at your direction, including attorneys, accountants, consultants, trustees, executors, family offices, or other representatives you authorize.
Successors or assignees in connection with an actual or proposed merger, acquisition, sale of assets, financing, reorganization, or other corporate transaction, subject to appropriate confidentiality protections where applicable.
We do not sell your nonpublic personal information.
6. Information Sharing Practices
The Firm may disclose nonpublic personal information to nonaffiliated third parties as permitted by law, including:
To service providers that perform functions on our behalf.
To process or service transactions that you request or authorize.
To protect the confidentiality or security of records and information.
To prevent fraud, unauthorized transactions, claims, or other liability.
To respond to judicial process or government regulatory authorities.
As otherwise permitted under Regulation S-P, the Gramm-Leach-Bliley Act, the Investment Advisers Act of 1940, and other applicable law.
If the Firm shares information with nonaffiliated third parties outside of applicable exceptions in a manner that triggers notice and opt-out rights under applicable law, the Firm will provide any required notices and opportunity to opt out before doing so.
7. Confidentiality and Security
The Firm restricts access to nonpublic personal information about clients to personnel, affiliates, and service providers who need to know that information to provide products or services, administer accounts, or perform compliance, risk management, legal, audit, operational, or support functions.
The Firm maintains physical, electronic, and procedural safeguards designed to protect nonpublic personal information and to comply with applicable federal standards. These safeguards include, as appropriate:
Access controls and authentication measures.
Encryption and secure transmission protocols where appropriate.
Network and endpoint monitoring.
Vendor oversight and contractual confidentiality obligations.
Employee training on privacy, confidentiality, and information security.
Incident response and business continuity procedures.
Record retention and secure disposal practices.
7A. Incident Response and Breach Notification
In accordance with the amendments to Regulation S-P adopted by the SEC in 2023, Alpenglow Capital maintains an incident response program reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information. In the event of a breach of security involving sensitive customer information, the Firm will notify each affected individual as soon as reasonably practicable, and no later than 30 days after the Firm becomes aware that unauthorized access to or use of the customer information has occurred or is reasonably likely to have occurred. Such notification will describe the incident, the type of information involved, and the steps the individual may take to protect themselves. The Firm will also maintain written policies and procedures for its incident response program and will document all covered incidents, response actions, and notifications. The incident response program will be reviewed at least annually and updated as necessary to reflect changes in the threat environment, applicable law, and the Firm’s systems and operations.
No method of transmitting or storing data is completely secure. Accordingly, while the Firm uses reasonable administrative, technical, and physical safeguards designed to protect personal information, the Firm cannot guarantee absolute security.
8. Former Clients
The Firm applies the privacy protections described in this Privacy Policy to nonpublic personal information about former clients to the extent required by applicable law.
9. Cookies and Online Information
If you interact with the Firm through a website, portal, or other online service, the Firm may collect information through cookies, pixels, log files, and similar technologies, including device identifiers, IP address, browser type, usage data, and session information. The Firm uses this information for website functionality, security, analytics, service improvement, and communications, subject to applicable law and any separate website privacy notice or cookie disclosure.
Where required by law, the Firm will provide any required disclosures or choices regarding online tracking technologies.
10. Text Messages, Email, and Electronic Communications
If you provide contact information to the Firm, we may use it to communicate with you regarding your accounts, services, transactions, documents, and other relationship-related matters. Electronic communications may not always be secure. Clients should avoid sending highly sensitive information through unencrypted email or other insecure channels unless specifically instructed otherwise.
11. State Law Rights
Certain state privacy laws may provide additional rights regarding personal information, including rights to access, correct, delete, restrict certain processing, or receive additional disclosures. To the extent applicable, the Firm will comply with such laws and may provide supplemental privacy disclosures for residents of particular states.
Nothing in this Privacy Policy is intended to limit any rights you may have under applicable state law.
12. Children’s Information
The Firm’s services are not directed to children, and the Firm does not knowingly collect personal information directly from children except as necessary in connection with accounts, trusts, custodial arrangements, or other relationships established by a parent, guardian, or other authorized representative.
13. Changes to This Privacy Policy
The Firm may amend this Privacy Policy from time to time to reflect changes in legal requirements, business practices, or service offerings. When required by applicable law, we will provide clients with a revised privacy notice describing our then-current policies and practices.
14. Questions and Contact Information
If you have questions about this Privacy Policy or the Firm’s privacy practices, please contact:
Efren C. Cleofe III
Chief Compliance Officer
Alpenglow Capital (Alpenglow Private Capital LLC)
132 Greenridge Drive, Reno, Nevada 89509
Tel: (775) 242-8408
Email: ecleofe@a-glowcap.com
15. Annual Notice
The Firm will deliver this Privacy Policy to clients at the commencement of the client relationship and thereafter as required by applicable law. If the Firm shares nonpublic personal information only as permitted by law and has not changed its policies and practices from those previously disclosed, the Firm may rely on any available exception to annual notice delivery to the extent permitted by law.
16. Regulation S-P Notice Summary
In accordance with Regulation S-P, the Firm provides the following summary:
We collect nonpublic personal information about you from applications, forms, transactions, and third parties.
We do not disclose nonpublic personal information about current or former clients to nonaffiliated third parties, except as permitted or required by law.
We restrict access to nonpublic personal information to those who need it to provide services or operate our business.
We maintain safeguards designed to protect your personal information.
By maintaining a relationship with the Firm, you acknowledge receipt of this Privacy Policy to the extent permitted by applicable law; provided, however, that no acknowledgment will be construed as a waiver of any rights you may have under applicable law.