Alesco Advisors LLC (“Alesco Advisors,” “we,” or “our”) strives to maintain the highest standards of confidentiality and to respect the privacy of our client relationships. This Privacy Notice is provided in accordance with Title V of the Gramm-Leach-Bliley Act of 1999 and the U.S. Securities and Exchange Commission’s Regulation S-P (17 C.F.R. Part 248), including the 2024 amendments to the Safeguards Rule and Disposal Rule. Our goal is to protect the confidentiality, integrity, and security of nonpublic personal information entrusted to us.

 Information We Collect About Clients

We collect nonpublic personal information (“customer information”) directly from you, from account applications and forms you complete, from conversations with you, and from third parties you have authorized to provide such information. Examples include:

• Personal identifiers such as social security numbers, personal addresses, business affiliations, telephone numbers, ages and marital status of clients and related persons;
• Financial details such as income, assets, liabilities, investment objectives, tax status, and risk tolerance;
• Account data from custodians, brokers, or other financial institutions with whom you maintain relationships;
• Identities of your attorneys, accountants, banks, brokers, investment advisers or managers, and others furnishing professional or financial services; and

Some of this information may qualify as “sensitive customer information” under Regulation S-P (17 C.F.R. § 248.30(d)(9)), meaning information that—alone or in combination with other data—could create a reasonably likely risk of substantial harm or inconvenience if improperly accessed.

How We Use and Share Client Information

Alesco Advisors uses client information only for legitimate business purposes, such as providing investment advisory services, account administration, billing, compliance, and client communications. We do not sell client information. We disclose nonpublic personal information only:

• Such information required by the account custodian to establish your asset account at Alesco Advisors;
• Such information above as is required to enable you to invest in an investment partnership or similar entity;
• Such information above as is required to enable you to obtain an insurance, annuity, investment, or other contract;
• The particulars of any trade of a security in your account to the account custodian and executing broker;
• Some or all of the above information to the entity or entities providing electronic data with respect to our client accounts;
• Any information you have authorized us to furnish to your attorney, accountant, or other person or entity; and
• Information (on a confidential basis) to any entity with which Alesco Advisors may contemplate a merger or consolidation or purchase or sale of assets, or to Alesco Advisors’ accountants, attorneys, or other advisors.
• As otherwise permitted or required by law.

When our relationship with you ends, we continue to treat your information as confidential and subject to this Privacy Notice.

Safeguarding Client Information

Consistent with the Safeguards Rule (17 C.F.R. § 248.30(a)), Alesco Advisors maintains written policies and procedures that include administrative, technical, and physical safeguards designed to:

1. Ensure the security and confidentiality of client information;
2. Protect against anticipated threats or hazards; and
3. Prevent unauthorized access to or use of client information that could result in substantial harm or inconvenience.

These safeguards include restricted access controls, secure data storage, encryption protocols, and employee training on confidentiality and cybersecurity. We periodically review and update these controls in light of evolving technology, regulatory guidance, and industry best practices. (See Safeguards Rule, 17 C.F.R. § 248.30(a)).

 Incident Response and Client Notification

In accordance with the amended Safeguards Rule (17 C.F.R. § 248.30(b)), Alesco Advisors maintains an incident-response program designed to detect, respond to, and recover from any unauthorized access to or use of customer information. If we determine that sensitive customer information has been—or is reasonably likely to have been—accessed or used without authorization, we will notify affected individuals as soon as practicable, but no later than 30 days after becoming aware of such an event, unless a delay is authorized by federal authorities for national-security or public-safety reasons. Our response process includes assessing the scope of the incident, containing and controlling any threat, investigating affected systems, and documenting all findings and remedial measures. (See Incident Response Program Requirement, 17 C.F.R. § 248.30(b)(2)).

 Authorized Service Providers

We engage a limited number of authorized service providers to support our advisory, operational, and compliance activities. These service providers may have access to customer information only as necessary to perform their functions and are contractually required to safeguard such information. In alignment with the Service Provider Oversight Requirement (17 C.F.R. § 248.30(b)(3)), Alesco Advisors conducts due diligence and ongoing monitoring of its service providers to ensure appropriate data-protection measures are in place and that they notify us of any security incidents within 72 hours of discovery. (See Service Provider Oversight, 17 C.F.R. § 248.30(b)(3)).

 Recordkeeping and Retention

Alesco Advisors maintains written records documenting compliance with the Safeguards Rule and Disposal Rule (17 C.F.R. § 248.30(c); 17 C.F.R. § 275.204-2(a)(25)). Records include our privacy and information-security policies, documentation of any detected or investigated incidents, service-provider agreements, and evidence of employee training. Client information is retained only as long as necessary to fulfill our advisory obligations and regulatory requirements. (See Recordkeeping Requirements for RIAs, 17 C.F.R. § 275.204-2(a)(25)).

Annual Privacy Notice and Updates

In accordance with 17 C.F.R. § 248.5(e), Alesco Advisors may rely on an exception from the annual privacy-notice delivery requirement if our data-sharing practices remain consistent with prior disclosures and any sharing occurs only under permissible exceptions. If our privacy practices materially change, we will provide you with an updated Privacy Notice reflecting those changes. (See Annual Privacy Notice Exception, 17 C.F.R. § 248.5(e)).

Continued Protection of Client Information

Even if you are no longer an active client, Alesco Advisors will continue to protect your nonpublic personal information in accordance with this Notice. We remain committed to maintaining your trust and ensuring the confidentiality of your financial and personal information. (See Reg S-P Safeguards Rule, 17 C.F.R. § 248.30(d)).

Notice Regarding Alesco Advisor LLC

ESL NewCo I, LLC (ESL-Alesco) CRD number 339091 will succeed to the registration and advisory business of Alesco Advisors, LLC (“Alesco”) CRD number 108590, upon the SEC’s declaration of the ESL-Alesco’s registration.