We Respect Your Privacy. Elmcore Group Inc., and its subsidiaries and affiliates, (“Elmcore”, “we”, “us”, “our”) are committed to your privacy. This Privacy Policy details how we use your personal identifying information. This Privacy Policy may be modified at any time without notice to you. Please review this document each time you visit us or use any of our tools or services. We restrict access to your personal and account information to our personnel, affiliated entities, and third-party service providers on a “need to know” basis, in order to provide products or services to you, or as permitted by law. We always maintain physical, electronic, and procedural safeguards to guard your non-public personal information. If you would like to opt-out of any disclosures by us of any and all categories of non-public personal information, please contact us at any time and request to do so. Introduction Elmcore provides online access to information regarding its products and services via its website at http://www.elmcore.com and any third-party website links to our affiliated entities (“Website”). If you feel your privacy has been violated, please contact us immediately. What information is collected and how is it used? To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you; we may also ask to see your driver’s license or other identifying documents. Any non-public personal information will generally be derived from information we receive from you (written or otherwise), information about your transactions with Elmcore (if applicable), and third-party affiliates that may be providing services to you. Information we collect may be used to improve the quality of our Website and for the promotion or benefit of our business and affiliated companies; such information is not necessarily personally identifiable in nature. We may also use information gathered, including Website visitors’ IP (Internet Protocol) addresses to aggregate the same for the placement of targeted promotional content that is mutually beneficial to potential partners, investors, advertisers, customers, and users alike. As such, if you choose to access our Website, you may be able to view third-party offers and advertisements which may contain embedded hyperlinks, or include referral buttons to websites operated by these third-parties. We are not responsible for the content or actions provided or taken through these third-party companies and websites nor the actions they take with your personal information. You can access certain parts of our Website without disclosing your personal data. Some aspects of our Website are available to our customers only and as our Terms of Use require, you must provide us with the required registration information, which has to be complete, accurate and up-to-date, or use identification data such as cookies or location data. You may be provided with the ability to select a password and User ID but may not select or use a User ID that is the name of another person or use any name that you are not legally allowed to use or one that violates the legal rights of another person or entity. Please note that you may be required to log back in to your account after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. You are responsible for the security of your account, including password and User ID. Elmcore cannot and will not be liable for any loss or damage from your failure to comply with this security obligation. We have implemented security procedures to protect the personal data that we have under our control. These procedures help to protect your data from unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss. However, please note that no policy, rule or technical measure can offer 100% protection against unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss. We use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Website. All our employees and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our customers’ and users’ personal data. In the event that the security to such information/content is breached for reasons outside of our control, you agree to hold us harmless and to indemnify us against any loss, damages, injuries, costs, fees, and claims of any and all nature regarding such security breaches. We make no guaranty of confidentiality or privacy of any communication or information transmitted on or through the Website or any website hyperlinked by us. We are not liable for the privacy of any email address, registration or identification information, data storage, communications, trade secrets, or any other content stored in our database or transmitted through our Website. Please reference the Electronic Communications Privacy Act (18 U.S.C. §§ 2701-2711) or any similar law in your jurisdiction for further guidance. Cookies A cookie is a small amount of data, which often includes an anonymous unique identifier, sent to your browser from a web server and stored on your computer’s hard drive. Cookies are small programs that improve your overall experience by assisting the functionality of other tools, services and functions in the Website. You may turn off your cookies by adjusting the appropriate setting on your browser. We use cookies to record current session information and aggregate tracking information of visitors to help us manage our Website. Other possible uses for the information we collect include internal tracking, review, or use for contacting purposes that is then archived by us for future usage. We also use the information we collect to provide custom content for our customer/user base. How to change or remove information? We are not responsible for the privacy of any information that you post, publish, or distribute on our Website or via our Website. Additionally, we cannot promise that content will be anonymous in nature for various reasons that may be outside of control such as governmental action, subpoenas, and other actions we cannot be responsible for. Exceptions to our Privacy Policy Possible exceptions to our Privacy Policy include whether a governmental agency or an attorney subpoenas your private information, or makes a formal request for discovery pursuant to any legal action or pending legal action. Should we possess that information, then we would share whatever personally identifying information we possess with the seeking party and with our attorney as appropriate. Additionally, certain information we collect may be used to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or as otherwise required by law. General Terms Continuity of Service. We will transfer information about you if we are acquired by or merged with another company. Opt-out. If we ever send you communication by email concerning new products, services, or information that you did not expressly request, we will provide means by which you may request no further notices. Questions or Feedback Any questions about this Privacy Policy or feedback or suggestions are welcome and should be addressed to feedback@elmcore.com.