PRIVACY NOTICE:

Capstone Partners, L.P. respects your right to privacy and recognizes our responsibility for protecting the privacy and security of the personal information we receive from you.  We have always been committed to securing the confidentiality and integrity of your personal information.  We are proud of our privacy practices and want our current and prospective customers to understand what information we collect and how we use it.  This notice refers to Capstone Partners, L.P. and its affiliated companies, CSP Securities, LP, Capstone Advisors SA and Capstone Advisors Ltd, and we refer to such companies collectively herein using the terms “we” and “our”.

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Why We Collect Your Information

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We, in connection with our business dealings with clients, investors and other third parties, hold personal information about you so that we can (i) know who you are and thereby prevent unauthorized access to your information, (ii) design and improve the services we offer, and (iii) comply with the laws and regulations that govern us.

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What Personal Information We Collect

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We may collect the following types of personal information about you:

• Information about your identity, such as your name, address, e-mail address, phone and fax number, company name, job title and social security number;

• Information about your transactions;

• Information about your personal financial profile, such as your risk tolerance levels, goals and objectives, assets, liabilities, savings and investments.

• Where such personal information is held by us, it is held solely for the purpose of conducting our financial services business.

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What Sources We Obtain Your Information From

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We collect personal information about our customers and clients, such as you, from the following sources:

• Information that you voluntarily provide to us, for example when you communicate with us via e-mail or other channels; information we receive from you on contracts or other forms; such as risk tolerance questionnaires and/or investment policy statements.

• Information about your transactions with our affiliates or others.

• Any personal information held by us can be made available on a group wide basis to our staff where it is relevant to the group’s business activities. 

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If you visit our web site, information we collect via a web server, is often referred to as a “cookie.”  Cookies indicate where a site visitor has been online and what has been viewed.

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What Information We Disclose

 

We do not disclose any nonpublic personal information about our customers, clients or former customers or clients to anyone, except to affiliates, as permitted or required by law, or for regulatory compliance.  Moreover, we will not release information about our customers, clients or former customers or clients unless one of the following conditions is met:

• We receive your prior written consent.

• We believe the recipient to be you or your authorized representative.

• We are required by law to release information to the recipient.

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Confidentiality and Security

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We maintain physical, electronic and procedural safeguards to guard your personal information.  We also restrict access to your personal and financial data to our authorized associates who have a need for these records.  We require all non-affiliated organizations and vendors to keep client data confidential and use appropriate security measures to protect it. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.

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Your Rights

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You have the right to know what personal information we process about you and may request a copy. You are also entitled to have incorrect personal information about you corrected and you may in some cases ask us to delete your personal information.

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Changes to Our Privacy Notice

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We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws; however, our policy about obtaining and disclosing information may change from time to time.  We will provide you with notice of any material change to this policy before we implement the change.

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CUSTOMER IDENTIFICATION PROGRAM NOTICE:

To help the government fight the funding of terrorism and money laundering activities, United States Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account with an institution based in the United States. What this means to you: When you open an account in the United States, we will require your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

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Business Continuity Plan

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CSP Securities, LP has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.  With that in mind, we are providing you with this information on our business continuity plan.

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Contacting Us – If after a significant business disruption you cannot contact us as you usually do by phone at +1 (972) 980-5800 or by e-mail at thargis@csplp.com, you should call our alternative number +1 (214) 882-4180.  If you cannot access us through either of those means, you should contact the entities that you have invested in directly for instructions on how you may access investment information, invest additional funds and/or provide you with prompt access to funds and securities.

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Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the Firm’s books and records, and allowing our customers to transact business.  In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.  Our business continuity plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and ensuring our customers prompt access to their investments if we are unable to continue our business.

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Since you invest directly, the entities in which you have invested are responsible for those records they maintain on your behalf. Additionally, when you invest with our assistance, we take steps to ensure that you have paper or electronic copies of everything that you have signed and/or to which you have obligated yourself, which results in your having access to essentially the same records as we have, should you be unable to contact us during an emergency situation. Finally, while most transactions done through us are not time sensitive, every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption. Thus, while each entity with which you have invested desires to restore its own operations and be able to complete existing transactions and accept new transactions and payments within a short period of time, your orders and requests for funds and securities could be delayed during this period.

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 Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district   where our firm is located, the city where we are located, or the whole region.  Within each of these areas, the severity of the disruption can also vary from   minimal to severe.  In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to     recover and resume business within two business days.  In a disruption affecting our business district, city, or region, we will transfer our operations to a site   outside of the affected area, and recover and resume business within five business days.  In either situation, we plan to continue in business and will notify   you through www.csplp.com or our customer emergency number, +1 (214) 882-4180, how to contact us.  If the significant business disruption is so severe   that it prevents us from remaining in business, we will ensure our customer’s prompt interface with the respective companies and entities that have   provided investment products to you, through us.

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 This plan is subject to modification, an updated summary will be promptly mailed to customers.

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 Complaint Notification

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 Please direct complaints to: CSP Securities, LP, Attn: Compliance, 13355 Noel Road, Suite 1600  Dallas, Texas; +1 (972) 980-5800.

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 SIPC Disclosure (FINRA Rule 2266)

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 Customers may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at www.sipc.org or +1 (202) 371-8300.

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 FINRA Brokercheck (Public Disclosure Program)

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 The FINRA Broker Check (Public Disclosure) Program allows the public to obtain current regulatory information about FINRA member firms and registered   representatives.  You can obtain more information by visiting the FINRA website at: www.FINRA.org or by calling the FINRA BrokerCheck Hotline Number: 1-   800-289-9999.  In addition, please be aware that available on the FINRA website is an investor brochure that includes information describing the FINRA   BrokerCheck resource.

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 For More Information

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 If you have questions about any of our policies or procedures, please contact us at +1 (972) 980-5800 or thargis@csplp.com.

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