MyRepChat – Terms of Service and Privacy Notice

Clearwater Capital Partners (“Clearwater Capital Partners,” “we,” “us,” or “our”) utilizes the MyRepChat text‑messaging platform (“MyRepChat”) to facilitate text‑message communications between you and Clearwater Capital Partners personnel in connection with the provision of investment advisory and related services. MyRepChat is made available as a convenience to clients and prospective clients and is not used by Clearwater Capital Partners for unsolicited bulk marketing or mass promotional campaigns.

By initiating or continuing a text‑message exchange with Clearwater Capital Partners through MyRepChat, you acknowledge and agree that Clearwater Capital Partners may send you text messages relating to your accounts, financial planning, service requests, appointment scheduling, and other matters arising out of or relating to your relationship with us. You may revoke your consent to receive text messages at any time by replying “STOP” to any message sent through MyRepChat. You may request assistance with respect to such messages by replying “HELP.”

Text messaging is not an appropriate medium for communicating time‑sensitive or emergency instructions, including, without limitation, trade orders, wire or funds‑transfer instructions, or reports of suspected fraud or identity theft. You should contact our office by telephone for any urgent or time‑critical matters. Standard message and data rates may apply, and your mobile carrier’s terms and conditions will govern your use of text messaging.

Information Collected via MyRepChat

In the ordinary course of providing investment advisory and related services, Clearwater Capital Partners may receive personal information about you through MyRepChat, including, but not limited to:

• Your name, mobile telephone number, and other contact information; and
• Information you choose to provide by text message regarding your financial situation, objectives, holdings, or service needs.

You are strongly discouraged from transmitting highly sensitive information (for example, full Social Security numbers, full bank or credit card numbers, online user IDs and passwords, or multifactor authentication codes) via text message. Clearwater Capital Partners will make available alternative, more secure means for transmitting such information, where necessary or appropriate.

If your relationship with Clearwater Capital Partners terminates, we may continue to retain and use your information as required or permitted by applicable law, including our record‑keeping obligations as a Registered Investment Adviser.

Use and Disclosure of Information

Clearwater Capital Partners is committed to the protection and privacy of our clients’ personal and financial information. We will not share such information with any affiliated or non‑affiliated third party except in limited circumstances, including, for example:

• When necessary to complete a transaction in a client account, such as with a clearing firm or custodians.
• When required to maintain, support, or service a client account.
• To resolve client disputes or inquiries.
• With persons acting in a fiduciary or representative capacity on behalf of the client.
• With rating agencies, persons assessing our compliance with industry standards, or our attorneys, accountants, and auditors.
• In connection with a written agreement to provide investment management or advisory services when information is released for the sole purpose of providing the products or services covered by the agreement.
• In any circumstances with the client’s instruction or consent.
• As otherwise permitted or required by applicable law and regulation.

Information obtained through MyRepChat may be used and disclosed in the same manner as other client information, including to service and administer your accounts, perform advisory services, comply with legal, regulatory, and supervisory obligations, and engage third‑party service providers to support Clearwater Capital Partners’ operations and services.

Federal and State Privacy Rights

Investment advisers are required by law to inform clients of their policies and practices regarding the privacy of client information. Federal law provides clients with certain rights to limit the sharing of personal information and to receive a clear explanation of how their information is collected, used, and protected.

Federal and state law may allow you to limit certain types of information sharing and may provide additional rights with respect to access to, and correction of, personal information that we maintain, as well as remedies in the event of a data breach or unauthorized disclosure. State laws and individual company policies may give you additional rights to limit sharing beyond what federal law requires.

Nothing in this MyRepChat Terms of Service and Privacy Notice is intended to limit any rights you may have under applicable federal or state law.

Safeguards and Security

Clearwater Capital Partners maintains physical, electronic, and procedural safeguards reasonably designed to protect your personal and financial information, including information transmitted or received through MyRepChat, from unauthorized access, use, or disclosure. These safeguards include, among other measures, access controls, secure systems, supervision and training of personnel, and policies intended to promote the confidentiality and security of client information.

Notwithstanding these safeguards, text messaging inherently presents certain risks, including the possibility that messages may be viewed on an unlocked or shared device, stored by your mobile carrier, or accessed by other third parties. You are responsible for implementing appropriate security measures on your devices, such as password protection or biometric authentication, and for promptly notifying Clearwater Capital Partners if you believe an unauthorized person may have access to your device or your text messages.

Your Choices

You may opt out of receiving text messages from Clearwater Capital Partners via MyRepChat at any time by replying “STOP” to any such message. You may contact us to inquire about our handling of your information, or to request limitations on certain types of information‑sharing to the extent such limitations are permitted under applicable law and consistent with our regulatory obligations.

Questions and Contact Information

If you have any questions regarding this MyRepChat Terms of Service and Privacy Notice or our privacy practices generally, please contact us at:

Clearwater Capital Partners
2800 W Higgins Road, Suite 1025
Hoffman Estates, Illinois 60169

Phone: 847-841-8650
Email: general@ccpwealth.com
Website: https://ccpwealth.com