Boveda Asset Management, Inc

Privacy Statement

FACTS	WHAT DOES BÓVEDA ASSET MANAGEMENT DO WITH YOUR PERSONAL INFORMATION?
How?	All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Bóveda Asset Management chooses to share; and whether you can limit this sharing.
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and employment information account balances and transaction history credit history and investment experience

Reasons we can share your personal information	Do we share?	Can you limit this sharing?
For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes - with service providers we use to offer our products and services to you (please see below to limit the ways in which we contact you)	Yes	No
For joint marketing with other financial companies	No	We don't share
For our affiliates' everyday business purposes - information about your transactions and experiences	Yes	No
For our affiliates' everyday business purposes - information about your creditworthiness	Yes	Yes
For our affiliates to market to you	Yes	Yes
For non-affiliates to market to you	No	We do not share

To limit our sharing	Call 1-888-368-5640 our menu will prompt you through your choices Online banking customers - log on to a secure session at 1baminc.com, and choose "Change Privacy Preferences" under the "Account Services" tab. Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we can continue to share your information as described in this notice. However, you can contact us at any time to limit our level of sharing.
To limit direct marketing	To limit our direct marketing to you by mail or telephone, call 1-888-368-5640 our menu will prompt you through your choices Online banking customers - log on to a secure session at 1baminc.com, and choose "Change Privacy Preferences" under the "Account Services" tab. Please note: A Do Not Call election is effective for five years (or while you are an active consumer customer, if longer). The Do Not Mail election is effective for three years. You may continue to receive marketing information in regular account mailings and statements, when you visit us online. You may also be contacted to service your account or participate in surveys. If you have an assigned client manager or team, they may continue to contact you to assist you in managing your portfolio or account relationship.
Questions?	Call 1-888-368-5640 or go to 1baminc.com/privacy
Who we are
Who is providing this notice?	Bóveda Asset Management, Inc and any of its affiliates presently known or to be formed or acquired in the future.

What we do
How does Bóveda Asset Management protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. For more information visit 1baminc.com
How does Bóveda Asset Management collect my personal information?	We collect your personal information, for example, when you: open an account or make deposits or withdrawals from your accounts seek advice about your investments We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can't I limit all sharing?	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 non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply individually unless you tell us otherwise. Any account holder may express a privacy preference on behalf of the other joint account holders.
Definitions
Affiliates	Companies related by common ownership or control. They can be financial and non-financial companies. Our affiliates, if and when established will be properly identified as an affiliate of Bóveda Asset Management, Inc and listed in this section of this website. Affiliates will include financial institutions we own or control.
Non-affiliates	Companies not related by common ownership or control. They can be financial and non-financial companies. Bóveda Asset Management does not share with non-affiliates for the purpose of marketing to you.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Bóveda Asset Management does not jointly market.

Other important information

Important Notice about Credit Reporting: We may report information about your account(s) to credit bureaus and/or consumer reporting agencies. Late payments, missed payments, or other defaults on your account(s) may be reflected in your credit report and/or consumer report.

Do Not Call Policy. This Privacy Policy constitutes Bóveda Asset Management's Do Not Call Policy under the Telephone Consumer Protection Act for all consumers. Bóveda Asset Management maintains an internal Do Not Call preference list. Do Not Call requests will be honored within 30 days and will be effective for at least five years from the date of request. No telemarketing calls will be made to residential or cellular phone numbers that appear on the Bóveda Asset Management Do Not Call list.

Nevada residents: We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions in the To limit direct marketing section. For more information contact us at 1-888-368-5640; info@1baminc.com, or contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; 702-486-3132; BCPINFO@ag.state.nv.us.

Vermont: We automatically treat customers with a Vermont mailing address as having limited sharing with our affiliates as provided on page one.

Trust accounts, for which Bóveda Asset Management is the trustee, are protected under special rules of confidentiality. Trust account information is not shared for marketing purposes without specific consent.

Bóveda Asset Management's Financial Advisors: If your financial advisor's affiliation with Bóveda Asset Management ends and they join a non-affiliated registered investment advisory firm or securities broker-dealer, your financial advisor may be permitted to use limited information to contact you to join their new firm, as a usual means to continue to service and maintain your accounts. The information they may use is limited to your name, address, email address, phone number and account title.