Covestor

Last updated 5 June 2009

Covestor Limited and Covestor Investment Management (CVIM), Covestor’s investment management division, have adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our clients and model managers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you.

This policy outlines the types of information we collect about you and how we use and safeguard that information. If you have any questions or concerns regarding this statement, you should contact Client Services.

1. What Information We Collect

1. When you sign up to become a client or model manager of CVIM, we collect certain non-public personal information about you (such as your name, address, social security number, email addresses, telephone numbers and personal, financial and investment status etc.) from information that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.).

2. We also collect information about your brokerage accounts and transactions (such as account numbers, additions/withdrawals, purchases, sales, account balances, inquiries, etc.).




2. What Information We Disclose

1. We do not disclose the non-public personal information we collect about our clients and model managers to anyone except:

1. in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.);

2. to persons assessing our compliance with industry standards (e.g. professional licensing authorities, etc.);

3. our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.

4. We are permitted by law to disclose the non-public personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.

2. If you decide at some point to either terminate our services or become an inactive client or model manager, we will continue to adhere to our privacy policy, as may be amended from time to time.




3. Security of Your Information

1. We restrict access to your non-public personal information to those employees who need to know that information to service your account.

2. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your non-public personal information.

3. The CV.IM console uses secure socket layer technology (SSL) so that information displayed and submitted by you is encrypted. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.




4. Communications

1. We will send you communications related to the servicing of your account when necessary to do so. These include but are not restricted to client take-on instructions and order confirmations.

2. We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

3. Generally, you may not opt-out of these communications, which are not promotional in nature.




5. Web Site Usage

1. When you visit our website we use “cookies” or other similar web tools to enhance the user experience. These tools enable us to maintain your web session while you browse the site as well as helping us provide you with a better, more personalized experience. Our cookies do not contain any personally identifiable information.

2. Covestor automatically receives and records information on our server logs from your browser including your IP address, CVIM cookie information and the pages you request. We use this information to improve the functionality and usability of our services. Our log files are not tied to personally identifiable information.




6. Amending Your Account Information

1. We are committed to keeping accurate and up-to-date records to help ensure the integrity of the services we offer. If you identify an inaccuracy, or need to make a change to it, please either update the information if you are able directly on our website or alternatively contact Client Services.

2. Covestor has the right to edit, remove or add any information at any time at its sole discretion.




7. Changes to our Privacy Policy or Relationship with You

1. Our policy about obtaining and disclosing information may change from time to time.

2. We will provide you notice of any material change to this policy before we implement the change.