Table of Contents

Scope……………………………………………………………………………………………………………………………………………………………… 2
Definitions………………………………………………………………………………………………………………………………………………….. 2
Changes to this Privacy Policy…………………………………………………………………………………………………………………… 2
Collection of Information………………………………………………………………………………………………………………… 2
Information that You Provide…………………………………………………………………………………………………………………… 2
Automatically Collected Information…………………………………………………………………………………………………….. 2
Information about Legal and Other Materials……………………………………………………………………………………….. 3
Cookies………………………………………………………………………………………………………………………………………………………… 3
Web Beacons……………………………………………………………………………………………………………………………………………….. 3
Cross-Site Tracking……………………………………………………………………………………………………………………………………. 3
Reviewing and Correcting Information……………………………………………………………………………………………………. 3

III. Use and Disclosure of Information………………………………………………………………………………………………… 3

Purposes……………………………………………………………………………………………………………………………………………………… 3
Marketing…………………………………………………………………………………………………………………………………………………… 4
Disclosure…………………………………………………………………………………………………………………………………………………… 4
Storage………………………………………………………………………………………………………………………………………………………… 5
Jurisdiction…………………………………………………………………………………………………………………………………………………. 5
Security………………………………………………………………………………………………………………………………………………………. 5
Miscellaneous…………………………………………………………………………………………………………………………………………… 5
Third-Party Websites………………………………………………………………………………………………………………………………… 5
Business Transfer of Provider………………………………………………………………………………………………………………….. 5
Children’s Information……………………………………………………………………………………………………………………………… 5
Other Agreements……………………………………………………………………………………………………………………………………… 6
Contact Information…………………………………………………………………………………………………………………………………. 6

This Privacy Policy describes the ways in which the company (“Provider”) collects, uses, and discloses information about you, including personally identifiable information, in connection with your use of the website (the “System”). By using the System, you consent to the use of your information as set forth in this Privacy Policy. Throughout this Privacy Policy, “you” refers to the individual or entity that is visiting the System.

I. Scope.

A. Definitions

(1) Provider utilizes the System to provide certain investor management and communication services to you (the “Services”).

(2) In the course of providing the Services, Provider may collect “Personal Information,” which means information about you.

B. Changes to this Privacy Policy.

(1) Provider reserves the right to update this Privacy Policy from time to time by posting a new Privacy Policy on this page, and in some cases where changes are material Provider may also contact you via electronic mail or post a notice on the homepage to let you know of such changes.

(2) You are advised to consult this Privacy Policy regularly for any changes.

(3) Your continued use of the System after such changes have been made constitutes acceptance of those changes.

II. Collection of Information.

A. Information that You Provide.

Provider collects any information that you voluntarily provide, including when you create an account on the System or when you use the Services available through the System.

Provider may also collect information that you provide by electronic mail, telephone or other means.

B. Automatically Collected Information.

Provider may automatically collect certain technical information from your computer or mobile device when you use the System, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the System, the pages you view immediately before and after you access the System, and the search terms you enter on the System.

This information allows Provider to recognize you and personalize your experience if you return to the System using the same computer or mobile device, and to improve the System and the Services.

C. Information about Legal and Other Materials.

In addition, Provider may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials and approval or execution of contracts, consents or other statements or agreements by means of the System, including the System’s Terms of Use and this Privacy Policy.

D. Cookies.

Provider may collect this information using “cookies,” which are small text files that the System saves on your computer or mobile device, or similar technologies.

You can disable cookies in your browser settings, but doing so may affect the functionality of the System.

E. Web Beacons.

Provider may also collect information using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon.

Web beacons, alone or in conjunction with cookies, may help Provider compile information about your interactions with electronic mail sent to you in connection with the Services.

F. Cross-Site Tracking.

Provider does not utilize technical measures in the System to track your activities across different Web sites or online services, whether you configure your browser’s Do Not Track feature or otherwise.

The System does utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.

G. Reviewing and Correcting Information.

Personal Information about you that is stored by the System can be reviewed by accessing your account/profile page.

You may update or correct Personal Information stored about you by means of the System, or by sending a written request to the contact addresses provided below.

III. Use and Disclosure of Information.

A. Purposes.

Provider may use the information collected for a number of purposes, including, but not limited to:

(1) providing you with the services, products, or information related to the System or the Services;

(2) providing you with information about the System, Services or required notices;

(3) customizing your experience when using the System, such as by providing interactive or personalized elements on the System and providing you with content based on your interests;

(4) allowing Provider to improve the System and the Services, such as by better tailoring content to users’ needs and preferences;

(5) generating and analyzing statistics about your use of the System, and use of the System in the aggregate;

(6) detecting, preventing and responding to fraud, intellectual property infringement, violations of the System’s Terms of Use, violations of law or other misuse of the System; and

(7) combining or aggregating any of the information collected through the System or elsewhere for any of these purposes.

B. Marketing.

In addition, Provider may use collected information for delivering marketing communications or investment materials that may be of interest to you.

However, Provider does not sell or otherwise share your personally identifiable information with other companies so that they can market to you.

C. Disclosure.

Provider may disclose the information Provider collects from you through the System:

(1) as necessary to provide you with the Services, or products, services or information related to the System;

(2) to service providers who work on Provider’s behalf and have agreed to adhere to rules at least as strict as those set forth in this Privacy Policy;

(3) to your employees or agents acting on your behalf, if you authorize Provider to do so;

(4) as required by law, such as to comply with a subpoena or other legal process, or to comply with government reporting obligations;

(5) when Provider believes in good faith that disclosure is necessary

(a) to protect Provider’s rights, the rights of other users of the System, the integrity of the System, or your safety or the safety of others, or

(b) to detect, prevent or respond to fraud, intellectual property infringement, violations of the System’s Terms of Use, violations of law or other misuse of the System;

(6) to affiliates, service providers, advisors and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of Provider’s assets;

(7) pursuant to your express consent; or

(8) in the form of aggregate reports on user demographics and traffic patterns, or other information that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Services and developing new Service offerings.

IV. Storage.

A. Jurisdiction.

Information collected through the System will be stored in, processed in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the System, you consent to such transfer to, storage in and processing within the United States.

B. Security.

Provider is committed to protecting your information from unauthorized access, use or disclosure. The system and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the System. For example, all information you transmit to the System is encrypted using Transport Layer Security technology (TLS). However, no information or communication system can be 100% secure, so Provider cannot guarantee the absolute security of your information. In addition, Provider is not responsible for the security of information that you transmit to the System over networks that Provider does not control, including the Internet and wireless networks.

V. Miscellaneous

A. Third-Party Websites.

The System and communications from Provider may contain links to websites operated by third parties. You acknowledge and agree that Provider is not responsible for the collection and use of your information by such websites that are not under Provider’s control. Provider encourages you to review the privacy policies of each website you visit.

B. Business Transfer of Provider.

If Provider, or substantially all of Provider’s assets, are acquired, or in the unlikely event that Provider were to go out of business or enter bankruptcy, user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Provider may continue to use your Personal Information as set forth in this Privacy Policy (as it may be amended from time to time).

C. Children’s Information.

The System is not directed to, nor does Provider knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact Provider immediately using the contact information provided below.

D. Other Agreements.

You may from time to time enter into binding legal agreements relating to certain Services available through the System, which may have terms that are different from those of this Privacy Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.

E. Contact Information.

If you have any questions about this Privacy Policy or the collection or use of information about you, please write to Provider at info@loyaltybrands.com.

VI. Loyalty Brands

A. Our Principles

We value your trust that we will do so sensibly and carefully. We do not share, rent, sell or give any specific personal information provided by you to any third party.

The next several sections describe Loyalty Brands and affiliates’ privacy policy (hereinafter the “Privacy Notice”). By visiting our website, you are accepting the practices described in this Privacy Notice.

As you browse our website, information may be collected and stored related to your visit. For example, to help Loyalty Brands and affiliates better serve the visitors of our website, and improve the website itself, Loyalty Brands and affiliates may monitor and store statistics such as how many people visit our website, which pages people visit on our website, and which browsers they use to do so.

Loyalty Brands and affiliates will also collect information about your transaction with us. This includes information such as securities bought and sold, money balances, and payment history.

Loyalty Brands and affiliates recognizes the need of visitors to our website for reasonable control of their personally identifiable information. The term “personally identifiable information” as used herein refers to any information associated with a visitor’s name or identity. Loyalty Brands and affiliates uses this information to better understand the general needs of visitors and to provide visitors with better service. To help Loyalty Brands and affiliates improve the experience of visitors, Loyalty Brands and affiliates might also track how visitors, in general, use the website.

If you are asked to provide personal information to subscribe to a service offered on our website, or to receive information, we may use such personally identifiable information as we would use the same information obtained in a traditional non-electronic manner. Employees of Loyalty Brands or affiliates who receive and process such requests are responsible for safeguarding individual customer communications and information.

Loyalty Brands and affiliates obtains and uses personally identifiable information for business purposes only. Loyalty Brands and affiliates does not sell or disclose personally identifiable information obtained online to anyone outside of Loyalty Brands and affiliates unless: (a) you specifically authorize it; (b) disclosure is required or permitted by law and/or required by a regulator, court order, warrant or subpoena; requested by government officials with reasonable grounds to believe that the information is a communication of a computer trespasser; or (c) disclosure is deemed necessary by Loyalty Brands or affiliates, in its sole discretion, to protect the safety, rights or property of Loyalty Brands and affiliates or any other person or entity.

B. Securing Personal Information

Loyalty Brands and affiliates works to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information transmitted between your browser and our servers. It is important for you to protect against unauthorized access to your password and to your computer.

C. Disclosing information

We do not disclose nonpublic personal information about our customers to third parties, other than those acting on our behalf, except as needed in the normal course of business or as required by law or regulatory authorities. In rare cases, we may be compelled by law or regulatory authorities to disclose information to third parties without your authorization.

D. What choices do I have?

As discussed above, you can always choose not to provide information. However, doing so may make it difficult or impossible to take advantage of certain features of our website.

E. What about cookies?

Cookies are identifiers in the form of small file containing a string of characters that is sent to your computer when you visit a website. We may use cookies to enhance the user’s experience when visiting our website. The “Help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies; how to have the browser notify you when you receive a new cookie; or how to disable cookies altogether.

F. Electronic communications

When you visit our website, or send e-mails to Loyalty Brands and affiliates, you are communicating with us electronically. By this action, you consent to receive communications from us electronically. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

G. Your Account

If you use our website, you are responsible for maintaining the confidentiality of your account and password, and for restricting access to your computer. In addition, you agree to accept responsibility for all activities that occur under your account or password. Loyalty Brands and affiliates reserves the right to refuse services, to terminate accounts, or to remove or edit content at its sole discretion.

H. Conditions of Use, Notices and Revisions

If you choose to visit our website your visit, and any dispute over privacy, is subject to this Legal Notice and our Terms of Use, including limitations on damages, arbitration of disputes, and application of the law of the State of Virginia without giving effect to any principles of conflicts of law.

I. Changes to this policy

Our business changes constantly, and our Privacy Notice and the Terms of Use will also change. You should check our website frequently to see any recent changes. Unless stated otherwise, our current Privacy Notice and Terms of Use apply to all information that we have about you and your account.

J. Protecting the confidentiality and security of information

We restrict access to nonpublic personal information about you to our employees who need to know such information in order to serve you. We maintain physical, electronic, and procedural safeguards to protect the nonpublic personal information we have collected about you. You have the right to obtain access to certain information we have about you. Further, you have the right to request such information be corrected if you feel it is inaccurate. If you have any questions or would like additional information regarding our firm and your privacy or if you would like to request a copy of our privacy policy or obtain access to your information, please contact us at (888) 268-0321.

K. When was this policy last updated?

This privacy policy was last updated December 23, 2021.