NOTICE OF PRIVACY POLICY

Protecting your privacy is our top priority. At Alpina Capital, LLC (“Alpina”), we understand our obligation to keep information about you secure and confidential. We will inform you of our policies for collecting, using, securing, and sharing personally identifiable and/or nonpublic personal information (“Customer Information”) the first time we do business and every year that you remain a customer with us. Therefore, we maintain the following principles with respect to protecting your privacy:

  • We are committed to protecting your privacy at all times;
  • We do not sell or disclose any nonpublic personal information about you to anyone except as permitted by law;
  • We do not provide customer information to persons or organizations outside the affiliated companies who are doing business on our behalf, for their own marketing purposes;
  • We contractually require any person and/or organization providing products or services to customers on our behalf to protect the confidentiality of Alpina customer information;
  • We afford prospective and former customers of Alpina the same protections as existing customers with respect to the use of personal information.

Information We Collect
We collect and use various types of information we believe is necessary to administer our business, and to offer you the best possible customer service. Customer information we collect is categorized into the following types:

Information we receive from you on applications, or on other forms, through telephone or in-person interviews, such as your name, address, phone number, social security number, your assets, income and other household information;Information about your transactions and account experience with us or others, such as your account balance, transaction history;Information from consumer reporting agencies, such as information regarding your creditworthiness or credit history;Information from visitors to our website provided through online forms, site visitor data and online information collecting devices such as “cookies.”

Other general information we obtain about you that is not assembled for the purpose of opening an account or offering certain products or services that you may request, such as demographic information.

Information We Share
The information we share helps us bring you greater convenience and more choices as a customer. We limit who receives Customer Information and what type of information is shared.

Unless you tell us not to, we may share all five types of Customer Information among ourselves and with other third-party financial services companies affiliated with us as part of the ordinary course of providing financial products and services to you, for the purposes of offering you new products and services to address your financial needs, for product development purposes, and as otherwise required or permitted by law.

Such “affiliated” companies may include other financial service providers such as brokerage firms, investment adviser firms, insurance companies and payment processing companies; and may also include non-financial companies such as check printing and data processing companies. These companies might assist us, for example, in fulfilling your service request, processing your transaction, or mailing account statements. For a list of companies affiliated with Alpina Capital, LLC please see “Alpina Capital, LLC Affiliated Companies” below.

In addition, we may share any of the five types of Customer Information with companies that work for us to provide marketing and other services or other financial institutions with which we have joint marketing agreements. All of these companies that are acting on our behalf, are contractually obligated to keep the information that we provide to them confidential, and use the information only to provide the services we’ve asked them to perform.

Limitations to Sharing Customer Information
You can limit information shared about you. If you do not want us to share information from your applications, consumer reports, or from other outside sources, please tell us of this request by notifying us through one of the following methods:

Writing to:
Alpina Capital, LLC
200 Columbine Street, Suite 260
Denver, CO 80206

Calling us at:
(303) 242-5755

Send us an email through the website at:
http://alpinacapital.com

Please note that this request will apply to customer application information, consumer reporting agencies and/or other outside sources only and may take up to 30 days to be fully effective. Through the normal course of doing business, including servicing your accounts and better serving your financial needs, we will continue to share transaction and account experience information, as well as other general information among our affiliated companies.

Disclosing Information in Other Situations
We may also disclose any of the five types of Customer Information to credit bureaus and similar organizations, and otherwise when permitted by law. For example, this may include:

  • A disclosure in connection with a subpoena or similar legal process;
  • A fraud investigation;
  • Recording of deeds of trust and mortgages in public records;
  • An audit or examination;
  • The sale of your account to another financial institution.

Information Security
We are committed to preventing others from authorizing access to your customer information, and we maintain procedures and technology designed for this purpose. We take several steps to protect the customer information we have about you, including the following:

  • We restrict access to information about you to those employees who need to know that information to provide you with the best possible products and services;
  • We require outside companies and independent contractors to whom we provide customer information for marketing, servicing or processing purposes to enter into a confidentiality agreement that restricts the use of such information to be used for specific purposes as intended, and prohibits the independent use of such information;
  • We have internal procedures that limit access to customer information to only those members who are considered “authorized” personnel.

Keeping Up-To-Date with our Privacy Policy
Alpina will provide notice of our privacy policy annually, as long as you maintain an ongoing relationship with us. If, at any time in the future, it is necessary to disclose any of your nonpublic personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you may have the opportunity to opt out of such disclosure. Additionally, since this policy may change from time to time, you can always review our current policy by contacting us for a copy at (303) 242-5755.

Alpina Capital, LLC Affiliated Companies
Affiliates to whom we may disclose personal information about you may be categorized in several different businesses, including securities and insurance. The following is a list, as of May 1, 2008, of all companies affiliated with Alpina Capital, LLC to which this policy applies:

  • Brokerage and Investment Firms