Disclaimer, Terms of Use, and CCPA Disclosure

SteelPeak Wealth is an independent financial planning and investment advisory firm that seeks to empower private clients with the direction and discipline to build their wealth for every life stage and their legacies for the future.Steel Peak Wealth Management, LLC (“SteelPeak”) is an SEC registered investment adviser located in California. SteelPeak may only transact business in those states in which it is notice filed, or qualifies for an exemption or exclusion from notice filing requirements. SteelPeak’s web site is limited to the dissemination of general information regarding its investment advisory services to United States residents residing in states where providing such information is not prohibited by applicable law. Accordingly, the publication of SteelPeak’s web site on the Internet should not be construed by any consumer and/or prospective client as SteelPeak’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Furthermore, information on this Internet site should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from SteelPeak. Any subsequent, direct communication by SteelPeak with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of SteelPeak, please contact the United States Securities and Exchange Commission on their web site at www.adviserinfo.sec.gov. A copy of SteelPeak’s current written disclosure brochure discussing SteelPeak’s business operations, services, and fees is available from SteelPeak upon written request. SteelPeak does not make any representations as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to SteelPeak’s web site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

WEBSITE PRIVACY POLICY
Last updated: December 1, 2025

This online Privacy Policy describes how SteelPeak Wealth, LLC and its affiliated entities (collectively, “SteelPeak Wealth,” “we,” “us,” or “our”) collect, use, disclose, store, transfer, and protect personal information and data when you visit our websites, mobile applications, use our online services, communicate with us through any channel (including by SMS/text, email, phone, or social media), or otherwise interact with us in a non-client capacity. This Privacy Policy is designed to provide transparency regarding our data practices and to comply with applicable federal and state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other relevant data protection regulations.

Our separate Gramm-Leach-Bliley Act (“GLBA”) Privacy Notice applies to certain financial products and services we provide to our clients and explains how we handle “nonpublic personal information” in connection with those products and services. Where GLBA applies, that notice will govern. This online Privacy Policy primarily covers personal information collected through our websites, digital properties, and marketing activities that fall outside the scope of GLBA.By accessing, browsing, or using our website, mobile applications, or any of our digital properties, or by providing any information to us through online or electronic means, you expressly acknowledge that you have read, understood, and agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree with any provision of this Privacy Policy, you should immediately discontinue use of our websites and digital services and refrain from providing us with any personal information. Your continued use of our services following any modifications to this Privacy Policy will constitute your acceptance of such changes.

1. SCOPE
This Privacy Policy applies to:• Visitors to our websites, mobile applications, landing pages, microsites, and any other digital properties we operate or control• Individuals who fill out online forms, request information, download content, sign up for communications (including email, SMS, push notifications, and other electronic messaging), participate in surveys or polls, or engage with our interactive tools* Prospective clients, existing clients (to the extent not covered by our GLBA Privacy Notice), business contacts, vendors, partners, event attendees, webinar participants, newsletter subscribers, social media followers, and job applicants whose information we collect through online or digital means* Any other individuals whose personal information we collect, process, or maintain through our digital channels or in connection with our online marketing and business development activitiesThis Privacy Policy does not modify any advisory agreement, account agreement, or other contract you may have with us. If there is a conflict between this Privacy Policy and a written agreement with you, the terms of that agreement will control.

2. PERSONAL INFORMATION WE COLLECT
The types of personal information we collect online depend on how you interact with us. Over the past 12 months, we may have collected the following categories of personal information:• Identifiers– Name, mailing address, email address, phone number, mobile phone number, IP address, online identifiers, and similar information.• Customer records and professional information– Information you provide in web forms or communications, such as your firm name, job title, advisory needs, goals, or basic financial profile information.• Internet or other electronic network activity– Browsing history, log data, pages viewed, referring URLs, time and date of visits, and interactions with our website, emails, or online content.• Geolocation data– General location information inferred from your IP address (for example, city or region).• Audio, visual, or similar information– If you participate in recorded webinars, events, or video calls hosted through our platforms.• Inferences– Inferences we may draw from the information above to help understand your preferences, interests, or potential advisory needs.For existing advisory clients, we may also collect additional nonpublic personal information as described in our GLBA Privacy Notice.

3. HOW WE COLLECT PERSONAL INFORMATION
We collect personal information in several ways:• Directly from you– When you fill out online forms, schedule a consultation, request information, subscribe to communications, opt in to SMS, or otherwise communicate with us.• Automatically from your devices– Through cookies, pixels, log files, analytics tools, and similar technologies when you visit or use our websites or open our emails.• From service providers and third parties– From marketing or analytics providers, web-hosting providers, customer relationship management (CRM) platforms, event partners, and similar vendors that support our business.• From affiliates– From our affiliated entities, such as insurance or investment entities, where permitted by law.

4. HOW WE USE PERSONAL INFORMATION
We use the personal information we collect for the following business purposes:• To provide, operate, and improve our websites and online services• To respond to inquiries, schedule meetings, and communicate with you• To send you newsletters, market commentary, updates, invitations, and other communications (including SMS, where you have opted in)• To personalize your experience and tailor content and communications to your interests• To conduct analytics regarding website usage and the effectiveness of our communications and marketing• To maintain security and prevent fraud, misuse, or unauthorized access• To comply with legal and regulatory obligations and respond to lawful requests• For other purposes disclosed to you at the time we collect information, or with your consent

5. COOKIES AND ANALYTICS
We and our service providers use cookies, pixels, and similar technologies to:• Recognize your browser or device• Remember your preferences• Analyze how visitors use our websites• Measure and improve website performance and marketing campaignsYou can adjust your browser settings to block or delete cookies, but some website features may not function properly if you do so. If you use a browser-based opt-out or a global privacy control signal, we will treat it in accordance with applicable law.

6. HOW WE DISCLOSE PERSONAL INFORMATION
We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under California law.We may disclose personal information to:• Service providers– Companies that provide services on our behalf, such as website hosting, data storage, analytics, communications platforms, email/SMS delivery, customer relationship management, and professional advisers (e.g., attorneys, auditors, consultants). These parties are permitted to use personal information only to perform services for us or as required by law.• Affiliates– Our affiliated entities, such as insurance or investment affiliates, as permitted by law and consistent with this Privacy Policy and our GLBA Privacy Notice.• Business partners and counterparties– As needed in connection with joint events, webinars, or business projects, and only to the extent permitted by law.• Legal, regulatory, and safety purposes– To comply with applicable law, regulation, legal process, or governmental request; to protect our rights, property, or safety; to enforce agreements; or to investigate or prevent fraud or other illegal activity.• Corporate transactions– In connection with a merger, acquisition, reorganization, sale of assets, or similar corporate transaction, subject to appropriate confidentiality protections.We do not share personal information with nonaffiliated third parties for their own independent marketing purposes.

7. SMS/TEXT MESSAGING PRIVACY
If you choose to opt in to receive SMS/text messages from us (for example, by submitting a web form or checking a box to receive text updates), we will collect and use your mobile phone number for that purpose.We use your mobile number and SMS consent to:• Send you messages related to your requests, communications, or relationship with us• Send confirmations, reminders, or service-related messages• Send certain marketing or informational messages, where permitted by law and your preferencesWe do not sell your mobile phone number.SMS consent is not shared with third parties.In addition, we do not share, sell, rent, or disclose your SMS consent or mobile phone number to third parties or our affiliates for their own marketing purposes.You may opt out of SMS at any time by replying STOP to any message. You may also contact us using the methods listed in the “Contact Us” section below and request that we remove your number from our SMS list.Message frequency may vary. Message and data rates may apply depending on your mobile plan and carrier.

8. YOUR PRIVACY RIGHTS (INCLUDING CALIFORNIA RESIDENTS)
Depending on where you live, you may have certain rights regarding your personal information, subject to applicable law. These may include:• Right to know/access– The right to request that we disclose the categories and specific pieces of personal information we have collected about you.• Right to deletion– The right to request that we delete personal information we have collected from you, subject to legal and regulatory retention requirements.• Right to correction– The right to request that we correct inaccurate personal information about you.• Right to non-discrimination– We will not discriminate against you for exercising your privacy rights.Because we do not sell or share personal information for cross-context behavioral advertising, the statutory “right to opt out of sale or sharing” is not applicable to our current practices.How to exercise your rights:You can submit a request by:• Calling us at (818) 835-8720; or• Using the contact form or other contact details provided on our website at www.steelpeakwealth.com.We may need to verify your identity before fulfilling your request, which may require matching information you provide with information we maintain. You may also authorize an agent to make a request on your behalf, subject to verification of the agent’s authority and your identity.Some information may be exempt from these requests under applicable law (for example, information subject to GLBA, or information we are required to maintain for legal or regulatory reasons).

9. DATA RETENTION
We retain personal information for as long as reasonably necessary to:• Fulfill the purposes described in this Privacy Policy• Provide services and maintain business records• Comply with legal, regulatory, and compliance obligations (including recordkeeping requirements for investment advisers)• Resolve disputes and enforce our agreementsRetention periods may vary depending on the type of information and applicable legal requirements. In many cases, we are required to retain certain records for a number of years under securities and other laws.

10. SECURITY
We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure. These safeguards include access controls, secure systems, and other measures consistent with applicable laws and industry practice.No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

11. CHILDREN’S PRIVACY
Our websites and online services are not directed to children under 13, and we do not knowingly collect personal information online from children under 13. If we become aware that we have collected such information, we will take reasonable steps to delete it as required by law.

12. THIRD-PARTY WEBSITES AND SERVICES
Our website may contain links to third-party websites or services that are not controlled by SteelPeak Wealth. This Privacy Policy does not apply to those third-party sites or services. We encourage you to review the privacy policies of any third-party sites you visit.

13. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. When we do, we will post the updated policy on our website with an updated “Last updated” date. Your continued use of our website or interaction with us after an update constitutes your acceptance of the revised Privacy Policy.

14. SMS TERMS OF SERVICE
By opting into SMS from a web form or other medium, you are agreeing to receive SMS messages from SteelPeak Wealth. This includes SMS messages for conversations and other communications related to your relationship with us. Message frequency varies. Message and data rates may apply depending on your mobile carrier and plan.SMS consent is not required as a condition of obtaining advisory or other services from us.

Mobile opt-in data—including telephone numbers, SMS consent, and message preferences—will not be shared with any third parties or affiliates for marketing or promotional purposes. Mobile opt-in data will be used solely for delivering the SMS communications that the user has consented to receive and for no other purpose.

You can reply HELP to any message for assistance.
You can reply STOP to any message to opt out of receiving further SMS messages from us at that number. Your opt-out will not affect other communications we may send you by email, phone, mail, or other channels, as permitted by law and your communication preferences.In addition, users may opt out of SMS messaging by sending an email request to Operations@spwm.com, identifying the mobile number to be removed. After receipt of a valid opt-out request by email, SMS messaging to that number will be discontinued within a reasonable time.

15. CONTACT US
If you have any questions about this Privacy Policy, our privacy practices, or your privacy rights, please contact us at:
SteelPeak Wealth, LLC
Phone: (818) 835-8720
Website: www.steelpeakwealth.com
Email: Operations@spwm.com
You may also contact us through any contact methods listed on our website.