We respect the privacy of all clients and prospective clients (collectively termed “customers” per federal guidelines), both past and present. It is recognized that clients have entrusted our firm with non-public personal information, and it is important that both access persons and customers are aware of firm policy concerning what may be done with that information.

The firm collects personal information about customers from the following sources:

• Information provided to us complete their plan or investment recommendation;
• Information provided via engagement agreements and other documents completed in connection with the opening and maintenance of an account;
• Information customers provide verbally; and
• Information received from service providers, such as custodians, about client transactions.

The firm does not disclose non-public personal information about our customers to anyone, except in the following circumstances:

• When required to provide services our customers have requested;
• When our customers have specifically authorized us to do so;
• When required during the course of a firm assessment (i.e., independent audit); or
• When permitted or required by law (i.e., periodic regulatory examination).

To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to protect the privacy of customer information. Within the firm, access to customer information is restricted to personnel that need to know that information. All access persons and service providers understand that everything handled in firm offices is confidential and they are instructed not to discuss customer information with someone else that may request information about an account unless they are specifically authorized in writing by the customer to do so. This includes providing information about a family member’s account.

The firm will provide customers with its privacy policy on an annual basis and at any time, in advance, if firm privacy policies are expected to change.

Contact us at:

BWS Investment Management, LLC

13100 Wortham Center Drive

Third Floor
Houston, TX 77065

832-534-3516

bwsinvestments.com

bwsinvestment.com

Protecting your private information is our priority. This Statement of Privacy applies to http://www.bwsinvestment.com, and BWS Investment Management, LLC and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to BWS Investment Management, LLC include http://www.bwsinvestment.com and BWS Investments. The BWS Investments website is a Informational site. By using the BWS Investments website, you consent to the data practices described in this statement.

Collection of your Personal Information

In order to better provide you with products and services offered, BWS Investments may collect personally identifiable information, such as your:

–          First and Last Name

–          Mailing Address

–          E-mail Address

–          Phone Number

–          Employer

–          Job Title

–          Marital Status, Dependents, Investment Experience, Risk Aversion

BWS Investments may also collect anonymous demographic information, which is not unique to you, such as your:

–          Age

–          Gender

–          Household Income

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services. These may include: (a) registering for an account; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.

Use of your Personal Information

BWS Investments collects and uses your personal information to operate and deliver the services you have requested.

BWS Investments may also use your personally identifiable information to inform you of other products or services available from BWS Investments and its affiliates.

Sharing Information with Third Parties

BWS Investments does not sell, rent or lease its customer lists to third parties.

BWS Investments may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is transferred to the third party. BWS Investments may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to BWS Investments, and they are required to maintain the confidentiality of your information.

BWS Investments may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on BWS Investments or the site; (b) protect and defend the rights or property of BWS Investments; and/or (c) act under exigent circumstances to protect the personal safety of users of BWS Investments, or the public.

Opt-Out of Disclosure of Personal Information to Third Parties

In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information. To opt-out of the disclosure of your personal information, visit this Web page _________________.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by BWS Investments. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the BWS Investments website.

Use of Cookies

The BWS Investments website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize BWS Investments pages, or register with BWS Investments site or services, a cookie helps BWS Investments to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same BWS Investments website, the information you previously provided can be retrieved, so you can easily use the BWS Investments features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the BWS Investments services or websites you visit.

Links

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Security of your Personal Information

BWS Investments secures your personal information from unauthorized access, use, or disclosure. BWS Investments uses the following methods for this purpose:

–          SSL Protocol

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Children Under Thirteen

BWS Investments does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

Opt-Out & Unsubscribe from Third Party Communications

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from third-party partners of BWS Investments by contacting us here:

– Web page: _________________

– Email: clientservices@bwsinvestment.com

– Phone: _________________

E-mail Communications

From time to time, BWS Investments may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from BWS Investments or click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from BWS Investments, you may opt out of such communications by replying STOP.

Changes to this Statement

BWS Investments reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our website, and/or by updating any privacy information. Your continued use of the website and/or Services available after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

BWS Investments welcomes your questions or comments regarding this Statement of Privacy. If you believe that BWS Investments has not adhered to this Statement, please contact BWS Investments at:

BWS Investment Management, LLC

13100 Wortham Center Drive

Houston, Texas 77065

Email Address:

info@bwsinvestment.com

Telephone number:

832-534-3516

Effective as of November 03, 2021