The website located at www.sctrust.co (the “Website”) is operated by StoneCastle Trust Co., a wholly owned subsidiary of StoneCastle Partners, LLC (“StoneCastle Trust Co.”, “we,” “us,” or “our). This Privacy Policy provides you with information about how we collect, use, and share personal information, and describes choices and rights available to you regarding your personal information.

This Privacy Policy describes our practices for information that we collect from your interactions with us, including, but not limited to:

• Use of this Website;
• Use or consideration of our products and services;
• Interacting with us, including contacting our customer service, operations or business development departments; and
• Responding to or viewing our advertisements.  

This Privacy Policy does not apply to third-party websites accessible through our Websites.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING THE WEBSITE OR SUBMITTING YOUR PERSONAL INFORMATION (DEFINED BELOW) YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES DESCRIBE IN THIS PRIVACY POLICY AND OUR TERMS OF USE.

1. PERSONAL INFORMATION WE COLLECT
‍“Personal Information" means any data that identifies you as an individual or relates to an identifiable individual. We obtain several categories of Personal Information relating to you from the sources described below.

A. Categories of Personal Information We Collect
‍The categories of Personal Information that we may collect include:

• Identifiers. We may collect identifiers, such as first name, last name, phone number, email address, physical address, geolocation information, date of birth, digital signature, social security number, and employer identification number, among other things.
• Internet Activity. We may collect internet activity information, such as IP address, browser characteristics, device IDs and characteristics, operating system version, and referring URLs.
• Payment Information. We may collect payment information, such as credit or debit card information, bank account information, and billing information.
• Commercial Information. We may collect commercial information, such as products or services purchased and/or used.
• Inferences. We may collect inferences regarding your marketing and communications preferences, interests, and other characteristics.
• Nonpublic Financial Information. We may collect nonpublic financial information, such as income, credit information, employment information, account balances, transaction history, assets, and investment experience.

B. Where We Collect Personal Information From
Personal Information Obtained from You
‍
We collect Personal Information from you directly in a variety of ways. Some examples are when you:

• Conduct Business with Us. We collect Personal Information from you at various places when you use our financial products or services.
• Pay for Services. We collect Personal Information from you in order to fulfill your requests related to our financial products and services.
• Inquire about Our Products and Services. We collect Personal Information from you in order to respond to your request for a quote or inquiry about our financial services and products.
• Contact Customer Support. We collect Personal Information from you when you contact us, including when you communicate with us by email or by calling our customer support or operations department.

Personal Information Obtained from Third Parties

We may collect your Personal Information from third parties. Some examples are when we collect information from:

• Affiliates and Business Partners. We may obtain your Personal Information from our affiliates and business partners in order to offer and provide our financial products and services and to support our core business functions.
• Credit Bureau and Agencies. We may obtain third-party information (consumer and/or commercial credit reports) from credit bureaus and agencies which is reviewed to make a credit decision, determine risk and fraud profiles, and to support our core business functions.
• Marketing Partners. We may obtain your Personal Information from our marketing and referral partners.    

Personal Information Obtained Passively

When you access our Website, we may collect Personal Information related to you, as well as processes and programs that are running on your device, through automated means, such as cookies, web beacons, and web server logs. A cookie is a small data file that a website transfers to your computer’s hard drive. Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a web page is viewed, and a description of the web page where the web beacon is placed. A web server log is a simple text file that records activity on the server, such as when and how visitors are accessing a website.

We may use cookies, web beacons, and web server logs to improve your experience on our Websites, including to troubleshoot and perform analytics on the Website. To learn more about our use of cookies and how to set your preferences, please see our “Cookies” section below.

2. HOW WE USE YOUR PERSONAL INFORMATION
‍We may use Personal Information provided to us as follows:

• To offer and provide our financial products and services and to support our core business functions.
• To present our Website and its contents to you.
• To personalize your experience and better respond to your individual needs.
• To provide you with information that you request from us.
• For internal research and marketing purposes.
• To investigate, prevent, defend against, or take other action regarding violations of our Privacy Policy or Terms of Use, illegal activities, suspected fraud, or situations involving potential threats to the legal rights of us or others.
• To comply with applicable laws and regulations.

We will not use your Personal Information for any other purposes unless we notify you, or for which you have specifically consented to at the time of collection, or as otherwise described in this Privacy Policy, or as permitted or required by law, rule, regulation, subpoena, or other legal process.

3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
‍We may disclose your Personal Information to third parties under the following limited circumstances:

• With our affiliates and business partners.
• To contractors, service providers, and other third parties we use to support our business.
• To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
• If required to do so by law or in the good faith belief that such action is appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (v) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (vi) to allow us to pursue available remedies or limit the damages that we may sustain.

By submitting Personal Information to us, you hereby agree to the foregoing transfers or assignments of your information, including Personal Information, and you further waive any claims that could be made against us in relation thereto.

4. COOKIES
‍We use cookies to collect information about your activity, browser, and device when you visit our Website. Cookies allow us to collect information such as browser type, time spent on the Website, pages visited, referring URL, language preferences, and other aggregated traffic data. Below is a summary of the types of cookies we use.

• Essential Cookies: These are cookies without which you would not be able to use our Websites. For example, Essential Cookies adjust the Website data transmitted to match your internet connection, get you to the secure versions of the Website, and help provide services you specifically request. If you set your browser to block these cookies, some parts of the Website will not work.
• Analytic Cookies: These cookies count visits and traffic sources to measure and improve Website performance. We may use persistent cookies, which will remain on your computer even after you close your browser, to understand general Website usage and volume statistical information (which does not include Personal Information) and improve the content and offerings on our Websites. We may also use persistent cookies to store user preferences.
• Functional cookies: These cookies allow the Website to remember choices you make and provide enhanced functionality and more personalized features. These technologies are used so that we can provide a continuous and more personalized shopping experience for you (e.g., to recognize you by name when you return to a Website).
• Advertising Cookies: These cookies help us manage and display our advertisements based on your activity on our Websites and other websites; this is known as interest-based advertising. We may use targeting cookies to gather demographic information about our user base as a whole. We may allow third-party ad servers (i.e., third parties that provide technology to place ads on websites and track ad performance) to use cookies, web beacons, and other technologies to automatically collect information about your visit to our Websites or to place our ads on third-party websites and to analyze the effectiveness of those ads.

This Privacy Policy covers the use of cookies and other tracking devices by us but does not cover the use of cookies or other tracking technologies used by any third-party sites we may refer you to and any of our partners. If you want to remove or block cookies on your device, you can update your browser settings (your browser manufacturer has information on changing the default setting for your specific browser). You can find simple instructions on how to manage cookies on the different types of web browsers at www.allaboutcookies.org.

You can also learn more about interest-based advertising and how to opt out of our vendors’ and other advertisers’ use of cookies and similar technologies to collect information to tailor content or advertising to you by visiting http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.

Do Not Track
‍Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device.

While most browsers are set to accept cookies and other tracking devices by default, you are always free to decline our cookies if your browser permits, but some parts of our Websites may not work properly if you do. Your browser manufacturer has information on changing the default setting for your specific browser.

5. SECURITY
‍We restrict access to nonpublic personal information about you to those Employees who need to know that information to provide financial products or services to you. Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside the Firm, including family members, except under the circumstances described above. We store your Personal Information and other information using reasonable physical, technical, and administrative safeguards that comply with federal standards.

While we use industry standard means to protect our Website and your information, no transmission of data over the internet is guaranteed to be completely secure. The measures we use are appropriate for the type of information we collect. However, it may be possible for third parties not under the control of us to intercept or access transmissions or private communications unlawfully. We cannot promise that your use of our Website will be completely safe, nor can we ensure or warrant the security of any information you transmit to us over the internet. We encourage you to use caution when using the internet.

6. OUR WEBSITE AND CHILDREN
‍Our Website is not created for children or designed to solicit information from individuals under the age of 18. We do not knowingly collect or store any personal information from anyone under the age of 18. If we become aware that we have collected or stored personal information from an individual under age 18, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to legal@sctrust.co.

7. INDIVIDUALS WITH DISABILITIES
‍If you have a disability and need access to our privacy policy in a different format, please contact us at legal@sctrust.co.

8. CHANGES
‍This Privacy Policy and our Terms of Use may be revised from time to time. The “Last Updated” legend at the bottom of this page indicates when this Privacy Policy was last revised, and the “Last Modified” legend at the top of the Terms of Use page indicates when our Terms of Use was last revised. Any changes will become effective when we post the revised Privacy Policy and Terms of Use on our Website. Your use of the Website following these changes means that you accept the revised Privacy Policy and our Terms of Use.

9. CONTACT INFORMATION
‍If you have any questions about this Privacy Policy or your dealings with StoneCastle Trust Co., please feel free to contact us at:
‍
StoneCastle Trust Co.,
20 Trafalgar Square, Suite 438
Nashua, NH 03063

Last Updated: May 2, 2023