At Wetherby Asset Management, we respect your right to privacy and never sell information with which you have trusted us. We understand the importance you place on the privacy and security of information that personally identifies you. As part of our commitment to earn our role as your trusted advisor every day, we provide the following resource to be fully transparent about how we treat your information, and what options you have.

Who We Are

Wetherby Asset Management is an independent registered investment advisory firm that specializes in comprehensive wealth planning and investment management for high net worth families and individuals. We offer objective, unbiased and thoughtful financial counsel centered on each client’s unique needs and priorities.

Background on Collecting Personal Information

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What Personal Information May Be Collected?

The types of personal information we collect and share depend on the relationship you have with us. This information can include:

• Email
• Address
• IP Address
• Drivers Licence/ Passport Number
• Occupation and Employment Status
• Date of Birth
• Marital Status
• Gender
• Social Security Number
• Financial Goals
• Assets, Income and Account Balances
• Investment Experience and Risk Tolerance
• Information received from credit bureaus including credit history
• Information from your wills, trusts, and other estate planning documents
• Information about your holdings or transactions with us, our affiliates, or others
• Mortgage rates & payments and records of personal property
• Wire transfer instructions

How Does Wetherby Collect Your Personal Information?

We collect your personal information, for example, when you:

• Subscribe to receive our communications
• Enter into an advisory contract
• Seek advice about your investments or make deposits or withdrawals from your account
• Give us your income information or contact information
• Open an account
• Fill out subscription documents for investment funds or vehicles

We also collect your personal information from other companies.

How Does Wetherby Protect Your Personal Information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We have policies and procedures designed to reasonably ensure the proper handling of customer information by employees and to require third parties to adhere to appropriate security and confidentiality standards.

How Personal Information Can Be Shared

All financial companies need to share Clients’ personal information to run their everyday business. In the section below, we list reasons financial companies can share their Clients’ personal information; the reasons Wetherby and its affiliates choose to share; and whether you can limit sharing.

Why Can’t I Limit All Sharing?

Federal Law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes – information about your credit worthiness
• Affiliates from using your information to market to you
• Sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See next page for more on your rights under state law.

In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Definitions

• Affiliates: Companies related by common ownership or control. They can be financial and non-financial companies.
• Non-Affiliates: Companies not related by common ownership or control. They can be financial and non- financial companies. Nonaffiliates we share with can include:
  • Government Entities
  • Broker-Dealers or banks
  • Claims processors
  • Payment processors
  • Investment service providers
  • Vendors or advisors to the respective client including attorneys, accountants, etc.
  • Other third-parties in relation to our services to you
• Joint-Marketing: Companies not related by common ownership or control. They can be financial and non-financial companies.

Other Important Information

California Residents

The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

• The right to request (a) the categories and specific pieces of personal information we collect and disclose, (b) the categories of sources from which we collected your personal information, (c) the categories of your personal information (if any) that we have disclosed for a business purpose, and (d) the categories of third parties with which we have shared personal information;
• For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
• The right to request that we delete the personal information we have collected from you or maintain about you; and
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests relating to your exercise of rights under the CCPA to us at 415-399-9159.

Nevada Residents: We are providing you this notice under state law. At your election, you may be placed on our Do Not Call list by calling us at 415-399-9159. You may obtain more information concerning Nevada Protection by contacting the following: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number- 702-486-3132; email: BCPINFO@ag.state.nv.us.

Vermont Residents: Under Vermont law, we will not share information we collect about Vermont residents with companies who are not affiliates, except as permitted by law, such as with your consent or to service your accounts. We will not share information about your creditworthiness with our affiliates without your authorization or consent, but we may share information about our transactions or experiences with you with our affiliates without your consent.

EU Residents: Wetherby has determined that its data collection and management practices do not subject the Company to the requirements of GDPR. Wetherby does not actively market its advisory services in the EU and will not process EU resident personal data unless it is received as a result of reverse solicitation. In the event Wetherby receives unsolicited inquiries from prospective Clients located in the EU, the Chief Compliance Officer will be responsible for documenting the unsolicited nature of such inquiries before Wetherby responds. The Chief Compliance Officer is also responsible for ensuring that Wetherby has identified, and complies with, all requirements of GDPR.

The Chief Compliance Officer will annually reassess the applicability of GDPR to Wetherby and will ensure appropriate policies and procedures are implemented in the event the Company becomes subject to GDPR.

Cookie Policy

We use cookies and similar technologies on the Wetherby Asset Management LLC website. Cookies are bits of data that a website sends to a web browser on a visitor’s computer. Cookies help us and our third-party partners to collect information about you and other visitors to our website, including date and time of visit, pages viewed, amount of time spent on our sites, or general information about the device used to access the site.

In addition to cookies, certain additional data may be automatically collected from your device or web browser, including:

IP addresses, referrer headers, data identifying your web browser and version, social media pixels, web beacons, and tags.

Third parties may also collect information via our website through cookies, third-party plug-ins, and widgets. These third parties collect data directly from your web browser and may connect it to personally identifiable information. The processing of this data is subject to the privacy policies of these third-party vendors.

We use cookies and pixel tags to track the usage of our website to provide services to existing and prospective clients and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about site traffic and site interaction, to identify trends, and to obtain statistics so that we can improve our site.