Privacy Policy

This privacy policy or “policy” explains how Steward’s capital management, LLC, the manager of the funds, and their subsidiaries and affiliates, including the investment products it sponsors or manages from time to time (collectively, “Stewards Capital Management”, “we”, “our”, and “us”) collect and protect Personal Information (as defined below). If you have any questions that this Policy does not address, please contact us at [email protected]. By creating an account on any Stewards Capital Management website/site (a “Stewards Capital Management website/Site”) or by otherwise submitting Personal Information to us through a Stewards Capital Management Site, you give your consent to the collection and use of your Personal Information as explained in this Policy. This Policy is part of our Terms of Service and all capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service.
Stewards Capital Management’s Policy applies to current and former Stewards Capital Management clients and any other users of any Stewards Capital Management websites. The term “Personal Information” refers to non-public information that personally relates to or identifies you as an individual or entity.
Updates and Changes to Our Privacy Policy Please note that, in the event of a change in policy, a revised Policy will promptly be posted to the Stewards Capital Management website. You agree to accept posting of a revised Policy electronically on the Stewards Capital Management Site as actual notice to you. Any dispute over our Policy is subject to this notice.

How and Why, We Gather Information

When you sign up to participate on a Stewards Capital Management Site, you may be asked to provide information such as your full legal name, address and date of birth, along with other personal information that is required to verify your identity and fulfill our legal and regulatory requirements. This information will also be used to transact your business and communicate with you. From time to time, we may request additional information to help us further assess your needs and preferences.

Types of Information We Collect

The information we collect and maintain about you is provided during the course of your entering into transactions with private issuers who have engaged Stewards Capital Management to provide certain services in the context of a private securities transaction or trading through Stewards Capital Management. This Personal Information, not available publicly, comes from the following sources:

• Information you provide to us when you fill out documents, complete a form or make a request for services, including your name, address, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and liabilities and/or income details and confidential documentation used to verify those details, telephone number, e-mail address and similar information; and information from your transactions with us, such as your sale proceeds or investment amount.

How We Protect Your Information

Keeping Information Safe
We limit access to the Personal Information you provide us to those employees who need access to that information to provide you with services related to the transactions you are entering into through the Stewards Capital Management Sites. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information. We have invested in software, systems and procedures aimed at offering you a safe and secure transaction environment and protect your personal, financial and historical transaction information. While no security system is absolutely impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available. We will delete your Personal Information when it is no longer needed for these purposes. If we cannot delete it, for technical reasons, entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

The Importance of Being Accurate

We have security standards and procedures in place designed to prevent unauthorized access to your Personal Information. A key part of this process helps ensure that the Personal Information we have about you is accurate and up to date. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information.

Your Rights Over Personal Information

Subject to applicable local law, you have rights regarding your Personal Information, including access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the lodgment of a claim to your local data protection authority.
If you would like to discuss or exercise the above rights, please contact us using the details set out at the end of this Privacy Policy.

An Ongoing Commitment to Your Privacy

We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you redeem or otherwise dispose of your investments with us, Stewards Capital Management will retain your information for regulatory compliance, internal record-keeping, and other legal purposes.

How Information Helps Both You and Us

Our mission is clear: to build transparent, familiar investment products that facilitate access to the digital asset class. Information about you and your accounts plays a key role in our ability to succeed in this mission. For example, we use information about you to:

• Respond more accurately and efficiently to your requests for assistance; and
• Secure your investments and help protect you and Stewards Capital Management from fraud.

Sharing Your Information with Unaffiliated Third Parties

We Limit the Sharing of Information
To protect your privacy, we limit the sharing of your Personal Information outside of Stewards Capital Management. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:

• To help us provide our services to you and/or to improve our services, we engage qualified and reputable third parties to help us to carry out certain functions such as account processing, client services and/or data collection relevant to our business. For example, in each case where you may invest through a Stewards Capital Management Website, we share your Personal Information with third party service providers to perform regulatory-required background checks, with certain technology providers to facilitate document execution, and with third parties that perform execution and clearing services on your behalf. Pursuant to our agreements with these service providers, their ability to use your Personal Information is specifically limited to the service being provided.
• As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
• Stewards Capital Management may share information with our affiliates if the information is required to provide the services you request. An affiliate is a company that we own or control, or with which there is common ownership with us.
• Stewards Capital Management also reserves the right to disclose your personal information where required by law to regulatory, law enforcement or other government authorities, including during routine regulatory examinations. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.
• Notwithstanding the foregoing, all Personal Information shall be dealt with in accordance with any local legislation, including but not limited to the General Data Protection Regulation, to the extent Stewards Capital Management is or becomes subject to such regulation.

Reviewing, Changing or Correcting Information

You are responsible for helping us to maintain the accuracy and completeness of your Personal Information and other data. We urge you to review your information regularly to ensure that it is correct and complete. If you would like to review your Personal Information or if you believe that any of your Personal Information is incorrect, or if you have any questions regarding your Personal Information, or this Privacy Policy, please contact us at [email protected].

Third Party Sites

If at any time you choose to purchase a product or service offered by another company, any Personal Information you share with that company will be subject to the privacy policies of the applicable third- party companies and will not be controlled by our Privacy Policy. Other than as described above, we are not responsible for the privacy policies or the content of third-party sites and/or services (each, a “Third Party Service”) we link to and have no control of the use or protection of information provided by you or collected by those Third-Party Services. Whenever you elect to hyperlink to a Third-Party Service, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third-party, and you should familiarize yourself with the privacy policy provided by that party.

Privacy and the Internet

The following additional information will be of interest to you if you access a Stewards Capital Management Site and/or one of its affiliates’ products or services through one or more of our websites:

• The Stewards Capital Management Sites are built upon an infrastructure with multiple layers of protection, including physical security of our equipment to system intrusion detection capabilities. Within such our sites, we use industry standard encryption technologies to help safeguard your information.
• Security is a cooperative effort between us and the users of the Stewards Capital Management Sites. Please remember that your user identification and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
• “Cookies” are small text files that may be placed on your web browser when you visit our websites. Cookies make it easier for you to navigate our website by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you navigate between our website pages and/or access our services. Authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set, or to prevent cookies from being set. Please note that if you decline to use cookies, you may experience reduced functionality, slower site response times, and declining to use our authentication-related cookies may prevent you from using our website altogether.
• Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Stewards Capital Management, or by our service providers. This may be accomplished by using cookies, Web beacons, page tags or similar tools that are set when you visit our website. Web surfing data and similar information may be shared internally within Stewards Capital Management and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our websites; and as otherwise permitted by applicable law or regulation. If you are a Stewards Capital Management client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by Third Party Services, solely in accordance with our instructions.
• Stewards Capital Management Sites may include social media features (“Features”), such as the Facebook Like button and widgets, such as the “Share This” button or interactive mini programs that run on this Site (“Widgets”). These Features and Widgets may collect your IP address, which page you are visiting on a Stewards Capital Management Site and may set a cookie to enable the Feature or Widget to function properly. Social media Features and Widgets are either hosted by a third party or hosted directly on a Stewards Capital Management Site. Your interactions with these Features and Widgets are governed by the privacy policy of the company providing it.

CalOPPA Disclosures

Do Not Track Signals
We do not currently respond to web browsers’ “Do Not Track” signals that provide a method to opt out of the collection information about visitors’ activities on the Stewards Capital Management Sites, and across other websites. If we do so in the future, we will provide all relevant information in this Privacy Policy.

Third Party Data Collection

We may authorize certain third parties, including, without limitation, Google Analytics, Chartbeat and Mixpanel, to track usage and collect information about users and their activities on the Stewards
Capital Management Sites.
Contact Us
Email: [email protected]