Privacy Policy

INFORMATION WE COLLECT

57 West Capital Advisors, Inc. must collect personally identifiable financial information about its customers to provide financial services and determine investment objectives. 57 West Capital Advisors, Inc. strives to maintain accurate personal information in our client files at all times. However, as personal situations, facts, and data change over time; we encourage our clients to provide feedback and updated information to help us meet our goals. The information we gather may include:

1. Information we receive from you on applications or other forms.
2. Information about your transactions with us or our affiliates.
3. Information we receive from a consumer reporting agency.

INFORMATION WE DISCLOSE

We do not disclose any non-public personal information about our customers or former customers to anyone, except as permitted or required by law, or as necessary to establish and manage accounts for you. In accordance with Section 248.13 of Regulation S-P, we may disclose all of the information we collect, as described above, to certain non-affiliated third parties such as our attorneys, accountants, auditors, and persons or entities that are assessing our compliance with industry standards. We enter into contractual agreements with all non-affiliated third parties that prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we disclose the information. SMS opt in and Phone numbers collected for Communications purposes will not be shared with Third parties and affiliates for Marketing.

INTERNAL PROCEDURES FOR CONFIDENTIALITY & SECURITY

We restrict access to non-public personal information about you to those Employees who need to know that information to provide financial services to you. We consider the level of risk that client information may be misused, altered, stolen, or destroyed, and maintain physical, electronic, and procedural safeguards that comply with federal standards to guard each client's personal financial information. The safeguards include:

1. Ensuring the security and confidentiality of client records and information.
2. Protecting against any anticipated threats or hazards to the security or integrity of client records and information.
3. Protecting against unauthorized access to, or use of, client records or information that could result in substantial harm or inconvenience to any client.
4. Hard copies of client personal and non-personal financial information including information contained on suitability form will be maintained in the Company's files, and will be secured (locked) after normal business hours.
5. Electronic access to client personal financial information will be restricted to the Client's Investment Advisor Representative(s) (IAR), the Chief Compliance Officer (CCO), and other authorized individuals the CCO determines need access.
6. All Associated Persons will be informed of the Company's delivery procedures, security safeguards and destruction/disposal procedures.

REPORTING & DOCUMENTING PRIVACY BREACH

Employees are required to report a breach of client privacy to the Compliance Department as soon as they are aware of the breach. Once reported, the Compliance Department will document the breach via the Privacy Breach and ID Theft log and will ensure the Firm informs the clients affected. A breach is any disclosure or unauthorized accessing of client non-public information by an unauthorized third party. This could include e-mailing or mailing documents to an unintended recipient, loss or theft of documents or information, or any other unauthorized or accidental disclosure of client non-public information.

WRITTEN INFORMATION SECURITY PROGRAM

57 West Capital Advisors Inc. strives to: (a) ensure the security and confidentiality of current and former client records and information; (b) protect against any anticipated threats or hazards to the security or integrity of current and former client records and information; and (c) protect against unauthorized access to or use of current and former client records and information that could result in substantial harm or inconvenience to any current and former client. Accordingly, the following procedures will be followed:

1. Confidentiality:

   Associated Persons shall maintain the confidentiality of information acquired in connection with their employment with the Company, with particular care taken regarding non-public personal information. Associated Persons shall not disclose non-public personal information, except to persons who have a bona-fide business need to know the information in order to serve the business purposes of the Company and/or clients. The Company does not disclose, and no employee may disclose, any non-public personal information about a client or former client other than in accordance with these procedures.

2. Information Systems:

   The Company has established and maintains its information systems, including hardware, software and network components and design, in order to protect and preserve non-public personal information.

3. Passwords & Access:

   Associated Persons use passwords for computer access, as well as for access to specific programs and files. Non-public personal information shall be maintained, to the extent possible, in computer files that are protected by means of a password system secured against unauthorized access.

4. System Failures:

   The Company will maintain appropriate programs and controls (which may include anti-virus protection and firewalls) to detect, prevent and respond to attacks, intrusions, or other systems failures.

5. Electronic Mail:

   As a rule, Associated Persons shall treat e-mail in the same manner as other written communications. However, Associated Persons shall assume that e-mail sent from the Company computers is not secure and shall avoid sending e-mails that include non-public personal information to the extent practicable. E-mails that contain non-public personal information (whether sent within or outside the Company) shall have the smallest possible distribution in light of the nature of the request made.

6. Disposal:

   Electronic media, on which non-public personal information is stored, shall be formatted and restored to initial settings prior to any sale, donation, or transfer of such equipment.

7. Documents:

   Associated Persons shall avoid placing documents containing non-public personal information in office areas where they could be read by unauthorized persons, such as in photocopying areas or conference rooms. Documents that are being printed, copied, or faxed shall be attended to by appropriate Associated Persons. Documents containing non-public personal information, which are sent by mail, courier, messenger or fax, shall be handled with appropriate care. Associated Persons may only remove documents containing non-public personal information from the premises for bona-fide work purposes. Any non-public personal information that is removed from the premises must be handled with appropriate care and returned to the premises as soon as practicable.

8. Electronic Documents:

   Unless specifically authorized by the CCO in writing, Associated Persons are prohibited from maintaining any electronic document that includes non-public personal client information on their personal computers and mobile electronic devices (smart phones, tablets, wearable computers, etc.).

9. Personal Identification Numbers ("PINs"):

   In some cases, the Company maintains access to private account information that enables us to gain access to client accounts for the purposes of monitoring such accounts. Such information may include PINs and passwords provided by clients or brokers that enable on-line access. Such information is found in the secure database of the company and/or in the clients' physical files. To access the database, authorized Company employees must use their assigned password to gain entry each time. The physical files are to be kept organized and the office locked when not in use. Associated Persons agree that they are obligated to tightly monitor this information at all times and use it only to affect the management of the Company's strategies in the account. Upon termination of advisory services, all electronic PINs and passwords maintained in client files will be destroyed.

10. Discussions:

    Associated Persons shall avoid discussing non-public personal information with, or in the presence of, persons who have no need-to-know access. Associated Persons shall not discuss non-public personal information in public locations, such as elevators, hallways, public transportation, or restaurants.

11. Access to Offices and Files:

    Access to offices, files or other areas where non-public personal information may be discussed or maintained is limited, and Associated Persons shall enter such locations for valid business purposes only. Meetings with clients shall take place in conference rooms or other locations where non-public personal information will not be generally available or audible to others. Visitors shall generally not be allowed in the office unattended.

12. Old Information:

    Client information that, at the sole discretion of the CCO, is no longer required to be maintained shall be destroyed and disposed of in a manner approved by the CCO.

DOCUMENT SHREDDING POLICY

As general policy, the Firm has adopted a procedure of contracting with a third-party service vendor to shred personally identifiable information relating to individual clients. Items that have been deemed outdated by associated persons during the course of their review of client files (typically older than 7 years) are required to be placed in the shredding bins for the vendor to professionally destroy. Additional items that require shredding include draft work papers or any other document that has any personal identifiable information on it.

TRAINING

The Company will provide guidance and periodic training to employees relating to information security risks and responsibilities. The Company will retain documentation of the agenda of those training sessions and the topics covered. The Company will also retain a dated list of the employees who received such training.

IDENITY THEFT

An identity thief can obtain a victim's personal information through a variety of methods. Therefore, Associated Persons shall take the following actions to prevent identity theft:

1. When providing copies of information to others, Associated Persons shall ensure non-essential information is removed and that non-public personal information not relevant to the transaction is removed or redacted.
2. The practice of “dumpster diving” provides access for a would-be thief to a victim's personal information. Therefore, when disposing of paper documents, paperwork containing non-public personal information shall be shredded or otherwise destroyed.
3. To avoid a fraudulent address change, requests must be verified before they are implemented, and confirmation notices of such address changes shall be sent to both the new address and the old address of record.
4. Associated Persons may be deceived by pretext calling, whereby an “information broker” or “identity thief” posing as a client, provides portions of the client's non-public personal information (i.e., Social Security number) in an attempt to convince an Associated Person to provide additional information over the phone, which can be used for fraudulent purposes. Associated Persons shall make every reasonable precaution to confirm the identity of the client on the phone before divulging non-public personal information.
5. The Company prohibits the display of Social Security numbers on any documents that are generally available or widely disseminated (i.e., mailing lists, quarterly reports, etc.).

Associated Persons could be responsible for identity theft through more direct means. Insider access to information could permit a dishonest Associated Person to sell consumers' personal information or to use it for fraudulent purposes. Such action is cause for disciplinary action at the Company's discretion, up to and including termination of employment as well as referral to the appropriate civil and/or criminal legal authorities.

SMS Terms & Services

1. SMS Consent Communication:

   The information (Phone Numbers) obtained as part of the SMS consent process will not be shared with third parties for marketing purposes.

2. Types of SMS Communications:

   If you have consented to receive text messages from 57 West Capital Advisors, Inc., you may receive messages related to the following:

   • Conversational (External)
   • Appointment Reminders
   • Follow Up Messages
3. Message Frequency:

   Message frequency may vary depending on the type of communication. You may receive up to 5 SMS messages per day depending on your engagement.

4. Potential Fees for SMS Messaging:

   Please note that standard message and data rates may apply, depending on your carrier's pricing plan. These fees may vary if the message is sent domestically or internationally.

5. Opt-In Method:

   You may opt-in to receive SMS messages from 57 West Capital Advisors, Inc. in the following ways:

   • Verbally, during a conversation
6. Opt-Out Method:

   You can opt out of receiving SMS messages at any time. To do so, simply reply "STOP" to any SMS message you receive. Alternatively, you can contact us directly to request removal from our messaging list.

7. Help:

   If you are experiencing any issues, you can reply with the keyword HELP. Or, you can get help directly from us at +1 (833) 457-5757

8. Standard Messaging Disclosures:
   • Message and data rates may apply.
   • You can opt out at any time by texting "STOP."
   • For assistance, text "HELP" or visit our https://57west.us/discover/privacy-policy to see our Privacy Policy and our Terms and Conditions.
   • Message frequency may vary.