AN INVESTOR IN SHELTON CAPITAL MANAGEMENT
When you become a client of Shelton Capital Management, you entrust us not only with your hard-earned assets but also with your nonpublic personal and financial information (“client information”). We consider your client information to be private and confidential, and we hold ourselves to the highest standards of trust and fiduciary duty in their safekeeping and use.
WHO WE ARE
Shelton Capital Management is a registered investment adviser with the U.S. Securities and Exchange Commission (SEC). We provide investment management services to individuals, institutions, and retirement plans. In the course of delivering these services, we may collect and access certain personal and financial information as required to maintain your account, process transactions, and communicate with you effectively. Our affiliated broker-dealer, RFS Partners, is a member of FINRA and may also access your information as necessary to fulfill regulatory obligations or support related account activities. Both Shelton Capital Management and RFS Partners are committed to maintaining the confidentiality and security of your personal information in accordance with applicable federal laws.
FACTS
What does Shelton Capital Management do with your personal information?
WHY?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.
Please read this notice carefully to understand what we do.
WHAT?
The types of personal information we collect and share depend on the product or service you have with us.
This information can include:
• Social Security number and account transactions
• Account balances and transaction history
• Wire transfer instructions
We collect your personal information, for example, when you:
- Open an account
- Provide account information or give us your contact information
- Make a wire transfer or deposit money
Federal law gives you the right to limit only:
- Sharing for affiliates’ everyday business purposes-information about your creditworthiness
- Affiliates from using your information to market to you
- Sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing.
HOW?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons the Funds choose to share; and whether you can limit this sharing.
| REASONS WE CAN SHARE YOUR PERSONAL INFORMATION | DO WE SHARE: | CAN YOU LIMIT THIS SHARING? |
| For our everyday business purpose – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties | No | We do not share. |
| For our marketing purposes – to offer our products and services to you | Yes | We share among the Funds. |
| For joint marketing with other financial companies | No | We do not share. |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | Yes | No |
| For our affiliates’ everyday business purposes – information about your creditworthiness | No | We do not share. |
| For non-affiliates to market to you | No | We do not share. |
DEFINITIONS
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
Non-affiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Shelton Capital Management does not share with non-affiliates so they can market to you.
Joint marketing: A formal agreement between non-affiliated financial companies that together market financial products or services to you.
- Shelton Capital Management does not jointly market.
OTHER IMPORTANT INFORMATION
California Residents: If your account has a California home address, your personal information will not be disclosed to nonaffiliated third parties except as permitted by applicable California law, and we will limit haring such personal information with our affiliates to comply with California privacy laws that apply to us.
Use of Email Addresses: If you have requested information regarding Shelton Capital Management products and services and supplied your email address to us, we may occasionally send you follow-up communications or information on additional products or services. Additionally, registered clients can subscribe to the following email services: We also include instructions and links for unsubscribing from Shelton Capital Management emails. We do not sell email addresses to anyone, although we may disclose email addresses to third parties that perform administrative or marketing services for us. We may track receipt of emails to gauge the effectiveness of our communications.
Cookie Policy
Effective date: November 24, 2025
Last updated: November 26, 2025
What are cookies?
This Cookie Policy explains what cookies are, how we use them, the types of cookies we use (i.e., the information we collect using cookies and how that information is used), and how to manage your cookie settings.
Cookies are small text files used to store small pieces of information. They are stored on your device when a website loads in your browser. These cookies help ensure that the website functions properly, enhance security, provide a better user experience, and analyze performance to identify what works and where improvements are needed.
You can modify your cookie settings anytime by clicking the ‘Consent Preferences’ button above. This will allow you to revisit the cookie consent banner and update your preferences or withdraw your consent immediately.
How do we use cookies?
Like most online services, our website uses both first-party and third-party cookies for various purposes. First-party cookies are primarily necessary for the website to function properly and do not collect any personally identifiable data.
The third-party cookies used on our website primarily help us understand how the website performs, track how you interact with it, keep our services secure, deliver relevant advertisements, and enhance your overall user experience while improving the speed of your future interactions with our website.
Types of cookies we use
Manage cookie preferences
You can modify your cookie settings anytime by clicking the ‘Consent Preferences’ button above. This will allow you to revisit the cookie consent banner and update your preferences or withdraw your consent immediately.
Additionally, different browsers offer various methods to block and delete cookies used by websites. You can adjust your browser settings to block or delete cookies. Below are links to support documents on how to manage and delete cookies in major web browsers.
Chrome: https://support.google.com/accounts/answer/32050
Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac
Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc
If you are using a different web browser, please refer to its official support documentation.
Cookie Policy generated by CookieYes – Cookie Policy Generator
