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General Privacy Statement and Legal Policy

PRIVACY PLEDGE

J.A. Reinhold Asset Management is committed to honoring the privacy and security of its website visitors. We collect information to process your transactions and to help us provide a better level of service. We do not sell your information to anyone. We strive to protect the security and confidentiality of the information we collect. We urge you to read the following sections.

There are a number of different ways that we may collect or use personal information from you. At the time of collection we will set out clearly the information that we are collecting and the purposes for which we will use it.

COMMUNICATIONS FROM YOU

You may email or write to us providing your name and contact details and any other personal information contained in your message.

CUSTOMER SUPPORT

You may telephone or email us in respect of technical assistance you require in respect of our products or information that you would like to receive relating to our products.

EMAIL/DIRECT MAIL CAMPAIGNS

From time to time we may contact you directly by mail, email or telephone informing you about new products, promotions or special offers that you may be interested in.

NEWSLETTERS

We may send out newsletters to our customers providing them with articles and information, which we believe, may be of interest to you.

AGGREGATE INFORMATION

Whenever you enter our website, our web server automatically collects and aggregates information in respect to your visit. This information includes URLs or domains of referring websites, browser type, operating system, the pages that you access and the date and time of your visit. In general, this aggregate information will not identify you personally. If we do correlate such information to you, we will treat it in accordance with this policy.

Because we rely on third party commercial software and programs to operate our servers, we may inadvertently collect personal information due to certain automatic functions or features contained in such software or due to certain software changes or upgrades.

COOKIES

“Cookies” are pieces of information that are stored by your browser on your computer’s hard drive to enable you to more easily communicate and interact with a Web site. We may use cookies to allow you to use our site more easily and to allow us to keep track of certain statistical information that helps us improve our site. Most web browsers are initially set to accept cookies. You may, however, disallow reception of cookies at any time by resetting your Web browser. We will never use cookies to retrieve information from a computer that is unrelated to the Web Site or your interaction with the Web Site.

CLICK STREAM DATA

As you browse the Internet, a trail of electronic information is left at each Web site you visit. This information, which is sometimes called “click stream” data, can be collected and stored by a Web site’s server. Click stream data can tell us the type of computer and browsing software you use, the address of the Web site from which you linked to the Web Site, and in some instances, your e-mail address. We may use click stream data to determine how much time visitors spend on each page of the Web Site and how they navigate through the Web Site. We will only use this information to improve the Web Site. Any collection or use of click stream data will be anonymous and aggregate, and will not contain any personally identifiable information.

CONSENT TO PROCESSING

By providing any information to the Web Site, all users fully understand and unambiguously consent to the collection and processing of such information in the United States.

SECURITY

We use commercially reasonable efforts to ensure that your information is stored and maintained in a secure environment. We have implemented procedures to ensure that your information is only made available to such designated staff as necessary to carry out the stated purposes that we have communicated to you.

LEGAL DISCLOSURE

Pursuant to valid legal process, such as a search warrant, subpoena or court order, we allow access to information, including personally identifiable information, provided to the Web Site in order to comply with such process and to protect our rights and property.

LINKED SITES

The Web Site may contain links to other sites. Other sites may also reference or link to the Web Site. J.A. Reinhold Asset Management is not responsible for the privacy practices or the content of such other sites.

CHILDREN

This site is a general audience site, which is neither designed nor intended to collect personal information from children who are under the age of 13. In order to ensure compliance with the provisions of the Children’s Online Privacy Protection Act children under the age of 13 should not provide any personal information to this site. We ask that parents supervise their children while online.

USER’S ACCEPTANCE OF THIS POLICY

By visiting this Web Site, you signify your consent to the terms of J.A. Reinhold Asset Management standard’s legal and privacy policies. If you do not agree with the terms of these privacy policies, please do not use the Web Site. We reserve the right, at our sole discretion, to change, modify, add or remove portions from this privacy and legal policy at any time. Your continued use of the Web Site following the posting of changes to these terms means you accept these changes.