Notice of Client Privacy Policy

Protecting Your Privacy

Altura Capital Group, LLC ("Altura") believes that protecting client privacy is vital to the success of its business. Accordingly, we have adopted a policy that is reasonable designed to protect the confidentiality and security of information that we collect from our clients. We do not share non-public information about you ("Information") without your consent, except for the specific purposes described below, in accordance with all applicable laws and regulations. This Notice describes the Information that we may gather and the circumstances under which we may share it.

Why We Collect and How We Use Information

We limit the collection and use of Information to the minimum we require to deliver superior service to you. Such service includes advising you about our products, services and other opportunities, maintaining your accounts with Altura, processing information that you provide to us, processing transactions requested by you or other persons authorized by you and administering our business.

How We Gather Information

We get most Information directly from you when you consent to our obtaining it, enter into a contractual agreement with us, or access and use our database or other products and services, whether in person, by telephone, electronically or through our website ("Site"). We may verify this Information or get additional Information from consumer reporting agencies or other legitimate sources. This Information may relate to your finances, business partners, avocations or other corporate (or personal) characteristics, as well as transactions and interactions with or through us or other third parties.

Information We Collect Through Technology

We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site. The Site may also use cookies. (Cookies are pieces of information that a website sends to your computer while you are viewing the website.) For instance, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are. Using the settings of your internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser Help menu to learn the correct way to modify your cookies. If you choose to turn off cookies, you may not have access to many features that makes your browsing of our Site smoother, and some of our services may not function properly. You may at any time delete any cookies set by using the relevant option of your internet browser or by deleting the cookies on your hard drive.

The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. We may use this information to measure site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

How We Protect Information

Our employees and representatives acting on our behalf are required, as a matter of policy and practice, to protect the confidentiality of Information and to comply with our established polices that are designed to achieve those goals. They may access such Information only when there is an appropriate reason to do so, such as to administer or offer our products and services. We also maintain physical, electronic and procedural safeguards that we believe are reasonably designed to protect Information and comply with applicable laws and regulations. Employees and representatives who violate our privacy policies will be subject to a disciplinary process.

Also, we use a variety of proven and generally accepted protections to maintain the security of your online session and navigation on our website. For example, we make extensive use of firewall barriers and authentication procedures. We may also place cookies and similar files on your hard drive for security purposes, to facilitate site navigation, and/or to personalize your experience on our site.

Disclosure of Information

We may disclose Information when we believe it necessary to conduct our business or where disclosure is required by applicable law or regulation. For example, Information may be disclosed for audit or research purposes, to attorneys or other professionals engaged by us, or to regulatory agencies or law enforcement to help, among other things prevent fraud or money laundering. In addition, we may disclose Information to other related companies or third party service providers, and consumer reporting agencies to (i) enable them to provide business services to us, such as performing computer-related or data maintenance or processing services to us, (ii) facilitate the processing of services or transactions requested by you, (iii) assist us in offering our products and services to you, or (iv) for credit review or reporting purposes. We may also provide Information to our affiliates or non-affiliated companies with whom we have we have joint marketing or other agreements, such as an agreement with another advisory firm or financial institution, trust company, or other company enabling us to offer you products or services. Except in those specific, limited situations, without your consent, we will not make any disclosures of Information to other companies or individuals who may want to sell or market their products or services to you. For example, without your consent, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer. Moreover, it is our policy to require all third parties that are to receive any Information to sign and deliver strict confidentiality agreements.

Our Former Clients

Even if you are no longer a client, our privacy policy will continue to apply to you.

To Whom This Policy Applies

This privacy policy applies to Altura and all of its employees and affiliates. Further, this privacy policy applies to products and services provided by Altura in the United States and which are used primarily for institutional purposes.

Access to and Corrected Information

Upon your written request, we will make available for your review any file that we may maintain with respect to your Information, provided however, that any Information collected in connection with, or anticipation of, any claim or legal proceeding will not be made available. If you notify us that any Information is incorrect, we will review it. If we agree with your assessment, we will use reasonable efforts to correct our records. If we do not agree with your assessment, you may submit a statement of dispute to us, which we may, but are not required to, include in any future disclosure of the disputed Information.

Further Information

We reserve the right to modify or otherwise change this privacy policy at any time in our sole discretion. The examples contained within this privacy policy are illustrations only and are not intended to be exclusive. Further, we believe that this notice has been reasonably designed to comply with all applicable laws and regulations. You may have additional rights under foreign or other domestic laws or regulations that may apply to you.