Privacy Policy

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Securities offered through Britehorn Securities, a registered broker-dealer (member FINRA/SIPC).  ∙ www.britehornsecurities.com ∙ 1401 Lawrence St., Suite 1600, Denver, CO 80202, USA. 720-465-5305. Britehorn Securities and S. Pointe Capital are not affiliated entities.

Privacy Policy & California Privacy Notice

Introduction

This Privacy Policy & California Privacy Notice ("Privacy Policy") outlines the privacy practices of S. Pointe Capital, a whole owned subsidiary of South Pointe Investments Group, LLC  (referred to as the “Firm,” “we,” “our,” or “us”). It details how we collect, use, share, and disclose Personal Information, including information collected through our website (the “Site”). This Privacy Policy forms a legally binding agreement between you and the Firm regarding your use of the Site, in accordance with applicable law.

Personal Information We Collect

When you visit the Site or interact with us during normal business activities, we may collect certain nonpublic personal information (“Personal Information”) to manage our relationship with you and meet your investment needs. The types of Personal Information we might collect include:

• Personally identifiable information such as names, addresses, contact details, signatures, nationality, tax identification or passport numbers, date of birth, place of birth, photographs, copies of identification documents, bank account details, asset or net worth information, investment activities, and other personal details.
• Background information obtained through pre-employment screening or customer due diligence, which may include credit history, criminal records, and other special categories of personal data (e.g., ethnic origin, health, disability).

Sources of Personal Information

We may gather Personal Information from:

• Your communications with us
• Your transactions with us
• Service providers
• Affiliates
• Nonprofit organizations
• Publicly available information (including social media)
• Government entities

How We Use Personal Information

Personal Information is used for purposes including:

• Providing and managing our products and services
• Administering our contractual relationship with you
• Processing requests and inquiries
• Offering new products and services
• Processing transactions and maintaining accounts
• Verifying identity and communicating with you
• Enhancing the Site
• Protecting the security and integrity of the Site
• Preventing and investigating fraud or unlawful activity
• Complying with legal requirements

How We Share Personal Information

We do not disclose Personal Information to nonaffiliated third parties, except as necessary to manage a client’s account or as permitted by law. We do not sell Personal Information.

How We Protect Personal Information

We strive to safeguard Personal Information using commercially reasonable efforts. Access to Personal Information is limited to employees who need it to provide our products or services.

Notice for Residents of the European Economic Area and United Kingdom

If you are in the European Economic Area (EEA) or the United Kingdom (UK), you have certain rights regarding your personal data:

• The right to access your information
• The right to rectify inaccurate or incomplete information
• The right to erase your information (the “right to be forgotten”)
• The right to restrict the processing of your information in certain circumstances
• The right to object to our use of your information, particularly if it’s for direct marketing
• The right to request data portability
• The right to withdraw consent where applicable
• The right to lodge a complaint with a supervisory authority

In the UK, complaints can be directed to the Information Commissioner’s Office (ICO). Your personal data may be transferred outside the UK and EEA, and we ensure that such transfers comply with GDPR requirements through appropriate contractual agreements.

Contact Us

For questions or comments about this Privacy Policy, please contact us at info@spointecap.com.

Privacy Notice For California Consumers

Last updated: October 2023

This notice includes disclosures required by the California Consumer Privacy Act (CPRA) and applies to California residents (“consumers” or “you”), including job applicants and employees.

Information We Collect

In the past 12 months, we have collected and disclosed the following categories of personal information:

• Identifiers: e.g., names, email addresses, social security numbers, driver’s license numbers
• Other personal information: e.g., signatures, phone numbers, employment history, financial information
• Protected classification characteristics: e.g., age, citizenship

Sources of Personal Information

We collect Personal Information from:

• Your communications with us
• Observations of your actions on our website
• Service providers (e.g., banks, brokers, auditors)
• Affiliates not under our brand
• Nonprofit organizations
• Government entities

We do not sell or share Personal Information of consumers under 18 years of age.

Purpose for Collection and Use

We use Personal Information for purposes including:

• Providing information about our products and services
• Updating you on performance and other matters
• Performing services (e.g., account servicing, payment processing)
• Auditing, legal compliance, and fraud detection
• Debugging, research, and improvement of services
• Short-term use that does not involve third-party disclosure
• Employment-related interactions

Sensitive personal information is used only as authorized under CPRA.

Disclosing Personal Information

We may disclose Personal Information to:

• Service providers
• Affiliates
• Business partners
• Legal or government authorities
• Potential business transferees
• Authorized third parties as per your instructions

We have not sold or shared Personal Information for cross-context behavioral advertising in the past 12 months.

Rights of California Consumers

Under CPRA, California consumers have the following rights:

• Requesting access to specific pieces and categories of Personal Information
• Requesting deletion of Personal Information
• Opting out of sales or sharing of Personal Information for advertising
• Requesting correction of inaccurate information
• Limiting use of sensitive personal information
• Not being discriminated against for exercising CPRA rights

Requests should be sent to info@spointecap.com. We will respond to verifiable requests within 45 days. Requests for access or data portability are limited to twice per 12-month period. You may designate an authorized agent to make requests on your behalf.

Questions

For questions regarding this Notice, please contact us info@spointecap.com.