Steadworth Gramm-Leach-Bliley Act (GLBA) Policy

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to protecting the privacy and security of its customers' nonpublic personal information ("NPI"). This Gramm-Leach-Bliley Act (GLBA) Policy ("Policy") outlines Steadworth's procedures for complying with the privacy provisions of the GLBA and its implementing regulations (Regulation P).

II. Policy Statement

Steadworth will:

• Provide clear and conspicuous notice to consumers about its privacy policies and practices.

• Give consumers a reasonable opportunity to opt out of the disclosure of their NPI to nonaffiliated third parties.

• Protect the confidentiality and security of consumer NPI.
  
  

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents who handle consumer NPI. It covers all of Steadworth's products and services that are offered to consumers for personal, family, or household purposes.

IV. Definitions

• Nonpublic Personal Information (NPI): Personally identifiable financial information about a consumer that is not publicly available.

• Consumer: An individual who obtains or has obtained a financial product or service from Steadworth for personal, family, or household purposes.

• Nonaffiliated Third Party: Any person that is not an affiliate of Steadworth.

• Opt Out: A direction by the consumer that Steadworth not disclose their NPI to a nonaffiliated third party.
  
  

V. Privacy Notices

Steadworth will provide consumers with an initial privacy notice that describes:

• The categories of NPI that Steadworth collects.

• The categories of NPI that Steadworth discloses.

• The categories of affiliates and nonaffiliated third parties to whom Steadworth discloses NPI.

• The consumer's right to opt out of the disclosure of their NPI to nonaffiliated third parties.

• Steadworth's policies and practices for protecting the confidentiality and security of NPI.
  
  

VI. Opt-Out Requirements

Steadworth will not disclose a consumer's NPI to a nonaffiliated third party unless:

• The consumer has been provided with an initial privacy notice.

• The consumer has been provided with an opt-out notice.

• The consumer has been given a reasonable opportunity to opt out of the disclosure.

• The consumer has not opted out.
  
  

VII. Reuse and Redisclosure of NPI

Steadworth will only reuse or redisclose consumer NPI in accordance with the exceptions provided by the GLBA.

VIII. Prohibition on Disclosure of Account Numbers

Steadworth will not disclose consumer account numbers to nonaffiliated third parties for marketing purposes.

IX. Responsibilities

A. Compliance Officer:

• The Compliance Officer is responsible for overseeing and implementing this Policy.

• This includes developing and maintaining procedures, providing training to employees, and monitoring compliance with the GLBA.
  
  

B. All Employees:

• All employees are responsible for complying with this Policy and reporting any potential violations to the Compliance Officer.
  
  

X. Training

Steadworth will provide regular training to its employees on GLBA compliance. This training will cover topics such as the definition of NPI, privacy notice requirements, opt-out requirements, and the protection of consumer information.

XI. Review and Revision

This Policy will be reviewed and revised periodically to ensure that it remains current and effective.

XII. Conclusion

Steadworth is committed to protecting the privacy and security of its customers' NPI. This Policy is intended to ensure that all employees are aware of their obligations under the GLBA and that Steadworth conducts its business in a compliant manner.

XIII. Contact

Any questions or concerns regarding this Policy should be directed to the Compliance Officer at: contact@steadworth.com

Please note: This Policy is intended to supplement, not replace, any other applicable Steadworth policies or procedures.