Effective: May 25, 2018

Elm Partners Management LLC (“Elm Partners”) is committed to safeguarding the use of your personal information that we hold. Elm Partners (also referred to as “we”, “our” and “us” throughout this notice) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with our communications with you.

Elm Partners does not sell or transfer your personal data/information to anyone.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Privacy Policy.

What information do we collect from you?	When do we collect this information?
Contact information, specifically First and Last Name Email address(es) Location (by region)	Research subscriptions Information requests Investment applications Message form submissions
For more information on the site cookies that we set, along with third-party cookies, please see our cookie policy here.

How do we use your information?

Communications: – Email updates, including recent posts to Elm’s blog and research notes – Materials related to Elm Partners and its services Email transcripts: Our Customer Relationship Manager (CRM) software compiles a transcript of email interactions between Elm Partners and its users.

• For investors:
• Additional, non-public data and information may be shared with Elm Partner’s service providers, such as the institutions that Elm Partners uses as a custodian or administrator. For more information, please see the Investor-specific Privacy Policy contained within our ADV-2 form here or on our website, ElmWealth.com.

Who has access to this information?

Elm Partners and its employees Third Party Applications and Services: Elm Partners uses third-party applications and services that have access to customer data. This includes the Hubspot CRM toolset, as well as email clients such as Outlook and Gmail.

How do we protect your information?

We require third parties that assist in providing our services to you to protect the personal information they receive. This includes contractual language in our third party agreements.

Our employees are also advised about Elm Partners’ need to respect the confidentiality of each client’s non-public personal information. We train our employees on their responsibilities, and limit employee access to information as appropriate.

In the event we discover a security breach, you will be notified within 72 hours of the discovery.

How can you control your information?

At any time, you can amend, update or correct your information by submitting a form through our website.

If you’d like to receive a copy of the information that we have, or request that we delete all of your personal data that we hold, please send a request to info@elmwealth.com.

Changes to our Privacy Policy

Periodically, we may revise our Privacy Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy.

• Questions?
• You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy, by contacting us at info@elmwealth.com.

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For those who wish to receive a copy of their information, please send an email to info@elmwealth.com with “[Your Name] Information Request” in the Subject heading.

For those who wish to have Elm Partners delete the personal data that we hold, please send an email to info@elmwealth.com with “[Your Name] Delete my Information” in the Subject heading.