- Cookies policy -

Klosters Capital, LLC (“us”, “we”, or “our”) provides financial advisory services to individuals and companies (the “Service”).

This page informs you about the policies for the collection, use and disclosure of personal data when you use our Service and the options that are related to this information.

We use your information to provide and improve our Service. By using our Service, you agree to the use and collection of this information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meaning as the Terms and Conditions set forth on our website, http://www.klosters-capital.com/

Definitions:

Service: Financial services provided by Klosters Capital LLC and the website https://www.klosters-capital.com operated by Klosters Capital, LLC
Personal Data: Information of the individual person by which it can be identified (or other type of information that is in our possession or that may become so).
Use of Information: Information collected automatically, either generated by the use of the Service or by the infrastructure of the Service itself (for example, the duration of a visit).
Cookies: Information collected on your device (computer or mobile phone).
Information Controller: Individual or legal person (either alone or jointly with other persons) that determines the manner in which this personal information is, or should be, processed. In the case of this Privacy Policy, we are the Information Controller of your Personal Data.
Information Processor (or Service Provider): Any natural or legal person who processes the information on behalf of the Information Controller. We may use the services of various Providers to process your information more efficiently.
Data Subject (or User): Any individual who is using our Service and is subject to providing Personal Information.

Information Collection and Use

We collect different types of information for different purposes to provide and improve our service to you.

Types of Information Collected

Personal information

In connection with the provision of products and services, we collect nonpublic personal information about you that can be used to contact or identify you (Personal Information) from the following sources:

Information we receive from you through applications or other forms (for example: investment/insurance applications, new account forms, and other forms and agreements);
Information about your transactions with us or with others (for example, broker/dealers, clearinghouses, or other investment financiers); Y
Information we receive from consumer agencies (for example, credit bureaus), as well as other types of material that we can use to give a good recommendation, or complete a required service.

Personally identifiable information may include and is not limited to:

• Email

• First name and last name

• Phone number

• Address, State, Province, Postal Code, City

We may use your Personal Information to contact you about newsletters, marketing or other promotions and information that may be of interest to you. You may choose to review some or all of these communications by following the unsubscribe link or instructions in any of the emails we send.

Use of Information

Klosters Capital, LLC uses the information collected for various purposes:

Provide and maintain our Service
Notify about changes to our Service
Provide customer support
Collect analysis or valuable information to improve our Service
Monitor the use of our Service
Detect, prevent and deal with technical problems
Provide information about special offers and general information about other goods, services and events that we offer and are similar to others that you have already purchased; unless you prefer not to receive this type of information.

Legal regulation of the processing of personal information under the General Data Protection Regulation (RGPD)

If you are a resident of the European Union (EU), Klosters Capital, LLC has the right to collect and use the personal information described in the Privacy Policy depending on the Personal Data we have collected and the specific context in which it was collected.

Klosters Capital, LLC is entitled to process your Personal Information because:

It is necessary to formalize a contract with you
You have given us permission to do so
The process is of our legitimate interest and is not invalidated by your rights.
To comply with the law

Data retention

Klosters Capital, LLC will retain your Personal Data only as necessary under the regulation of this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligation (for example, if retention of your information is required to comply with applicable laws, including, but not limited to, the Investment Advisory Act of 1940, resolve disputes and enforce our legal agreements and policies.

Klosters Capital, LLC will also retain the Use Information for internal analysis purposes. Use Information is generally retained for a short period of time, except when this information is used to enhance the security or to improve the functionality of our Service, or when we are required by law to retain this information for long periods of time._cc781905-5cde -3194-bb3b-136bad5cf58d_

Data transmission

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where data protection law may differ from that of your jurisdiction._cc781905-5cde-3194-bb3b -136bad5cf58d_

If you are located outside of the United States and choose to provide information to us, please note that we transmit the information, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by compliance with this information constitutes your acceptance of said transmission.

Klosters Capital, LLC will take all necessary measures to ensure that your information is treated with the necessary security and in accordance with the Privacy Policy; and no personal information will be transmitted to an organization or a country unless there are the necessary controls in place including data security and personal information.

Data Disclosure

Disclosure for Law Enforcement

Under some circumstances, Klosters Capital, LLC may be required to disclose your personal data by law or in response to valid requests from public authorities (for example: court or government agency)

Legal requirements

Klosters Capital, LLC may disclose your personal data in good faith and in the belief that such action is necessary:

To comply with a legal obligation
To protect and defend the rights or property of Klosters Capital, LLC
To prevent or investigate possible errors related to the Service
To protect the personal safety of users of the service or the public
To protect yourself from legal liabilities

Data Security

The security of your data is important to us, but remember that neither the means of transmission over the Internet, nor the method of electronic storage is 100% secure. Although we strive for the correct commercial use of your personal data, we cannot guarantee its absolute security.

Data Protection Rights under the General Data Protection Regulation (RGPD)

If you are a resident of the European Union (EU), you have certain data protection rights. Klosters Capital, LLC intends to take the necessary steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you want to be informed of what personal data we have about you and if you want them to be removed from our system, please contact us.

In certain circumstances you have the following data protection rights:

Right to access, update or delete the information we have about you. Where possible, you may access, update, or request deletion of your personal information.

Right of rectification. You have the right to have your information rectified if it is incorrect or incomplete information.

Right of objection. You have the right to object to the processing of your personal data.

Right of restriction. You have the right to request that the processing of your personal information be restricted.

Right to data portability. You have the right to be given a copy of the information we have about you in a common, structured and machine-readable format.

Right to withdraw consent. You also have the right to withdraw your consent at any time that Klosters Capital relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to these requests.

You have the right to claim from the Data Protection Authority the collection and use of your personal data. For more information, please contact your local data protection authority in the European Union (EU).

Service provider

We may contract with outside companies and individuals to facilitate our Service (“Service Providers”)

These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use such information for any other purpose.

Links to other web pages

Our service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's website. We strongly recommend that you review the Privacy Policy of any web page you visit.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites or services.

children's privacy

Our Service is not directed to anyone under the age of 18 (“Children”)

We do not collect personally identifiable information from anyone under 18 years of age. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we discover that we have collected personal data from children without verification of parental consent, we will take appropriate steps to delete that information from our servers.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time, in which case we will notify you of any changes by sending you the new Privacy Policy on this page.

We will notify you via email and/or notice of our service, before the change becomes effective and we will update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy will be effective when they are posted on this page.

If you have any questions about this Privacy Policy, please contact us:

- Interest Policy Management-

The purpose of Klosters Capital's conflict of interest management policy (hereinafter, “Policy”) is (together with its Internal Rules of Conduct), to establish the mechanisms that allow effective prevention of conflicts of interest that may arise between Klosters Capital and its clients, or between its clients, and that may result in harm to them, in the provision of investment services, as well as effectively manage the aforementioned conflicts of interest.

This Policy applies to: (i) the members of the Board of Directors of Klosters Capital; (ii) employees whose work is directly or indirectly related to Klosters Capital's activities related to investment services; (iii) the Agents, if applicable, who provide investment services on behalf of Klosters Capital; and (iv) where applicable, to the companies with which an investment service is subcontracted; (hereinafter, “Competent Persons”).

It will be understood that a conflict of interest arises when Klosters Capital or the Competent Persons:

They can obtain a financial benefit or avoid a financial loss at the expense of the client;
Have an interest in the result of a service provided to the client or of a transaction carried out on behalf of the client that is different from the client's interest in that result;
Have financial or other incentives to favor the interests of another client or group of clients over the interests of the first client;
They develop the same activity as the client;
Receive or will receive from a person other than the client an incentive in relation to a service provided to the client, in the form of money, goods or services, apart from the usual commission or remuneration for that service.

The Policy establishes the measures and procedures adopted by Klosters Capital to identify conflicts of interest related to the provision of investment services, as well as to identify scenarios in which conflicts of interest may potentially arise.

The Policy establishes the necessary measures to manage conflicts of interest identified by Klosters Capital. The purpose of the measures will be to guarantee that in the provision of investment services to Clients, Competent Persons can comply with the general principles of honest, impartial and professional action.

Finally, the Klosters Capital Policy includes the relevant measures to prevent the flow of information between the areas of activity that, under current regulations, must act independently and separately.

Klosters Capital will maintain, in accordance with the regulations in force at all times, an updated record of the circumstances and investment services in which there is or may arise a conflict of interest with a significant risk of harm to the interests of its clients. The Policy will be reviewed annually by the Regulatory Compliance Unit.

In those cases in which the measures established to manage conflicts of interest are not, in the opinion of Klosters Capital, reasonably sufficient to avoid the risk of the client being harmed, Klosters Capital must inform the client of the nature of the conflict and the other circumstances that allow you to make a decision about contracting the investment service in the context of which the conflict of interest arises.

In the event that a client requires more information regarding a specific point of the policy, said request will be requested from the Company.