Cassford Management LLC

Web Site Privacy Policy

This is the privacy policy ("Privacy Policy") for the Cassford Management Web Site with a front page at the cassfordmanagement.com domain name (this Site). This Site is made available by Cassford Management LLC, a New York Limited Liability company ("Cassford Management" or we or us). This Privacy Policy sets forth our policies regarding the collection, use and disclosure of certain personally identifiable information (Personal Information) relating to an individuals use of this Site. Your use of this Site signifies your understanding and acceptance of the terms of this Privacy Policy. This Privacy Policy is incorporated into, and part of, the [Cassford Management Web Site Terms and Conditions], which govern your use of this Site in general, and shall be read as if the Terms and Conditions and Privacy are one unified document. For the avoidance of doubt, this Privacy Policy applies to Personal Information collected through this Site, but not to Cassford Management LLC offline business activities. UNDER WHAT CIRCUMSTANCES DO WE COLLECT YOUR PERSONAL INFORMATION?

Personal Information When you send us an e-mail through this Site, we obtain your e-mail address from your e-mail.

Technical information When you visit this Site, we may collect technical information that does not, by itself, identify you by name. This information may include your IP (Internet Protocol) address, which pages you visit on this Site, and which browser you used to view this Site. This technical data is used to measure and improve the effectiveness of this Site, to help diagnose problems with our server, to administer this Site, to see where Site traffic is coming from and to identify our users. We may also collect other non-personally identifiable information via this Site, such as Site usage activity and preferences, also known as demographic or profile data. We may combine the data described in this paragraph with your Personal Information.

DO WE USE WEB BUGS? We may use web bugs (described in more detail below) in this Site or in our communications with you to verify your viewing and/or receipt of communications. A web bug is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail, which is retrieved from a remote site on the Internet enabling the verification of an individuals viewing or receipt of a Web page or e-mail message.

USE OF PERSONAL INFORMATION We use Personal Information collected on and through this Site for a variety of purposes in the course of business and as otherwise set forth herein. For example: To respond to your requests that you send to us via e-mail; To send you e-mail messages promoting our products and services and products and services that we jointly provide with our business partners or our business ventures. (You may opt-out of receiving certain promotional e-mail messages from us as described in the Opt-out section below.)

DO WE SHARE YOUR PERSONAL INFORMATION? We may contract with other companies or individuals to provide you the services that you request from us. Such companies may be given access to your Personal Information solely for their use in connection with providing you with those services, consistent with this Privacy Policy. We may use third party service providers to develop and/or host our web site, to host and maintain our databases, to transmit our e-mail messages, and to provide other back-end services for this Site. In connection with this, such service providers may have access to your Personal Information for use solely on our behalf consistent with this Privacy Policy. We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a Reorganization Event), transfer, sell or assign your Personal Information to third parties involved in the Reorganization Event. From time to time, we may be required to provide Personal Information in response to a court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful, and to disclose any information concerning you as necessary or appropriate to satisfy any law, regulation or other governmental request, to operate this Site properly, or to protect or defend our rights or the rights or well-being of our users or if you are involved (or are reasonably suspected to be involved) in any illegal or harmful activity, even without a subpoena, warrant or court order. We may release certain Personal Information when we believe that such release is reasonably necessary to protect the rights, property, and safety of others and ourselves.

DO YOU HAVE CHOICES REGARDING HOW YOUR PERSONAL INFORMATION IS USED? Opt-Out If you would like to opt not to receive promotional or marketing e-mail from us in the future, you may let us know by sending us an e-mail to info@cassfordmanagement.com stating the e-mail address you wish to be removed from our mailing list. However, your option not to receive promotional and marketing e-mail shall not preclude us from corresponding with you, by e-mail or otherwise, regarding your existing relationship with us. Your opt-out request will also not apply to correspondence that has already been initiated.

CONSENT TO PROCESSING By providing any Personal Information to this Site, you fully understand and unambiguously consent to the transfer of such Personal Information to, and the collection and processing of such Personal Information in, the United States, provided, however, only to the extent permitted in this Privacy Policy.

SECURITY Please be careful whenever sending Personal Information to us via e-mail. E-mail is commonly not a secure means of transferring information. Due to the open nature of the Internet, we cannot guarantee that any information stored on our servers, or transmitted to or from you, will be free from unauthorized access. By using this Site, you acknowledge that you understand and agree to assume these risks. In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

THIRD PARTIES We have no control over what information third parties track or collect, and we have no responsibility or liability for any tracking, data collection or other activities of third parties.

DOMICILE REQUIREMENT FOR USE OF THE SITE You represent and warrant that, unless you otherwise notify us in writing, you are domiciled in the United States. If you are not domiciled in the United States and you so notify us in writing, applicable foreign law may or may not afford different protections for your privacy and personal data. You agree that United States law will apply to this Privacy Policy and your Personal Information without regard to laws relating to choice or conflicts of laws.

WHO CAN YOU CONTACT IF YOU HAVE QUESTIONS OR CONCERNS? Please contact us at info@cassfordmanagement.com to report any known or suspected privacy or security breaches or to submit privacy-related questions or complaints.

WILL THIS PRIVACY POLICY CHANGE? If there are changes or additions to this Privacy Policy, we will notify you by posting those changes here. Changes and additions to this Privacy Policy are effective when they are posted. Please check this web page periodically to see any changes we have made to our Privacy Policy.

Date of Last Revision to Privacy Policy: 2001