Privacy Policy

What Do We Do with Your Personal Information?

Riverplace Capital Management (“RCM”) recognizes that protecting the privacy of the confidential personal information we collect about you is an important responsibility. The following information will help you understand our privacy policy and how we will handle and maintain confidential personal information as we fulfill our obligations to protect your privacy. "Personal Information" refers to the nonpublic financial information we obtain in providing you with our services.

Information We Collect
We collect personal information to help us serve your financial needs, provide customer service, and fulfill legal and regulatory requirements. The type of information that we collect varies according to the services involved, and may include:

• Information we receive from you on applications and related forms (such as name, address, social security number, assets, and income)
• Information about your transactions and relationships with us and your brokerage firm (such as investments and account balances)
• Information we receive from third parties to service your accounts

Information Disclosed in Administering Your Accounts
We do not disclose any personal information about current or former clients, without their authorization, to non-affiliated third parties except as permitted or required by law. We do not sell any personal information about you to any third party. In the normal course of business, personal information may be shared with persons or entities involved in servicing and administering your accounts such as your broker, and other service providers and affiliates assisting RCM.

Procedures to Protect Confidentiality and Security of Your Personal Information
Our procedures limit the access to nonpublic personal information about you to those employees, representatives, and service providers who need to know that information to perform services for you on behalf of RCM. We educate our employees on the importance of protecting the privacy and security of confidential personal information. We also maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

We will update our policy and procedures where necessary to ensure that your privacy is maintained and that we conduct our business in a way that fulfills our commitments to you. If we make any material changes in our privacy policy, we will make that information available to you through written communication.