Privacy Policy

As a registered investment adviser, Steele Capital Management, Inc. (“SCM”) has a responsibility and
fiduciary duty to protect the privacy of client information. SCM must comply with SEC Regulation S‐P,
which requires registered investment advisers to adopt policies and procedures to protect clients’ nonpublic
personal and financial information (“NPFI”). To comply, SCM holds both the firm and its
employees to the highest standards of trust and fiduciary duty in the safeguarding and use of clients’
NPFI. SCM is committed to maintaining the confidentiality of the information it collects from current,
potential and former clients and therefore SCM adheres to the policies and practices described in this

Client Information: In order to provide clients with personalized financial services, SCM requests nonpublic
personal, financial and transactional information. SCM will collect this confidential information
from clients directly through conversations, paperwork and correspondence so SCM can compile a full
financial picture in order to best serve the client.

Disclosure of Client Information: SCM maintains safeguards to comply with federal and state standards
to safeguard each client’s NPFI. SCM does share NPFI with nonaffiliated third parties, in the following

  • As necessary to provide services the client has requested or authorized, or to maintain and
    service the client’s account;
  • With outside solicitors that provide clients with separate non‐investment advisory services, in
    instances where the client was referred to SCM by the solicitors for advisory services and would
    have signed a disclosure acknowledgment as to this arrangement;
  • As required by regulatory authorities or law enforcement officials who have jurisdiction over
    SCM, or as otherwise required by an applicable law;
  • To protect the confidentiality or security of the financial institution’s records against fraud and
    for institutional risk control purposes; and
  • To provide information to the firm’s attorneys, accountants and auditors or others determining
    compliance with industry standards.

Safeguarding Client Information: SCM restricts access to NPFI to those employees who need to know
such information in order to provide services to clients. SCM maintains physical, electronic and
procedural safeguards to restrict the access to such information. Employees are prohibited, either
during or after termination of employment, from disclosing NPFI to any person or entity outside SCM,
including family members, except under the circumstances described above.

SCM’s Privacy Policy remains in effect at all times, even after the client relationship is terminated.


Revised May 2018