Privacy Policy

GPS Investment Partners, LLC or one or more of its affiliates (collectively, “GPS Investment Partners”, “we”, “us” or “our”) are committed to protecting the security and privacy of your personal information. This Privacy Policy providers information about our collection, processing and disclosure of personal information in connection with the website www.________.com (“Website”).

By visiting the Website, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access the Website. This Privacy Policy is incorporated into and subject to the Terms and Conditions of Use.

Personal Information We May Collect About You

When you contact us using our contact details on the Website, any personal information submitted (e.g., your name or email address) will be collected and processed by us.

We collect non-public personal information about our clients from the following sources:

Information received from clients on subscription documents or other forms, including, the information we collect on the Website;

Identifying information as required by laws and regulations addressing money laundering and related matters or information needed for us to comply with applicable laws and regulations governing the services we provide, and

Information about clients’ transactions with us, our affiliates or others.

In addition, we automatically collect basic technical information from all visitors to the Website. We collect technical information during your visit to the Website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g., web beacons). This information may include your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients. We use this information to operate, develop and improve our services. Please see the Section on Cookies below for further information.

How We Use Your Personal Information

The provision of personal information by you may be necessary where we have a legitimate interest to carry out the following purposes: (i) to contact you and respond to your enquiry or provide you access to specific information or offers; (ii) to support our relationship with you; (iii) to understand how we can improve our products and services; (iv) to personalize your visit to the Website and to assist you while you use the Website; (v) to send marketing communications to you; (vi) to improve the Website by helping us understand who uses the Website; and (vii) to comply with applicable laws, regulations or codes of practice.

Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.

Confidentiality

We may share the non-public personal information we collect with non-affiliates and affiliates for our everyday business purposes, such as to process your transactions, maintain your accounts, and other purposes. Our affiliates may also have access to personal information provided to us by you including through or in connection with this Website for the purposes set out in this Privacy Policy.

We do not disclose any personally identifiable information about you to non-affiliates to market to you.

The servers used in the operation of the Website automatically identify a computer by its IP address. If we, in good faith, determine that you have or are attempting to misuse or harm the Website, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights and property.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities.

Security

GPS Investment Partners uses various methods to ensure the protection of your personal information against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access. While these methods are considered to be effective, GPS Investment Partners does not guarantee the protection of your personal information as no data transmission over the Internet can be guaranteed to be completely confidential or 100% secure. You use our Website and provide all such personal information at your own risk. GPS Investment Partners retains personal information for as long as necessary to fulfill the purposes for which such personal information was collected or to comply with its legal obligations, resolve disputes or enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether GPS Investment Partners is subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Cookies

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit the Website, we may place a “cookie” or other online tracking device (e.g. web beacons) in order to improve your experience by recognizing you when you visit the Website, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your IP address, or click stream data within our Website (i.e. the actions taken in connection with the Website). This information helps us improve the functionality of the Website.

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the Website.