Updated: 2023

POLICY
LotusGroup Capital, LLC. (LGC) will ensure the privacy of clients.

PURPOSE
The purpose of this privacy policy is to ensure the safeguarding of our customer’s nonpublic personal information.

PROCEDURE

1. We collect nonpublic personal information about clients for business purposes from the following sources:
   • Agreements, forms, and contracts may include your name, address, social security number, income information, net worth, asset statement, tax circumstances, and information about your investment goals and risk tolerance.
   • Account history, including information regarding the client’s account transactions, may include the parties to a transaction, the positions held or sold, and pricing.
   • Correspondence, including written, telephonic, or electronic, between clients or investors, LGC, and/or any service providers for client’s accounts.
2. We do not disclose any nonpublic personal information about clients or investors to nonaffiliated third parties, except service providers and as otherwise permitted by law. We do not sell any personal information about clients to any third party.
3. In the ordinary course of business, personal information we collect about clients or investors, as described above, may be shared with financial service providers who provide services on behalf of our clients and investors’ accounts (such as brokerage firms, custodians, executing brokers, portfolio management software providers, or other client advisors, and the like). We may disclose all the information we collect about clients or investors to nonaffiliated third-party service providers as necessary to achieve the following:
   • Effect, administer, or enforce a transaction that a client or investor requests or authorizes.
   • In connection with processing or servicing a financial product or service that a client or investor requests.
   • In connection with maintaining or servicing a client’s or investor’s account with the third party. For example, information may be disclosed to others to enable them to perform general administrative activities for us, assist us in processing a transaction authorized or requested by a client, or execute transactions on a client’s or investor’s behalf in conjunction with our Customer Agreement.
   • As required by a regulatory authority or law enforcement agency.
   • For resolving customer disputes or inquiries.
   • To people holding a legal or beneficial interest relating to the customer.
   • To our attorneys, accountants, or auditors as deemed necessary.
   • In connection with a proposed or actual sale or merger of our firm.
   • To comply with a civil, criminal, or regulatory investigation by federal, state, or local authorities.
4. We employ reasonable precautions to safeguard private customer information security, including physical, technical, and personnel measures.
5. As it pertains to our website only (not offline information collected):
   • We collect information from visitors (customers and consumers) when they subscribe to our newsletter or fill out a form.
   • Any of the information we collect is used to send periodic emails originating from LotusGroup Capital.
   • We do not sell, trade, or otherwise share collected information with any unaffiliated third parties unless included in Item 3 above.
   • If customers or consumers would like to unsubscribe from receiving future emails at any time, we include detailed unsubscribe instructions at the bottom of each email.
   • We implement a variety of security measures to maintain personal information safety.
   • We do not use cookies.
   • Occasionally, we may include or offer third-party products or services on our website at our discretion. These third-party sites have separate and independent privacy policies.
   • We comply with California’s Online Privacy Protection Act and will not distribute personal information to outside parties without your consent.
   • We comply with COPPA requirements (Children’s Online Privacy Protection Act), and we do not collect information from anyone under 13 years of age on our website.
   • Using our website, LGC visitors consent to our website privacy policy.
   • If we change our privacy policy, we post those changes and the date of such changes.