CHAPWOOD CAPITAL INVESTMENT MANAGEMENT, LLC

We Take Important Steps to Help Safeguard the Personal Information We Collect About You

At Chapwood Capital Investment Management, LLC, we are committed to safeguarding your personal information. This notice describes the personal information we collect and how we handle and protect it. As part of our normal business practices, we distribute our policy annually or when significant changes are made to it.

This notice contains important information about how we share information and applies to personally identifiable information about an individual’s current or former client relationships.

Why and How We Collect Personal Information
We collect personal information to enable us to provide products and services to you and to improve and conduct our business. For example, we collect personal information to:

  • Help us evaluate your financial needs
  • Process your requests and transactions
  • Inform you about products and services that may be of interest to you
  • Provide you with effective and efficient customer service
  • Assess products and services

We collect information from a variety of sources, including:

  • Account applications and other forms that you submit to us, which provide information such as your name, address, e-mail address, telephone number, date of birth, Social Security number or other tax identification number, occupation, financial goals, assets and income
  • Your transactions or experiences with us

Who Has Access to Personal Information
Only those employees who need to have access to personal information to perform their jobs are authorized to use your personal information. They may need access to your personal information to conduct business on your behalf, service your account, help you pursue your financial objectives, and to conduct our business.

How We Protect Personal Information
Employees who have access to your personal information are required to maintain and protect the confidentiality of that information and must follow established procedures. We maintain physical, electronic and procedural safeguards to protect your personal information to comply with applicable laws and regulations.

Why and How We Share Information With Our Affiliates
We may share your personal information (as described above in “Why and How We Collect Personal Information”) with our affiliates as required or permitted by applicable law. Our affiliates are companies controlled or owned by us, or are under common control with us.

For example, we may share information with our affiliates in order to:

  • Provide you with products and services that you have requested
  • Service your account
  • Process transactions relating to your account

We may share your name, contact information and information about our transactions and experiences with you with our affiliates so that they or we may offer products or services that may be appropriate for you and to conduct business. We also may share with our affiliates personal information that was collected to determine your eligibility for products and services you previously requested from us (“eligibility information”). An example of this type of information would be information used to determine creditworthiness, such as net worth, income or credit history. (See “How You Can Direct How Your Information Is Shared and Presented” below.)

Why and How We Share Information With Nonaffiliated Third Parties
We do not and will not rent or sell your personal information. However, we may share your personal information (as described above in “Why and How We Collect Personal Information”) with companies that we hire to perform services for us, such as vendors that provide data processing, computer software maintenance and development, transaction processing and
marketing services.

In addition, to help us service your account or to offer products and services that may meet your financial needs, we may share your name, contact information, and information about our transactions and experiences with you with nonaffiliated financial service institutions with which we have agreements to market financial services or products that we jointly offer, endorse or sponsor. Nonaffiliated financial service institutions include fund companies, securities brokers, clearing brokers and banks.

In the two cases above, we require these nonaffiliated companies and nonaffiliated financial service institutions with whom we share your personal information to agree to limit the use of such information to the purposes for which it was provided.

Finally, we may disclose personal information to others, including nonaffiliated companies and regulatory authorities, as either required or permitted by applicable law. For example, we may disclose personal information to:

  • Comply with investigations by regulatory authorities or law enforcement agencies
  • Protect against or prevent actual or potential fraud, unauthorized transactions, claims or
    other liabilities

How You Can Direct How Your Information Is Shared and Presented
To protect the confidentiality of your information and respect your wishes for how it is used, we offer “opt out” alternatives. These permit you to direct how your information is shared with our affiliates and how it is presented in statements.

Eligibility Information Sharing With Our Affiliates
If you do not want us to share eligibility information (see “Why and How We Share Information With Our Affiliates” above for a definition of “eligibility information”) about you with our affiliates, you may opt out of these disclosures. That is, you may instruct us not to share eligibility information with our affiliates.

Please note that, even if you direct us not to share eligibility information with our affiliates, we may still share your personal information—including eligibility information—with our affiliates as permitted by law, for example, to process transactions or to service your account. Moreover, we may also share certain other types of non-eligibility information with our affiliates, such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us.

If you wish to opt out of the disclosure of eligibility information, please call Chapwood Investments at 972-865-2225.

Special Note for California and Vermont Accounts
To comply with California and Vermont laws, we do not share information with nonaffiliated third parties for accounts with a primary mailing address in these states, except as required or permitted by applicable state law. Additionally, Vermont accounts are automatically opted out of the sharing of eligibility information with our affiliates. If this paragraph applies to your accounts and you would like to have your statements householded, please contact your Financial Advisor at the toll-free number listed on your account statements.

Accessing and Revising Your Personal Information
We strive to keep our customer files complete and accurate. Most of the information we collect about you is from applications that you submit to us to obtain our products or services and is reflected in account statements and other documentation you receive from us.

We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have questions or concerns about your personal information or this privacy notice, please contact us.

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