Privacy Policy

Privacy Policy

   Amended April 30, 2025

Vines Capital Management, LLC has adopted this privacy policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to serve you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information. 

Information We Collect: We collect certain nonpublic information about you ("Customer Information").  The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include: 

• Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, trusts, mortgages and tax returns.  

• Identifying information such as your name, age, address, social security number, etc.  

• Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).  

• Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill out a service request.  

Security of Your Information: We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information. 

How Your Information is Used: We collect personal information from you with your explicit consent and use it solely to provide personalized financial planning, manage your accounts, and deliver services in accordance with regulatory standards. Your information may also be used to communicate important account updates, financial insights, or firm-related notices via email or text message. You may opt out of non-essential communications at any time. We do not sell or share your personal information with third parties for marketing purposes. All handling of client information is conducted in compliance with applicable laws and regulations, including those set forth by the U.S. Securities and Exchange Commission (SEC) 

Information We Disclose: We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the authorized services (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. Phone numbers collected with SMS consent, will not be sold, rented, or shared with third parties or affiliates for marketing purposes under any circumstances. 

We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.  

Former Clients: If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time. 

User Rights: The user retains the right to deny usage and collection of their information. You have the right to limit access to and updating of your personal data. You also hold the right to the deletion of your information upon request. 

Changes to Our Privacy Policy: In the event there was to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt out of such disclosure arrangements. 

Questions: If you have questions about this privacy notice or about the privacy of your customer information, call our main number 318-450-4664 and ask to speak to the Chief Compliance Officer.  Also, please contact Vines Capital Management LLC if there are any changes in your financial situation or investment objectives, or if you wish to add or modify any reasonable restrictions to the management of your account.