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  EisnerAmper Fund Services's Privacy Policy: Last Modified: 06/20/2018
 
EisnerAmper Fund Services LLC (the "Company", "us" or "we") respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.eisneramperfundservices.com (the "Website") and when you create an account with us to use the Website, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:
 
bullet On the Website.
bullet In the process of exchanging any electronic messages between you and the Website.
bullet Through mobile and desktop applications, if any, that you download from the Website.
bullet When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
bullet Through any other means associated with or relating to the Website.
  This policy does not apply to information collected by:
 
bullet Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
bullet Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
  Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to the terms of this privacy policy.

This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

  Children Under the Age of 13
 
Our Website is not intended for children under eighteen (18) years of age. No one under age eighteen (18) may provide any personal information to us or on or through the Website.

We do not knowingly collect personal information from children under the age of thirteen (13). If you are under thirteen (13), do not use or provide any information on this Website or on or through any of its features or register on the Website (if such feature is available), make any purchases through the Website (if such feature is available), use any of the interactive or public comment features of this Website (if such feature is available) or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under thirteen (13) years of age without verification of parental consent, we will delete that information.

If you believe we might have any information from or about a child under the age of thirteen (13), please contact us at privacy@eafsllc.com.

  Information We Collect About You and How We Collect It:
 
We may collect several types of information from and about users of our Website, including information:
 
bullet by which you may be personally identified, such as name, mailing address, e-mail address, telephone number, or your company's name (collectively, "personal information").
bullet that is about you but individually does not identify you, such as the internet protocol (IP) address from which you log onto the Website, or the geographic location from which you accessed the Website, and
bullet about your internet connection, your browser, the equipment you use to access our Website, your browsing history, and usage details.
  We collect this information:
 
bullet Directly from you when you provide it to us.
bullet Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
bullet From third parties, for example, our affiliates or business partners.
 
  Information We Collect About You:
 
The information we collect on or about you may include:
 
bullet Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, creating an account (if such a feature is available), subscribing to a service, or requesting further services or information from us.
bullet Information you provide to us or we acquire from your network or computing device.
bullet Records and copies of your correspondence (including email addresses), if you contact us.
bullet Any comments and information you provide to us when you use the "Contact Us" feature of our Website.
bullet Your responses to surveys that we might ask you to complete.
bullet Your search queries on the Website.
bullet Information that our affiliates and business partners collect about you, such as services you have signed up to receive, or products you have purchased, in each case which are related to our business.
bullet Information you provide when you contact our customer service agents, if available.
bullet Any other information you provide to us, or we collect throughout your usage of or access to our Website, which we collect for a business purpose.
 
  Information We Collect Through Automatic Data Collection Technologies:
 
As you navigate through and interact with our Website and mobile applications, we may use automatic data collection technologies to collect certain information about you, your equipment, browsing actions, and patterns, including:
 
bullet Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
bullet Information about your computer or mobile device and about your internet connection, including your IP address, mobile device identifier, your operating system, browser type, and the name of your mobile carrier.
  We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our services and our Website and to deliver a better and more personalized service, including by enabling us to:
 
bullet Estimate our audience size and usage patterns.
bullet Store information about your preferences, allowing us to customize our Website according to your individual interests.
bullet Speed up your searches.
bullet Recognize you when you return to our Website.
bullet Analyze our services and products and perform market research.
  When you visit or leave our Website by clicking a hyperlink or when you view a third-party site that includes our plugins or cookies (or similar technology), we may automatically receive the URL of the site from which you came or the one to which you are directed.

We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we may use to show you local information on our mobile applications and for fraud prevention and security purposes. Most mobile devices allow you to prevent real time location data being sent to us.

The technologies we use for this automatic data collection may include:
 
bullet Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Note that while you can set your browser to not allow cookies, we may not be able to honor that request, and may track your activity and collect information about you and your online activities even when the browser is set to "do not track",
bullet Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies and you may not be able to shut down our collection of and use of information through this technology.
bullet Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
 
  Do Not Track:
 
Do Not Track ("DNT") is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser's DNT option in your browser's preferences. When a user's browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly. We intend to comply with DNT signals, and have implemented steps in an effort to do so, however, browser settings can change over time and are different from browser to browser, so we cannot assure you of compliance with DNT signals at any given time or across all different browsers.

  Third-Party Use of Cookies and Other Tracking Technologies:
 
Some content or applications, including advertisements, on the Website may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

  How We Use Your Information:
 
We may use information that we collect about you or that you provide to us, including any personal information:
 
bullet To present our Website and its contents to you.
bullet To provide you with information, products, or services that you request fromus, and those of our affiliates.
bullet To fulfill any other purpose for which you provide it.
bullet To provide you with notices about your account and/or the Website.
bullet To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, if needed.
bullet To notify you about changes to our Website or any products or services we offer or provide though it.
bullet To allow you to participate in interactive features on our Website, if any.
bullet To develop and create our products and services.
bullet For behavioral tracking.
bullet For any other purpose as needed for our business.
bullet In any other way we may describe when you provide the information.
bullet For any other purpose with your consent.
bullet To contact you about our own and third-parties' goods and services that we think may be of interest to you.
bullet To enable us to display advertisements to our advertisers' target audiences.
 
  Disclosure of Your Information:
 
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:
 
bullet To our subsidiaries and affiliates.
bullet To contractors, service providers, and other third parties we use to support our business and assist us in providing services and offering our products.
bullet To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
bullet To third parties to market their products or services to you.
bullet To fulfill the purpose for which you provide it.
bullet For any other purpose disclosed by us when you provide the information.
bullet With your consent.
  We may also disclose your personal information:
 
bullet To comply with any court order, law, or legal process, including responding to any government or regulatory request.
bullet To enforce any agreements between us, including this Privacy Policy, including for billing and collection purposes.
bullet If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
 
  Your California Privacy Rights:
 
California Civil Code Section 1798.83, known as the "Shine The Light" law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

Note that, as stated in the 'Information We Collect Through Automatic Data Collection Technologies' Section above, we may use cookies and other tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

Please also see the "Do Not Track" Section above for information on how our Website responds to your browser's "do not track" settings.

  Data Security:
 
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to change your password from time to time. We also highly recommend that you use a password that is dissimilar to and cannot be easily found by unauthorized third parties who may have obtained your login credentials to other sites. Keep in mind that if you use the same password for all websites, if someone obtains your credentials for one site, they may be able to then use those credentials to log into any other site you use.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted through or collected through the use of our Website. Any transmission of personal information is at your own risk.

We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

  Changes to Our Privacy Policy:
 
The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

  Contact Information:
 
To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@eafsllc.com.

   
© EisnerAmper Fund Services LLC 2018 EisnerAmper Fund Services LLC