Privacy Policy | Crestone Capital

At Crestone we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal information.

This Privacy Policy applies to our use and handling of your personal information that we obtain in any manner, whether through your use of the crestonecapital.com website, the Crestone Capital Client Portal, the Crestone app, and any other Crestone digital app, and the website’s and apps’ associated services, including email newsletters, associated content distribution platforms, and public Crestone Capital LLC and its affiliates’ online social media accounts (collectively, the “Services”), in subscription or other documents you provide us, or otherwise. By providing us with any of your Personal Data (defined below) or by using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined in our Privacy Policy, and you hereby consent that we will collect, use and share your information as described in our Privacy Policy. We may update this Privacy Policy from time to time and any modifications will be effective immediately upon posting unless we indicate otherwise. We suggest that you review this Privacy Policy periodically for changes.

Collectively, Crestone Capital LLC and its affiliates are referred to herein as “Crestone,” or as “we” or “us.”

You may print a copy of this Privacy Policy by using the “Print” feature in your browser. If you have a disability, you may access this Privacy Policy in an alternative format by contacting info@crestonecapital.com.

This Privacy Policy covers how we treat Personal Data that we gather. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Information Collected Automatically

Like most websites, apps, and similar services, the Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to automatically recognize your web browser, determine your referring page (if provided by the browser), analyze and track your usage of the system, and tell us how and when you visit and use our Services, to analyze trends, learn about our user base, aggregate usage data, enable features of the Services, operate and improve our Services, record session data, and personalize your experience with the Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies: Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. In addition to our own Performance/Analytical Cookies, the Services may contain Performance/Analytical Cookies from third party analytics services.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you related to the website, look in the “preferences” or “options” section of your browser’s menu.

The Cookies themselves and other automatically collected information will not contain any Personal Data, but they may be linked to any Personal Data that you provide on our Services.

We may share any non-personally identifiable information, such as the information automatically collected when you visit crestonecapital.com or any Cookies, with any third party without your knowledge or consent.

Personal Data Collected

The Personal Data that is collected and used by Crestone includes your name, contact information such as physical addresses, email addresses, and phone numbers; your social security number and other government-issued identification number; your IP address and geolocation data; account information regarding your accounts with us and our affiliates, such as your account numbers, account balances, account assets, account transactions, and account histories; account credentials such as login names and passwords; account and routing information regarding your personal bank account; your employment or occupation and related data including employer names, position, and compensation; and any information in any requests, error logs, or other materials you submit related to the Services.

We collect your Personal Data from information you submit to us directly. Your choice to submit Personal Data is completely voluntary, and by providing any Personal Data to us through the Services or otherwise, you are providing us your consent for us to use your Personal Data for the purposes described herein and as necessary for us to fulfill any obligations to you.

How We Use Your Personal Data

We process Personal Data to operate, improve, understand and personalize our business, including but not limited to the Services. We collect and use Personal Data for the following purposes:

To meet or fulfill the reason you provided the information to us.
To provide support and assistance for the Services.
To create and manage your account or other user profiles.
To make investments, wire transfers, and complete other transactions related to your accounts.
To deliver our newsletters, emails and facilitate events.
To manage visitors to our offices and protect our proprietary information and intellectual property.
To respond to user inquiries and fulfill user requests.
To verify your identity to allow access to your account and portfolio information.
To improve and develop our business and the Services, including testing, research, analysis and product development.
To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable state data privacy laws.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about the services that we offer. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at info@crestonecapital.com.

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Sharing of Personal Data

We occasionally hire other companies to provide certain services on our behalf, such as handling the processing and delivery of mailings, providing customer support, monitoring or processing payment and investment transactions, providing software development and maintenance services for our Client Portal and digital app, or performing statistical analysis of our Services. We will only provide those companies access to the Personal Data they need to deliver the service, which includes your name and contact information, account names and information, and information related to your usage of the Services. They are required to maintain the confidentiality of your information and are prohibited from using that information for any other purpose.

We may transfer your Personal Data to a successor entity or individual upon a merger, consolidation, or other reorganization or sale of substantially all assets of the applicable business, in which we participate. We may also transfer your Personal Data between different offices and affiliates of ours for internal management and administrative purposes.

We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on us; (b) protect and defend our rights or property, including to the Services; or (c) act under exigent circumstances to protect the personal safety of users of the Services or the public.

Except as described above, we do not sell, rent, or lease user Personal Data to third parties.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or another sign-on mechanism; limiting access to your computer or device and browser or app; and signing off after you have finished accessing your account. You agree to be responsible for all actions taken under any of your user accounts. You must notify us immediately if you believe that there has been any unauthorized use or access of any of your user accounts. Although we work to protect the security of your accounts and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as we have a business or legal purpose to do so. If you are a client of ours, we will retain your Personal Data for as long as your relationship with us continues, and thereafter for such time as we deem appropriate for purposes of compliance with the books and records requirements of the securities laws. For Personal Data of parties that are not clients, we intend to retain your Personal Data for a reasonable time, not exceeding 24 months. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data collected may be stored and processed in the United States or any other country in which we or our affiliates, subsidiaries or agents maintain facilities, and by providing such Personal Data or using any of the Services, you consent to any such transfer of information outside of your country.

Personal Data of Children

We do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information promptly. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at info@crestonecapital.com. For any residents of California under the age of 18 using the Services or sending us Personal Data, we will permit removal of any information submitted upon the user’s request.

Changes to the Privacy Policy

We’re constantly trying to improve our business and the Services, so we may need to change our Privacy Policy from time to time. Any changes to the Privacy Policy will be posted on this page or a similar page with privacy or legal notices on our website crestonecapital.com, the Crestone Capital Client Portal, and/or in our digital app. We encourage you to periodically review this Privacy Policy to be informed of how we are using and protecting your Personal Data. If you send us any Personal Data or use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: info@crestonecapital.com

STATE SPECIFIC CONSUMER PRIVACY ACT PROVISIONS

The following terms are contained in the privacy laws of the designated states, and they shall apply to the extent such laws are found to apply to us and to you:

California Resident Rights

If you are a California resident, you have the rights set forth in this section pursuant to the California Consumer Privacy Act (the “Cal. CPA”). Please see the “Cal. CPA - Exercising Your Rights” subsection below for instructions regarding how to exercise these rights.

If there are any conflicts between this section and any other provision of this Privacy Policy (not including other provision that expressly applies to residents of other states), and if you are a California resident and Cal. CPA applies, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@crestonecapital.com.

Cal. CPA - Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. Upon your request, we will provide you with the following information:

The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data and the categories of such Personal Data shared or disclosed about you.
The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient.

Cal. CPA - Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the Cal. CPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Cal. CPA - Correction

You have the right to request that we correct any inaccurate Personal Data that we maintain related to you, taking into account the nature of the Personal Data and the purposes of the processing of the personal information.

Cal. CPA - Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Data or are an agent authorized by that person, including without limitation your name and email address, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request at the following link: https://www.crestonecapital.com/contact-us or by calling 888.908.8210 or 303.442.4447.

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with a power of attorney or other written permission acceptable to us to exercise your rights on your behalf, and we may request a copy of this power of attorney or written permission from your Authorized Agent when they make a request on your behalf.

Cal. CPA - Personal Data Sales Opt-Out and Opt-In

In this section, we use the term “sell” as it is defined in the Cal. CPA. Over the past 12 months, we have not sold any Personal Data to third parties. We also do not sell the Personal Data of minors under 16 years of age.

Cal. CPA - We Will Not Discriminate Against You for Exercising Your Rights Under the Cal. CPA

We will not discriminate against you for exercising your rights under the Cal. CPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the Cal. CPA. However, we may offer different tiers of our services as allowed by applicable data privacy laws (including the Cal. CPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Cal. CPA - Categories of Personal Information Under California Law

The types of Personal Data we have collected regarding consumers in the last 12 months are described above in the section titled “Personal Data Collected.” This information falls into the following categories of “personal information” as established by the Cal. CPA:

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, or other similar identifiers.
Certain information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number, employment, employment history, and financial account numbers.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Geolocation data.
Professional or employment-related information.
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

The following information collected falls into the definition of “sensitive personal information” as established by the Cal. CPA:

Social security number, driver’s license, state identification card, or passport number.
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

The Following Personal Data has been shared in the last 12 months as described in the section titled “Sharing of Personal Data.” This information falls into the following categories of “personal information” as established by the Cal. CPA:

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, or other similar identifiers.
Certain information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number, employment, employment history, and financial account numbers.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Geolocation data.
Professional or employment-related information.

The following information that is shared in this manner falls into the definition of “sensitive personal information” as established by the Cal. CPA:

Social security number, driver’s license, state identification card, or passport number.
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

We do not share any Personal Data for payment or other valuable consideration, or for any cross-context behavioral advertising.

Colorado Resident Rights

If you are a Colorado resident, you have the rights set forth in this section pursuant to the Colorado Privacy Act (the “Colo. CPA”). Please see the “Colo. CPA - Exercising Your Rights” subsection below for instructions regarding how to exercise these rights.

If there are any conflicts between this section and any other provision of this Privacy Policy (not including other provision that expressly applies to residents of other states), and if you are a Colorado resident and Colo. CPA applies, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@crestonecapital.com.

Colo. CPA - Personal Data Sales Opt-Out and Opt-In

We do not currently sell your Personal Data, or engage in Targeted Advertising or Profiling using your Personal Data (within the meaning of the Colo. CPA).

Colo. CPA - Access

You have the right to request confirmation as to whether we are processing your Personal Data and to access that Personal Data. This includes the right to access such information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. This right may be exercised no more than twice per calendar year.

Colo. CPA - Deletion

You have the right to request that we delete the Personal Data that we have collected about you.

Colo. CPA - Correction

You have the right to request that we correct any inaccuracies in the Personal Data that we maintain related to you, taking into account the nature of the Personal Data and the purposes of the processing of the personal information.

Colo. CPA - Exercising Your Rights

We will work to respond to your Valid Request within 45 days of receipt, although we may extend this time to the extent permitted by the Colo. CPA. We will not charge you a fee for making a Valid Request once per calendar year, although we may charge you a fee to the extent permitted by the Colo. CPA for the second or subsequent request in a calendar year.

You may submit a Valid Request at the following link: https://www.crestonecapital.com/contact-us or by calling 888.908.8210 or 303.442.4447.

If we refuse to take action on a request, you may also appeal this decision by the same methods, in which case you must provide adequate information to identify the refused request. We will generally respond to a valid appeal within 45 days of receipt, although we may extend this time to the extent permitted by the Colo. CPA. Any concerns about the rejection of any such appeal may be directed to the Colorado Attorney General’s Office.

Colo. CPA - We Will Not Discriminate Against You for Exercising Your Rights Under the Colo. CPA

We will not discriminate against you for exercising your rights under the Colo. CPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the Colo. CPA.

Connecticut Resident Rights

If you are a Connecticut resident, you have the rights set forth in this section pursuant to the Connecticut Personal Data Privacy and Online Monitoring Act (the “Conn. DPOMA”). Please see the “Conn. DPOMA - Exercising Your Rights” subsection below for instructions regarding how to exercise these rights.

If there are any conflicts between this section and any other provision of this Privacy Policy (not including other provision that expressly applies to residents of other states), and if you are a Connecticut resident and Conn. DPOMA applies, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@crestonecapital.com.

Conn. DPOMA - Non-Applicability to Commercial/Business Context

The terms in this “Connecticut Resident Rights” section are restricted to Connecticut residents acting only in an individual or household context. This does not cover a natural person acting in a commercial or employment context, or on behalf of a business entity.

Conn. DPOMA - Personal Data Sales Opt-Out and Opt-In

We do not currently sell your Personal Data, or engage in Targeted Advertising or Profiling using your Personal Data (within the meaning of the Conn. DPOMA).

Conn. DPOMA - Access

You have the right to request confirmation as to whether we are processing your Personal Data and to access that Personal Data (unless such confirmation or access would require us to disclose a trade secret). This includes the right to access such information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

Conn. DPOMA - Deletion

You have the right to request that we delete the Personal Data that we have collected about you.

Conn. DPOMA - Correction

Conn. DPOMA - Exercising Your Rights

We will work to respond to your Valid Request within 45 days of receipt, although we may extend this time to the extent permitted by the Conn. DPOMA. We will not charge you a fee for making a Valid Request once per 12-month period, although we may charge you a fee to the extent permitted by the Conn. DPOMA for the second or subsequent request in a 12-month period or if requests are manifestly unfounded, excessive, or repetitive.

You may submit a Valid Request at the following link: https://www.crestonecapital.com/contact-us or by calling 888.908.8210 or 303.442.4447.

If we decline to take action on a request, you may also appeal this decision by the same methods, in which case you must provide adequate information to identify the declined request. We will respond to a valid appeal within 60 days of receipt.

Conn. DPOMA - We Will Not Discriminate Against You for Exercising Your Rights Under the Conn. DPOMA

We will not discriminate against you for exercising your rights under the Conn. DPOMA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the Conn. DPOMA, except as may be permitted by the Conn. DPOMA.

Utah Resident Rights

If you are a Utah resident, you have the rights set forth in this section pursuant to the Utah Consumer Privacy Act (the “Ut. CPA”). Please see the “Ut. CPA - Exercising Your Rights” subsection below for instructions regarding how to exercise these rights.

If there are any conflicts between this section and any other provision of this Privacy Policy (not including other provision that expressly applies to residents of other states), and if you are a Utah resident and Ut. CPA applies, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@crestonecapital.com.

Ut. CPA - Non-Applicability to Commercial/Business Context

The terms in this “Utah Resident Rights” section are restricted to Utah residents acting only in an individual or household context. This does not cover a natural person acting in a commercial or employment context.

Ut. CPA - Personal Data Sales Opt-Out and Opt-In

We do not currently sell your Personal Data or engage in Targeted Advertising using your Personal Data (within the meaning of the Ut. CPA).

Ut. CPA - Access

You have the right to request confirmation as to whether we are processing your Personal Data and to access that Personal Data. This includes the right to access such information in a format that is portable (if technically feasible) and readily usable (to the extent practicable) that allows you to transmit the data to another entity without impediment.

Ut. CPA - Deletion

You have the right to request that we delete the Personal Data that you have provided to us.

Ut. CPA - Exercising Your Rights

We will work to respond to your Valid Request within 45 days of receipt, although we may extend this time to the extent permitted by the Ut. CPA. We will not charge you a fee for making a Valid Request once per 12-month period, although we may charge you a fee to the extent permitted by the Ut. CPA for the second or subsequent request in a 12-month period or in such other cases where permitted by the Ut. CPA (including cases where the request is excessive, repetitive, technically infeasible, or manifestly unfounded).

You may submit a Valid Request at the following link: https://www.crestonecapital.com/contact-us or by calling 888.908.8210 or 303.442.4447.

Ut. CPA - We Will Not Discriminate Against You for Exercising Your Rights Under the Ut. CPA

We will not discriminate against you for exercising your rights under the Ut. CPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the Ut. CPA, except as may be permitted by the Ut. CPA.

Virginia Resident Rights

If you are a Virginia resident, you have the rights set forth in this section pursuant to the Virginia Consumer Data Protection Act (the “Va. DCPA”). Please see the “Va. DCPA - Exercising Your Rights” subsection below for instructions regarding how to exercise these rights.

If there are any conflicts between this section and any other provision of this Privacy Policy (not including other provision that expressly applies to residents of other states), and if you are a Virginia resident and Va. DCPA applies, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@crestonecapital.com.

Va. DCPA - Non-Applicability to Commercial/Business Context

The terms in this “Virginia Resident Rights” section are restricted to Virginia residents acting only in an individual or household context. This does not cover a natural person acting in a commercial or employment context.

Va. DCPA - Personal Data Sales Opt-Out and Opt-In

We do not currently sell your Personal Data, or engage in Targeted Advertising or Profiling using your Personal Data (within the meaning of the Va. DCPA).

Va. DCPA - Access

Va. DCPA - Deletion

You have the right to request that we delete the Personal Data that we have collected about you.

Va. DCPA - Correction

Va. DCPA - Exercising Your Rights

We will work to respond to your Valid Request within 45 days of receipt, although we may extend this time to the extent permitted by the Va. DCPA. We will not charge you a fee for making a Valid Request twice per calendar year, although we may charge you a fee to the extent permitted by the Va. DCPA for the third or subsequent request in a calendar year or if requests are manifestly unfounded, excessive, or repetitive.

You may submit a Valid Request at the following link: https://www.crestonecapital.com/contact-us or by calling 888.908.8210 or 303.442.4447.

Va. DCPA - We Will Not Discriminate Against You for Exercising Your Rights Under the Va. DCPA

We will not discriminate against you for exercising your rights under the Va. DCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the Va. DCPA, except as may be permitted by the Va. DCPA.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at info@crestonecapital.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by submitting a request at the following link: https://www.crestonecapital.com/contact-us or by calling 888.908.8210 or 303.442.4447. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

INTERNATIONAL USE

We make no representations that this Privacy Policy is appropriate for locations outside of the United States, or whether access to the Services and/or the provision of information through the Services or otherwise from such locations is permitted. Those who choose to use the Services and/or provide us with information from such other locations do so on their own initiative and are responsible for compliance with applicable local laws. The Services are not directed at individuals in the European Union and we do not currently knowingly collect any personally identifiable information from individuals in the European Union.

Date of Latest Update: October 2, 2023