Terms and Conditions

Nepsis Capital Management™, Inc. ("Nepsis") collects personal, private information from its clients in order to determine the client's specific investment goals and objectives, which will assist in determining how to adequately service the client account based on the services provided by Nepsis, as disclosed in Nepsis' Form ADV Part II, which we are happy to supply upon request.

The safeguarding of customer information is an issue we take seriously, and we want to assure all of our customers that whenever information is collected and used, it is done so with discretion. To affirm our continuing commitment to the proper use of customer information, we have set forth the following Privacy Policy, which is designed to guide us in serving the privacy needs of our customers.

Recognition of a Customer's Expectation of Privacy: At Nepsis we believe the confidentiality and protection of customer information is one of our fundamental responsibilities. And while information is critical to providing quality service, we recognize that one of our most important assets is our customers' trust. Thus, the safekeeping of customer information is a priority for Nepsis.

Use, Collection, and Retention of Customer Information: Nepsis limits the use, collection, and retention of customer information to what we believe is necessary or useful to conduct our business, provide quality service, and offer products, services, and other opportunities that may be of interest to our customers. Information collected may include, but is not limited to: name, address, telephone number, tax identification number, driver's license number, date of birth, employment status, annual income and net worth.

Maintenance of Accurate Information: Nepsis recognizes that it must maintain accurate customer records. The above referenced information is collected at the inception of your relationship with Nepsis. Therefore, Nepsis will contact you periodically to review your overall account holdings, and to ensure that personal/confidential information contained in your file is accurate. Nepsis also request that you review any information provided to you related to your advisory account, and notify Nepsis at 952-226-1356 promptly on the discovery of erroneous information. Nepsis will respond to a comment/request to correct inaccurate information immediately.

Limiting Employee Access to Information: At Nepsis, employee access to personally identifiable customer information is limited to those employees that have a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of customer information and on these Privacy Principles. Because of the importance of these issues, all Nepsis employees are responsible for maintaining the confidentiality of customer information and employees who violate these Privacy Principles will be subject to disciplinary measures.

Protection of Information via Established Security Procedures: Nepsis recognizes that a fundamental element of maintaining effective customer privacy procedures is to provide reasonable protection against the unauthorized access to customer information. Therefore, Nepsis has established appropriate security standards and procedures to guard against any unauthorized access to customer information.

Restrictions on the Disclosure of Customer Information: When it comes to sharing customer information with unaffiliated companies, Nepsis places strict limits on who receives specific information about customer accounts and other personally identifiable data. Nepsis may share information with such companies if they provide a product or service that may benefit our customers. Whenever we do this, we carefully review the company and the product or service to make sure that it provides value to our customers.

We share the minimum amount of information necessary for that company to offer its product or service. We may also share information with unaffiliated companies that assist us in providing our products and services to our customers; in the normal course of our business (for example, with broker-dealers, consumer reporting agencies and government agencies); when legally required or permitted in connection with fraud investigations and litigation; in connection with acquisitions and sales; and at the request or with the permission of a customer.

Maintaining Customer Privacy in Business Relationships with Third Parties: If we provide personally identifiable customer information to a third party with which we have a business relationship, we will insist that the third party keep such information confidential, consistent with the conduct of our business relationship.

Disclosure of Privacy Principles to Customers: Nepsis recognizes and respects the privacy expectations of our customers. We want our customers to understand our commitment to privacy in our use of customer information. As a result of our commitment, we have developed these Privacy Principles which are made readily available to our customers. Customers who have questions about these Privacy Principles or have a question about the privacy of their customer information should call Mark Pearson at (952) 226-1356.

These Privacy Principles apply to individuals, and we reserve the right to change these Privacy Principles, and any of the policies or procedures described above, at any time. Under such circumstances, we will provide you with an updated set of our policies, and will provide adequate time for you to opt out of any information sharing arrangement. These Privacy Principles are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreements we have with our customers.

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