FACTS

WHAT DOES VAULTIS PRIVATE WEALTH LTD. DO WITH YOUR PERSONAL INFORMATION

Why?

Financial companies can 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.

As necessary, we seek certain personal information about you to provide you with investment advice and other administrative services. In addition, we utilize this information to perform such activities as setting up new accounts, sending program documents, and responding to your inquiries. By using our services, you consent to the collection and use of your personal information and any related information in the manner described in this document.

What?

The types of personal information we collect depends on the product or service you and/or your financial advisor (singly and collectively, ÒYouÓ) receive from us. This information may include, but is not limited to: Your name, address, phone number, and email address Your social security number or other unique identifier Your account information, such as account balance, contributions, etc. Your demographic information, such as age, income, investment preferences, etc.

We may share some of this data in order to conduct our everyday business. We will not disclose any nonpublic, personal information about our former clients to anyone, except as required by law.

How?

All financial companies need to share clientsÕ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clientsÕ personal information; the reasons we choose to share; and whether you can limit this sharing.

Reason Financial companies can share your information.

Do we share?

Limit sharing?

For our everyday business purposes—such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations

Yes. See information below

No

For our marketing purposes—to offer our products and services

Yes. See information below

No

For joint marketing with other financial companies

Yes. See information below

N/A

For our affiliatesÕ everyday business purposes—information about your transactions and experiences

No

N/A

For our affiliatesÕ everyday business purposes—information about your creditworthiness

No

N/A

For our affiliates to market to you

No

N/A

For non-affiliates to market to you

No

N/A

For our research purposes

Yes. See information below

No

 

What We do

 

How do we protect your personal information?

We have put appropriate security measures in place to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of personal information. These measures include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We operate secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized individuals have access to the information provided

How do we collect your personal information?

The personal information we collect may be obtained from a variety of sources, such as:

from you when accessing our services directly (e.g., via the Internet) from Your financial advisor (e.g., when completing a proposal/application) from Your employer or an agent of your employer (e.g., plan record keeper, plan service providers, etc.)

Why canÕt you limit sharing?

Federal law only gives you the right to limit: sharing for affiliatesÕ 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 companiesÕ policies may give you additional rights to limit sharing.

 

Definitions

 

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies. Vaultis Private Wealth Ltd. does not share your personal information with non-affiliates for the purpose of their marketing their services to you.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Vaultis Private Wealth Ltd. enters into an agreement with other advisory firms to offer our program to you. Through this arrangement, we may share your personal information for joint marketing activities with their advisory firm.

 

Other Important information

Reasons Financial Companies can share your personal information

We will not make your personal information available to anyone outside of Vaultis Private Wealth Ltd. and its affiliates—except as described above, when instructed by You or where required to comply with law. Please note, however, that there are some exceptions to this policy. First, service providers may have access to your personal information to perform contractually specified services on behalf of Vaultis Private Wealth Ltd. or You. Second, your financial advisorsÕ advisory firm and its affiliates may have access to your personal information to oversee the activities of your financial advisor. Third, if You indicate that You are interested in receiving information about a particular third partyÕs products/services, or opt to receive certain products or services through us, we may provide your personal information to that third party for purposes of fulfilling your request/s.  We will not sell your personal information to anyone and will only disclose information as permitted by Regulation S-P, to unaffiliated organizations that provide services relating to maintaining or servicing your account, such as your record keeper or retirement account service provider.

We reserve the right to change this policy at any time by distributing and/or posting a new privacy policy without notice. We encourage you to review our privacy policy on a regular basis so that you are aware of any changes. In addition, as required by Regulation S-P, we will distribute our privacy policy to you at least once per year.

Your Consent By being part of our program, you consent to the collection and use of your personal information and any related information in the manner described in this Privacy Policy.

 

Questions

At Vaultis Private Wealth Ltd., we want to make your experience with us satisfying and safe. Your privacy is very important to us. If you have further questions, contact us at kk@vaultispw.com