Background

As a registered investment advisor, Lake Street must comply with federal Regulation S-P (or other applicable regulations), which requires registered advisors to adopt policies and procedures to protect the “nonpublic personal information” of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information.

Nonpublic personal information includes nonpublic “personally identifiable financial information” plus any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Lake Street to clients, and data or analyses derived from such nonpublic personal information.

The purpose of these privacy policies and procedures is to provide administrative, technical and physical safeguards, which assist employees in maintaining the confidentiality of nonpublic personal information collected from the consumers and customers of an investment advisor. All nonpublic information, whether relating to an advisor’s current or former clients, is subject to these privacy policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality.

Responsibility

The CCO is responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Lake Street’s client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations. The CCO is also responsible for distributing these policies and procedures to employees and conducting appropriate employee training to ensure employee adherence to these policies and procedures.

Policy and Procedures

Lake Street has adopted the privacy policy (attached) and the CCO reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Non-Disclosure of Client Information

Lake Street does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:

• As necessary to provide the service that the client has requested or authorized, or to maintain and service the client’s account;
• As required by regulatory authorities or law enforcement officials who have jurisdiction over Lake Street or as otherwise required by any applicable law; and
• To the extent reasonably necessary to prevent fraud and unauthorized transactions.

Employees are prohibited, either during or after termination of their employment, from disclosing client information to any person or entity outside Lake Street including family members, except under the circumstances described above. An employee is permitted to disclose personal information only to other employees who need to have access to this information to provide services to the client.

Security of Client Information

Lake Street restricts access to personal information to those employees who need to know such information to provide services to our clients. Any client information is secured in a locked file cabinet after business hours. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving personal information must be conducted by employees in a manner that protects the information from being overheard.

Privacy Notices

Lake Street provides to a client the privacy policy notice at the time the client signs the advisory agreement and acknowledges receipt of the privacy policy. Lake Street will  also mail to each client, on an annual basis, a notice of the firm’s current privacy policy.

If Lake Street adopts changes to its privacy policy, the firm shall provide each such client with a revised notice reflecting the new policy.

Text Message Terms & Privacy Policy

By requesting or engaging in communication by text with a representative of Lake Street Private Wealth, you agree to receive conversational and informational messages from Lake Street Private Wealth. Message and data rates may apply. Message frequency may vary. You may unsubscribe at any time by replying STOP or clicking the unsubscribe link (where available). Reply HELP for assistance. The full Privacy Policy and Terms are outlined below.

Use of Text Messaging

Lake Street Private Wealth uses text messaging via its SL2 platform to communicate with individuals in connection with our business relationship, in compliance with applicable laws and regulations.

• We communicate by text with individuals who have indicated that text messaging is an acceptable method of communication.
• You may opt out of text communications or request assistance at any time.
• All text message communications are captured and archived in accordance with applicable laws and regulations.
• Carrier message and data rates may apply.

Consent to Text Message Communications

By indicating that text messaging is an acceptable method of communication (such as telling us directly, responding to a text from us, or completing a consent form), you expressly authorize Lake Street Private Wealth to contact you at the phone number you provide and agree to receive messages under these terms.

Please note that, in some jurisdictions, even individually sent text messages may be classified as being sent via an “automatic telephone dialing system.” Similarly, some text content may be classified as “informational” or “marketing” depending on local laws. By providing your consent, you acknowledge and accept these conditions.

Opting Out

You can opt out of text message communications at any time by replying with the word STOP to any message. You may also opt out or request assistance by contacting us directly at 312.766.7040.

Changing Your Phone Number

If your phone number changes, please notify us immediately so we can update your contact preferences. Ideally, you should opt out using your old number before it is deactivated. Consent must be renewed for any new number you provide.

Message Frequency

The number of messages you receive may vary based on the nature and frequency of your communication with our team. If you feel you are receiving too many messages, you can reply STOP to limit or end communications.

Marketing and Promotional Content

Lake Street Private Wealth does not send unsolicited advertisements or promotional offers via text. While we may inform you of relevant services that support your financial goals, these messages are not part of a marketing campaign. If you have questions about the types of texts you may receive, please contact us at 312.766.7040.

Privacy and Data Use

We do not sell any personal information collected through our text messaging communications. Additionally:

• Your information will not be shared with third parties or affiliates for marketing or promotional purposes.
• Third-party vendors we use (such as our text messaging platform provider) are prohibited from selling or using your information outside of the scope of providing services to us.
• Information provided via text messaging will only be used to (a) document your consent, (b) send text messages, and (c) comply with applicable laws and regulations.

Getting Help

If you need assistance with our text messaging services, reply HELP to any message or contact us directly at 312.766.7040.

Privacy Policy Attachment

LAKE STREET PRIVATE WEALTH, LLC PRIVACY NOTICE (REGULATION S-P)

Pursuant to Regulation S-P adopted by the Securities and Exchange Commission, it is the policy of Lake Street Private Wealth, LLC (“Lake Street”) to keep confidential nonpublic personal information (“information”) pertaining to each current and former client (i.e., information and records pertaining to personal background, investment objectives, financial situation, investment holdings, account numbers, account balances, etc.) unless Lake Street is (1) previously authorized by the client to disclose information to individuals and/or entities not affiliated with Lake Street, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment advisor account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) permitted to do so in accordance with the parameters of regulation S-P. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Lake Street in order to facilitate the commencement/ continuation/ termination of a business relationship between the client and nonaffiliated third party service provider (i.e. broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for Lake Street (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider. Each individual and/or entity affiliated  with Lake Street is aware of Lake Street’s privacy policy, and has acknowledged his/her/its requirement to comply with same. In accordance with the Lake Street privacy policy, each such affiliated individual and/or entity shall have access to information to the extent reasonably necessary for Lake Street to perform its services for the client, and to comply with applicable regulatory procedures and requirements.