Policies

361 Capital’s Privacy Policy

Maintaining your privacy is important to 361 Capital. That’s why we take every reasonable precaution to safeguard your personal information from unauthorized access. After all, your relationship with us is built on trust and our goal is to preserve that trust. So whether you visit our website, or call our service representatives, know that we are committed to keeping your personal information safe and secure.

The 361 Capital Privacy Assurance

1. We do not and will not sell your personal information without your consent

2. Collection and use of your nonpublic personal information.
We collect information such as name, address, email address, and phone number. This information is collected via 361capital.com and 361 Capital Service Representatives. 361 Capital limits the use of your information to what is necessary to: fulfill legal and regulatory requirements; provide you with superior service; alert you to 361 Capital products and services that may be of interest to you; and occasionally conduct market-related research and surveys. 361 Capital will include instructions for “unsubscribing‟ in its marketing and/or research-related email communications. In addition, if 361 Capital contacts you via telephone in relation to a survey, you can indicate to us that you would prefer not to receive any additional calls of that nature in the future.

3. Nonpublic personal information 361 Capital shares
361 Capital may share nonpublic personal information with our affiliates. This includes information such as name, date of birth, address, SSN, account activity and account balances.

4. Third-party relationships with 361 Capital
The types of affiliated third parties with whom 361 Capital shares information include institutions such as investment advisors and transfer agents. 361 Capital protects this shared information with strict confidentiality agreements. 361 Capital does not disclose, and does not intend to disclose, nonpublic personal information to nonaffiliated third parties except as permitted by law.

5. Information shared with service providers
361 Capital may share nonpublic personal information under servicing or joint marketing agreements with institutions such as service bureaus and application service providers. In all cases, your information is strictly protected. Each agreement requires that service providers keep the information strictly confidential and use it only for its intended purpose.

6. Information about former shareholders
361 Capital does not disclose, and does not intend to disclose, nonpublic personal information to nonaffiliated third parties with respect to persons who are no longer shareholders.

7. Right to opt out
361 Capital is not in the practice of selling or distributing nonpublic information to third parties. If, in the future, our business directs us to do this, you will be notified and given the opportunity to opt out of having this information shared.

8. Confidentiality, security and integrity
For the purposes of this Privacy Policy, “361 Capital” includes 361 Capital LLC, a Registered Investment Advisor.

9. Physical Security
361 Capital provides or partners with firms providing leading edge technology to ensure that all transmitted information is safe and secure. Information is stored on a secure record-keeping system that is located in secured areas of the buildings we or our service providers occupy. All record-keeping systems are located in controlled areas, with physical access limited to authorized persons. Authorized personnel escort visitors into controlled areas at all times. Employees of 361 Capital and our service providers may, from time to time, have access to this information in order to fulfill our service commitment to you. However, physical access to the controlled areas is logged and each employee, upon employment with 361 Capital, is required to sign a security agreement concerning their individual duty to safeguard confidential data.

361 Capital’s Website Terms of Use

1. Terms
By accessing this website, you are agreeing to be bound by these website Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.

2. Use License
a. Permission is granted to temporarily download one copy of the materials (information or software) on 361 Capital’s website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:

i. modify or copy the materials;

ii. use the materials for any commercial purpose, or for any public display (commercial or non-commercial);

iii. attempt to decompile or reverse engineer any software contained on 361 Capital’s website;

iv. remove any copyright or other proprietary notations from the materials; or

v. transfer the materials to another person or “mirror” the materials on any other server.

b. This license shall automatically terminate if you violate any of these restrictions and may be terminated by 361 Capital at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer
The materials on 361 Capital’s website are provided “as is”. 361 Capital makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, 361 Capital does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet website or otherwise relating to such materials or on any sites linked to this site.

4. Automatic Information
When you visit www.361capital.com, 361 Capital is capturing Internet Protocol (“IP”) addresses to track and aggregate certain non-personal information. For example, 361 Capital can see which pages on the 361 Capital sites a user visits in an effort to better site performance and offer more personalized information.

In addition, 361 Capital retains certain types of information when a user interacts via the website, including pages visited and activities performed. 361 Capital records certain “traffic data” including your IP address, 361 Capital cookie information, and pages requested. 361 Capital may use the data collected in an effort to better understand and serve clients and prospective customers better, individually or in the aggregate.

361 Capital collects usage information, such as the number and frequency of visitors to the Site and use of components of Services available. 361 Capital may use this information to provide research, advice and information. This type of collective data enables 361 to determine how often customers use parts of the website so we can communicate more effectively with a greater level of personalization, with the goal delivering a better customer experience.

E-mail Communications:
361 may receive confirmation when a user opens an e-mail from 361 Capital. 361 Capital may use this information to further customize emails, and enhance their relevance to our audience. 361 Capital may also send out emails with information regarding 361 Capital products or events. Users who complete the request form on the Site to be subscribed to mailings and/or request to be contacted may be sent information regarding 361 Capital and our products. Users may opt out of being contacted by 361 Capital by sending an email to [insert email] or by unsubscribing through the unsubscribe or opt-out link in an email.

Information From Other Sources:
In order to enhance our ability to provide relevant information to our users, 361 Capital may obtain information about you from other sources and add it to our account information.

5. Limitations
In no event shall 361 Capital or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption,) arising out of the use or inability to use the materials on 361 Capital’s Internet site, even if 361 Capital or a 361 Capital authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

6. Revisions and Errata
The materials appearing on 361 Capital’s website could include technical, typographical, or photographic errors. 361 Capital does not warrant that any of the materials on its website are accurate, complete, or current. 361 Capital may make changes to the materials contained on its website at any time without notice. 361 Capital does not, however, make any commitment to update the materials.

7. Links
361 Capital has not reviewed all of the sites linked to its Internet website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by 361 Capital of the site. Use of any such linked web site is at the user’s own risk.

8. Site Terms of Use Modifications
361 Capital may revise these terms of use for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these Terms and Conditions of Use.

9. Governing Law
Any claim relating to 361 Capital’s website shall be governed by the laws of the State of Colorado without regard to its conflict of law provisions.