Privacy Policy

(Effective January 1, 2022)

Bespoke Service Company, LLC. (“BSC”) values the trust our clients have placed in us and are committed to the responsible management, use, and protection of their personal information.  BSC does not rent, sell, or trade information concerning our clients to anyone.  Please take a moment to review this Privacy Policy to learn how we protect your information and use it to service your account(s).

Information We Collect From You

BSC collects, stores, and uses personal information about our clients to help us serve their cryptoasset management and financial needs, process transactions in their account(s), provide services to our clients, offer new products or services, and fulfill legal and regulatory requirements. BSC collects information about our clients from the following sources:

  • Information provided to us, our affiliates, or staff by our clients on account applications and related forms required to fulfill ‘know your customer’ (KYC) processes and in discussions with our employees and in our capacity as advisors, managers, or as committee members within our clients’ private trust companies or investment holding companies.
  • Information gathered from our internal files and externally sourced files regarding clients’ transaction histories (such as products or services purchased, account balances, trading history, and payment history), as well as that provided by custodial companies, service companies, external financial institutions, employers, and consumer reporting agencies (such as transactions or credit relationships with unaffiliated third parties), or from available blockchain records.
  • Information on your business activity.  While it may not constitute personal information, if you use our services, we likely collect data you provide us related to your business and obtain other information related to your business, such as various financial account balances and transaction history (“Business Data”). We understand your Business Data is sensitive (and in some instances confidential). As such, we do not access, use, or disclose your Business Data except as set forth in the Sharing Information section on this Policy.

This information may include “nonpublic, personal information,” which means information that is not readily known or accessible in the public realm, such as a client’s social security number or other tax identification number, passport number, driver’s license number, birth date, net worth, assets, income, and medical information (if applying for insurance), as well as the fact that the client has an account with us.

Sharing Information

Pursuant to federal law, we may not disclose a client’s nonpublic personal information without the client’s prior consent, unless the disclosure is needed to:

  • Provide services requested by the client, including, but not limited to:

    • clearing, transferring, confirming, or reconciling transactions in client account(s); and
    • providing statements or other records regarding the status or value of the Client’s account(s);
  • Provide the Client with marketing materials regarding our products and services, as well as those offered pursuant to joint agreements with our affiliates or non-affiliated third parties, so long as all parties offering the products or services have agreed in writing to protect the confidentiality of the Client’s information and to not use it for any other purpose;
  • Enforce any of our rights, including the collection of any fees or other payments due;
  • Provide any of BSC’s affiliates with information regarding our operations, or as reasonably required pursuant to the proposed or actual sale, merger, transfer, or exchange of all or a portion of our business;
  • Comply with mandatory disclosures to of regulatory or law enforcement organizations;
  • Respond to a subpoena or discovery request;
  • Provide disclosures as otherwise required by law.

We may provide such information to BSC’s affiliates and/or unaffiliated financial or non-financial services providers (such as insurance companies, mutual fund companies, banks, investment firms, third-party administrators, clearing firms, and other third parties who assist us in providing account maintenance or Client service) as necessary pursuant to the exceptions listed above.

We do not sell, share, or disclose your nonpublic personal information to unaffiliated third-party marketing companies.

Opting Out

Clients may request that their data be removed from our systems and / or that we not disclose their nonpublic, personal information for any reason – other than one of the exceptions listed above.

To request that we remove your data and / or not disclose your information for any purpose (other than those covered under the exceptions listed under “Sharing Information,” above), please contact us by email at .  If we do not receive such a request from you within thirty (30) days of you opening an account, contracting for services, or receiving an updated privacy notice, we have the right to assume you do not object to the

disclosure of your information if required by federal law until you notify us to the contrary. (Please note that the laws of certain states may impose additional restrictions upon the disclosure of Clients’ confidential information.) We will remove all relevant personal data, so long as that removal is technically feasible, does not impact the legitimate servicing or business practices of our customers, and does not violate other regulatory or legal standards with which we must comply.  We will also cooperate with our customers in good faith to address any requests we receive or that may impact them directly.

Safeguarding Information

BSC recognizes the need to prevent unauthorized access to the information we collect, including information held in electronic format.  BSC authorizes access to your nonpublic personal information only to personnel who need that information to serve you.  We maintain physical, electronic, and procedural safeguards regarding your nonpublic, personal information to ensure that we comply with our own policy, industry practices, and federal and state regulations.  All physical documents containing client nonpublic personal information remain secured in locked storage when not in use, and all offices are locked when unoccupied.  Electronic records are stored in end-to-end encrypted file storage and electronic communications take place either over password-encrypted closed networks or over encrypted VPN connections.

If you decide to close your account(s) or become an inactive Client, we will adhere to the privacy policies and practices as described in this notice.

Changes

We may alter this Privacy Policy from time to time.  We will post any updated Privacy Policy to our Website(s) with a new effective date.  We will also provide Clients with the modified Privacy Policy if the changes materially alter the previous Privacy Policy.  Each Client is responsible for regularly reviewing this Privacy Policy for any changes.

Questions

You do not have to contact us to benefit from our privacy protections; they apply automatically to all of our Clients and former Clients.  If you have any questions after reading this privacy policy, we encourage you to email us at to contact us as 877–757–8120.

Effective Date

The Privacy Policy is effective as of January 1, 2022.