Privacy & Affiliate Marketing Policy

Responsible Department

The Compliance Department of Alphastar Capital Management, LLC (“Alphastar”) is responsible for the Privacy and Affiliate Marketing Policy.

Purpose

This policy was created to help ensure compliance with (i) Regulation S-P under the Investment Advisers Act of 1940, as amended ("Advisers Act"), the Gramm-Leach-Bliley Act, and the Fair and Accurate Credit Transactions Act of 2003 ("FACT Act"), which governs the treatment of Nonpublic Personal Information about Consumers by certain financial institutions, including Alphastar; and (ii) Regulation S-AM under the Advisers Act and the Fair Credit Reporting Act ("FCRA") as amended by the FACT Act, which governs the limitations on Affiliate marketing.

Protecting Consumers' private information is of paramount importance and the requirements of this policy and related policies must be strictly followed.

Scope

This policy applies to Alphastar and all Supervised Persons of Alphastar.

Definitions

The following terms are used throughout this policy:

Affiliate	Any company that controls, is controlled by, or is under common control with Alphastar.
Consumer	An individual who obtains or has obtained a financial product or service from Alphastar that is to be used primarily for personal, family, or household purposes, or that individual's legal representative. Consumers include both Clients and prospective Clients of Alphastar.
Clients	A Consumer who has a continuing relationship with Alphastar (i.e., the Consumer signed an Investment Management Agreement, Financial Planning Agreement, or other contract with Alphastar or an IAR on behalf of Alphastar).
Eligibility Information	Any information the communication of which would be a "consumer report" if the exclusions from the definition of "consumer report" in section 603(d)(2)(A) of the FCRA did not apply (i.e., certain financial information, such as information regarding an individual's transactions or experiences with the Affiliate). Does not include aggregate or blind data that lacks personal identifiers such as account numbers, names, or addresses.
Marketing Solicitation	The marketing of a product or service initiated by Alphastar to a particular individual with whom Alphastar does not have a pre-existing business relationship that is: (i) based on Eligibility Information communicated to Alphastar by its Affiliate; and (ii) intended to encourage the individual to purchase or obtain such product or service. Marketing communications directed at the general public are excluded.
Nonaffiliated Third Party	Any person except: (i) Alphastar's Affiliate; or (ii) a person employed jointly by Alphastar and any company that is not Alphastar's Affiliate (but includes the other company that jointly employs the person).
IAR	As defined in Alphastar's Code of Ethics.
Non-Public Information	Information that has not been broadly disseminated or made widely available to the general public. Includes, but is not limited to, Alphastar's proprietary information, information regarding Clients and prospective Clients that is not Publicly Available Information, Non-Public Personal Information, PII, investment recommendations to Clients, and trading activity in Clients' advisory accounts.
Non-Public Personal Information	(i) PII; and (ii) any list, description, or other grouping of Consumers (and Publicly Available Information pertaining to them) that is derived using any PII that is not Publicly Available Information. Example: A list of individuals' names and street addresses derived in whole or in part using PII such as account numbers.
PII	Personally identifiable financial information — any information (i) a Consumer provides to Alphastar to obtain a financial product or service; (ii) about a Consumer resulting from any transaction involving a financial product or service between Alphastar and a Consumer; or (iii) Alphastar otherwise obtains about a Consumer in connection with providing a financial product or service. Does not include aggregate information or blind data lacking personal identifiers. Information provided on an application for a financial product or service Account balance information The fact that an individual is or has been one of Alphastar's Clients Any information disclosed in a manner indicating the individual is or has been Alphastar's Consumer Any information collected through an Internet "cookie" Information from a consumer report
Supervised Person	As defined in the Alphastar Code of Ethics.
Publicly Available Information	Any information that Alphastar reasonably believes is lawfully made available to the general public from: (i) Federal, State, or local government records; (ii) widely distributed media; or (iii) disclosures to the general public required by federal, State, or local law.

I. Handling and Use of Non-Public Information

Supervised Persons must maintain the confidentiality of Non-Public Information, including Non-Public Personal Information and PII, in accordance with this Policy, Alphastar's Code of Ethics, and any applicable confidentiality agreement or undertaking. This obligation continues even after a Supervised Person ceases to be affiliated with Alphastar, as long as the Supervised Person is in possession of Non-Public Information learned during their affiliation.

Alphastar has adopted a "need to know" policy with respect to the disclosure of Non-Public Information. Supervised Persons are expected to limit disclosure of Non-Public Information only to those persons who must have the information to serve the business purposes of Alphastar or its Clients and who can be expected to maintain the information in confidence.

All communications regarding Non-Public Information should be conducted so as not to disclose such information inadvertently to those not authorized to receive it. For example, Supervised Persons should avoid discussing Alphastar’s or Clients’ affairs with, or in the presence of, persons who do not have a need to know the information. Accordingly, Supervised Persons should avoid such discussions in hallways, elevators, public transportation, restaurants and other public places. Supervised Persons should also ensure that they do not have Non-Public Information out in an area where unauthorized persons might have access to the material or on a non-password protected computer or other electronic device.

II. Regulation S-P — Safeguarding Consumer Information

Regulation S-P is a set of rules designed to protect the privacy interests of Consumers of financial products and services, including investment advisory services. It contains requirements for initial and annual privacy notices to Consumers, and restrictions on Alphastar's ability to disclose Non-Public Personal Information to Nonaffiliated Third Parties.

Privacy Notice Requirements

Alphastar's Privacy Notice must provide clear and conspicuous notice to Clients that accurately reflects our privacy policies and practices. The notice must be provided at the following times:

When the Privacy Notice must be delivered

Initial Notice: New Clients receive an initial Privacy Notice at the time the Client relationship is established with Alphastar.
Amended Notice: Must be delivered to existing Clients if (i) Alphastar changes its collection, sharing, or security practices; or (ii) the Client obtains a new financial product or service not covered by the current Privacy Notice.
Annual Notice: Alphastar delivers the current version of its Privacy Notice annually to Clients, along with the current version of Alphastar's Form ADV Part 2A (Brochure).

Disclosure Restrictions

Prior to disclosing any Non-Public Personal Information about a Consumer to any Nonaffiliated Third Party, Alphastar is required to provide the Consumer with (i) the Privacy Notice; (ii) an opt-out notice; and (iii) a reasonable opportunity to opt out of the disclosure.

Alphastar and Supervised Persons are prohibited from disclosing any Non-Public Personal Information about a Consumer to any Nonaffiliated Third Party without the prior written approval of the Compliance Department.

III. Regulation S-AM — Limitations on Affiliate Marketing

Regulation S-AM allows individuals who do not have a pre-existing business relationship with Alphastar to block Alphastar from using Eligibility Information received from an Affiliate to make Marketing Solicitations to that individual. Unlike Regulation S-P, Regulation S-AM does not limit Alphastar's or its Affiliates' ability to share information with one another — instead, it limits Alphastar's ability to use that information for solicitation purposes.

Under Regulation S-AM, Alphastar is prohibited from using Eligibility Information that it receives from an Affiliate to make a Marketing Solicitation to an individual without a pre-existing business relationship unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the individual; (2) the individual has been provided a reasonable opportunity and a simple method to opt out of receiving the Marketing Solicitation; and (3) the individual has not opted out. Alphastar and Supervised Persons are prohibited from using Eligibility Information regarding an individual who does not have a pre-existing relationship with Alphastar and that is received from an Affiliate to make Marketing Solicitations to that individual about Alphastar’s or an IAR’s advisory products and services.

Alphastar and Supervised Persons are prohibited from using Eligibility Information regarding an individual who does not have a pre-existing relationship with Alphastar — received from an Affiliate — to make Marketing Solicitations about Alphastar's or an IAR's advisory products and services.

IV. Exceptions

Any exceptions to the above requirements must be pre-approved in writing by the Compliance Department.

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