Disclosures

Privacy and Security Policy

We are committed to protecting your privacy and personal information. This notice describes our Privacy Policy and practices.

How does this policy apply to you?

The descriptions in this Policy apply to our relationships with individuals who inquire about and/or obtain products or services from us or any company with whom we partner to provide products or services.

Protecting Your Information

We restrict access to nonpublic information about you to only those employees who need to know that information for a legitimate business purpose, such as providing products and services to you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information.

Collecting Information

We collect only relevant information about our customers that is needed to establish and maintain our business relationship, as the law allows or requires us to collect. In order to provide services to you, and to protect you from fraud, we may collect and maintain nonpublic personal information about you from the following sources:

• Applications and other forms that you provide to us, such as your name, address, social security number, EIN number, assets, income and investment objectives;
• Information about your transactions with us;
• Information we receive from business or consumer reporting agencies, such as your credit worthiness or credit history; and
• Information we receive from outside sources regarding their relationship with you or verifying representatives made by you, such as banking history, loan or deposit balances, employment history, or property insurance coverage.

Sharing of Customer Information

We do not disclose nonpublic personal information about our customers or former customers to anyone, except as permitted by law. However, in order to conduct our operations, including initiation and continuation of services, we need to share information with various service providers. For example, we may provide information to outside companies who will deliver services to you or on your our behalf.

We may share the information we collect about you, with companies that are not our affiliates in the following circumstances. These service providers have contractually agreed to keep the customer information we provide to them confidential.

• Companies that provide services with respect to transactions that you have requested or authorized; or
• When required or permitted by applicable law.

We may share information with our affiliates about your transactions with us, such as your account status, payment history, parties to transactions and any adverse experiences with respect to your account, except as permitted by law. We are permitted by law to share with our affiliates information about your transactions and experiences with us (such as account balances and transaction history), even if you have opted out of non-transactional information sharing.

Sharing of Customer Information with Affiliates

In our efforts to better serve your needs, we may share your non-transactional information with any affiliated company. We want to be sure that we understand your entire relationship with us when addressing your needs, providing you services, developing products and determining what products you may want to know about.

The types of non-transactional information that you may ask us not to share with our affiliates, include:

• Information we obtain from your application, such as your income, assets, or employer;
• Information we obtain for a credit report, such as your credit score or credit history;
• Information we obtain to verify representations made to us by you, such as your creditors or assets; and
• Information we obtain about you from another person regarding your employment, credit or other relationships, such as your employment history.

You have a choice as to whether or not you want this non-transactional information shared with any affiliated company. If you prefer that we not share this information, you may opt out by following the procedure listed below.

Opting Out with Our Affiliates

If you prefer that we not share non-transactional information with any affiliated companies, you may restrict information sharing (other than those disclosures permitted by law) by contacting Customer Service via email at contact@factorfundsinfo.com .

We reserve the right to make changes to this policy, and will notify you at that time.

Protection of Your Information On-Line

If you request information through www.factorfundsinfo.com, use online tools and calculators, apply for products, subscribe to online services, or conduct transactions online, we and any non-affiliated third parties with whom we partner to deliver online services may retain the information you provide. To ensure your online information and/or application is secure, we use technology that encrypts information so it can transfer privately between you and us.

If you agree to receive email messages from us, we may retain the information you provide us to deliver emails of specific interest to you. If you choose to send us an email, we may retain the content of the email message, your email address, and our subsequent response. Please be careful with the type of information you send to us via email, as this channel of communication is not necessarily secure against interception.

Our services are not designed for or directed toward children. We do not knowingly solicit or collect data from children and we do not knowingly market to children online.

Privacy Policy Inquiries

If you have questions about our privacy practices, please contact us (specify contact) via email, US mail, or telephone.