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GENERAL PRIVACY POLICY*

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.

Our Privacy Principles:

  • We do not sell client Information.
  • We do not provide client information to persons or organizations outside of Shelton Capital Management who are doing business on our behalf (e.g., non-affiliated third parties), for their own marketing purposes.
  • We afford prospective and former clients the same protections as existing clients with respect to the use of client information.

Information We May Collect:
We collect and use information we believe is necessary to administer our business, to advise you about our products and services, and to provide you with customer service. We may collect and maintain several types of client information needed for these purposes, such as those below:

  • From you, (application and enrollment forms, transfer forms, distribution forms, checks, correspondence, or conversation), such as your address, telephone number, and social security number.
  • From your transactions with our custodian, such as your transaction history, and account balance.
  • From electronic sources, such as our website or e-mails.

How We Use Information About You:

Shelton Capital Management will only use information about you and your accounts to help us better serve your investment needs or to suggest Shelton Capital Management services or educational materials that may be of interest to you.

Use of E-mail Address:

If you have requested information regarding Shelton Capital Management products and services and supplied your e-mail address to us, we may occasionally send you follow-up communications or information on additional products or services.  Additionally, registered shareholders can subscribe to the following e-mail services:

  • Prospectus and Shareholder Reports – Receive prospectuses and shareholder reports online instead of by U.S. mail.
  • Paperless Statements – Receive an e-mail with a link to our Web site informing you that our investor statements are available online to view, print or download.
  • Tax Form Alerts – Receive an e-mail in early January informing you if you will receive tax forms for your taxable Shelton mutual funds, including the approximate date they will be mailed.

We also include instructions and links for unsubscribing form Shelton Capital Management e-mails.  We do not sell e-mail addresses to anyone, although we may disclose e-mail addresses to third parties that perform administrative or marketing services for us.  We may track receipt of e-mails to gauge the effectiveness of our communications.

Information Disclosure:

We do not disclose any nonpublic personal information about our clients or former clients to non-affiliated third parties without the client’s authorization. However, we may disclose client information to persons or organizations inside or outside our family of funds or advisory clients, as permitted or required by law.  For example, we will provide the information, as described above, to our custodian to process your requests or authorized transactions.

How We Protect Your Information:

We restrict access to your client information to authorized persons who have a need for these records in order to provide products or services to you. We also maintain physical, electronic, and procedural safeguards to guard client information. To further protect your privacy, our website uses the highest levels of Internet security, including data encryption, Secure Sockets Layer protocol, user names and passwords, and other tools. As an added measure, we do not include personal or account information in non-secure e-mails that we send you via the Internet.


For clients with Internet access, Shelton Capital Management recommends that you do not provide your user name or password for any reason to anyone.

In the event that you hold shares of one or more Funds through a financial intermediary, including, but not limited to, a broker-dealer, bank, or trust company, the privacy policy of that financial intermediary would govern how your nonpublic personal information would be shared with non-affiliated third parties.

*As referenced in this policy statement, Shelton Capital Management (formerly known as CCM Partners, LP) is a registered investment adviser to the Shelton Funds and the Shelton Greater China Fund and other advisory clients. RFS Partners, LP is the distributor of the mutual funds. This General Privacy Policy applies to all named entities.