General Disclosure Information

This site is only intended for clients and interested investors residing in states and countries in which Alton Capital Management is qualified to conduct investment advisory services.

Alton Capital Management is an SEC registered investment adviser located in Alton, IL. Alton Capital Management may only transact business in those states or countries in which it is registered, or qualifies for an exemption or exclusion from registration requirements. For non-clients of the firm, Alton Capital Management's website is limited to the dissemination of general information pertaining to its investment advisory services.

Please contact Alton Capital Management at 618-466-9700 to find out if we may conduct advisory business in the state or country where you reside. Accordingly, Alton Capital Management does not, and will not, effect or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, through this website. Any subsequent, direct communication with a prospective client shall be conducted by an Alton Capital Management representative who is either registered or qualifies for an exemption or exclusion from registration in the state or country where the prospective client resides.

For further information regarding our firm or any other investment advisory firm, please visit www.adviserinfo.sec.gov.

FORM ADV PART II

Please call our offices to request a free copy of our Form ADV Part II.

BUSINESS CONTINUITY PLAN

Click to view/print either of the following:

ASG Business Continuity Plan Summary
ASG Business Continuity Plan

PRIVACY POLICY

Alton Capital Management requires that you provide current and accurate financial and personal information. We will protect the information you have provided in a manner that is safe, secure and professional. Alton Capital Management and its employees are committed to protecting your privacy and to safeguarding that information.

SAFEGUARDING CUSTOMER DOCUMENTS

We collect non-public customer data in checklists, forms, in written notations, and in documentation provided to us by our customers for evaluation, registration, licensing or related consulting services. We also create internal lists of such data.

During regular business hours access to customer records is monitored so that only those with approval may access the files. During hours in which the company is not in operation, the customer records will be locked.

No individual who is not so authorized shall obtain or seek to obtain personal and financial customer information. No individual with authorization to access personal and financial customer information shall share that information in any manner without the specific consent of a firm principal. Failure to observe Alton Capital Management�s procedures regarding customer and consumer privacy will result in discipline and may lead to termination.

SHARING NON-PUBLIC PERSONAL & FINANCIAL INFORMATION

Alton Capital Management is committed to the protection and privacy of its customers� and consumers� personal and financial information. Alton Capital Management will not share such information with any affiliated or nonaffiliated third party except:

When necessary to complete a transaction in a customer account, such as with the clearing firm or account custodians;

When required to maintain or service a customer account;

To resolve customer disputes or inquiries;

With persons acting in a fiduciary or representative capacity on behalf of the customer;

With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;

In connection with a sale or merger of Alton Capital Management�s business;

To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;

To comply with federal, state or local laws, rules and other applicable legal requirements;

In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement;

In any circumstances with the customer�s instruction or consent; or

Pursuant to any other exceptions enumerated in the California Information Privacy Act.

Opt-Out Provisions

It is not a policy of Alton Capital Management to share nonpublic personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service customer accounts or is mandated by law, there are no allowances made for clients to opt out