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. 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” 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.

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.Shelton Capital Management Cookie Policy and How We Protect Your Information:Last Updated: January, 20191. What Are CookiesAs is common practice with almost all professional websites, www.sheltoncap.com, www.sheltonfunds.com, www.rentx.life, www.shelton401k.com, (“Website”) uses cookies. Cookies are small text files stored on your computer by your browser. They’re used for many things, such as remembering whether you’ve visited a website before, so that you remain logged in – or to help us work out how many new website visitors we get each month. They contain information about the use of your computer but don’t include any personal information. This Cookie Policy describes what information the cookies on our Website gather, how we use it and why we sometimes need to store these cookies.2. How We Use CookiesWe use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this Website. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.3. Disabling CookiesYou can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this Website. Therefore, it is recommended that you do not disable cookies.4. The Cookies We Set

Account related cookies

If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases, they may remain afterwards to remember your Website preferences when logged out.

We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

Email newsletters related cookies

This Website offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.

Forms related cookies

When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

Website preferences cookies

In order to provide you with a great experience on this Website we provide the functionality to set your preferences for how this Website runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.5. Third Party CookiesIn some special cases, we also use cookies provided by trusted third parties (such as AdRoll and Google Analytics) for targeted advertising purposes. The following section details which third party cookies you might encounter through this Website.

This Website uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the Website and ways that we can improve your experience. These cookies may track things such as how long you spend on the Website and the pages that you visit so we can continue to produce engaging content.
Third party analytics are used to track and measure usage of this Website so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the Website or pages you visit which helps us to understand how we can improve the Website for you.
From time to time we test new features and make subtle changes to the way that the Website is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on the Website whilst ensuring we understand which optimizations our users appreciate the most.
As we advertise product, it’s important for us to understand statistics about how many of the visitors to our Website actually click on the product links, and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible outcome.

6. Changes to this Cookie PolicyWe may, at our own discretion, update this Cookie Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage you to frequently check this page for any changes to stay informed the type of cookies we set. You acknowledge and agree that it is your responsibility to review this Cookie Policy periodically and become aware of modifications.7. More InformationHopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our Website. However, if you are still looking for more information on our Cookie Policy, you can email us at info@sheltoncap.com

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	No	We do not share.
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.

WHO WE ARE
Who is providing this notice?Shelton Capital Management

WHAT WE DO
How does Shelton Capital Management protect my personal information?To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.How does Shelton Capital Management collect my personal information?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 moneyWhy can’t I limit all sharing?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.

DEFINITIONS
AffiliatesCompanies related by common ownership or control. They can be financial and nonfinancial companies.Non-affiliatesCompanies 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 marketingA 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 ResidentsIf 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.

Shelton Capital Management Cookie Policy and How We Protect Your Information:

Last Updated: January, 2019

1. What Are Cookies

As is common practice with almost all professional websites, www.sheltoncap.com, www.sheltonfunds.com, www.rentx.life, www.shelton401k.com, (“Website”) uses cookies.

Cookies are small text files stored on your computer by your browser. They’re used for many things, such as remembering whether you’ve visited a website before, so that you remain logged in – or to help us work out how many new website visitors we get each month. They contain information about the use of your computer but don’t include any personal information.

This Cookie Policy describes what information the cookies on our Website gather, how we use it and why we sometimes need to store these cookies.

2. How We Use Cookies

We use cookies for a variety of reasons detailed below.

Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this Website. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

3. Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this).

Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this Website. Therefore, it is recommended that you do not disable cookies.

4. The Cookies We Set

Account related cookies

Email newsletters related cookies

Forms related cookies

When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

Website preferences cookies

5. Third Party Cookies

In some special cases, we also use cookies provided by trusted third parties (such as AdRoll and Google Analytics) for targeted advertising purposes. The following section details which third party cookies you might encounter through this Website.

This Website uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the Website and ways that we can improve your experience. These cookies may track things such as how long you spend on the Website and the pages that you visit so we can continue to produce engaging content.
Third party analytics are used to track and measure usage of this Website so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the Website or pages you visit which helps us to understand how we can improve the Website for you.
From time to time we test new features and make subtle changes to the way that the Website is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on the Website whilst ensuring we understand which optimizations our users appreciate the most.
As we advertise product, it’s important for us to understand statistics about how many of the visitors to our Website actually click on the product links, and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible outcome.

6. Changes to this Cookie Policy

We may, at our own discretion, update this Cookie Policy at any time. When we do, we will revise the updated date at the top of this page.

We encourage you to frequently check this page for any changes to stay informed the type of cookies we set. You acknowledge and agree that it is your responsibility to review this Cookie Policy periodically and become aware of modifications.

7. More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our Website.

However, if you are still looking for more information on our Cookie Policy, you can email us at info@sheltoncap.com