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Last updated: November 2018

Flat World Partners Holdings Corporation, Flat World Partners LLC, Flat World Partners Funds LLC, Flat World Partners Advisors LLC, and Flat World Partners Technologies Corporation (“we”, “us” “FWP” or “our”) is committed to ensuring the privacy and security of the personal information with which you entrust us. It is our policy to protect and safeguard the personal information we obtain about our “Customers” (as that term is defined in by Regulation S-P and below). This Notice is to inform you of our policies regarding the collection, use and disclosure of your personal information and to inform “Visitors” and “Users” (as defined below) of our website, services and applications what information we track, use and share. We will never use or share your information with anyone except as described in this Privacy Policy

 

Introduction

For this Notice, a Customer is an individual who by signing our Investment Advisory Agreement or other document has enabled to provide advice.

 

Information the Firm Collects

If you choose to become a Customer the information we collect from you includes information regarding age, family, income and tax bracket, we will ask you for certain nonpublic personal identifying information (“Personal Information”) including, but not limited to, your name, address, social security number, date of birth, and employment status.

You may choose not to provide any of this above information, however you cannot become a Customer without providing it.

 

Use of Information

We store, process and maintain data related to you in order to provide client support, offer new products or services and to provide our online services to Customers in accordance with applicable laws and regulations.

 

Information the Firm Discloses

FWP does not disclose the nonpublic personal information it collects about you to anyone except:

• to the Broker who will act as Custodian for the Customer Account;

• our attorneys, accountants, and auditors; or

• as otherwise required to do so by law.

 

These parties are prohibited from using or sharing the Personal Information for any purpose other than for which it was originally provided. If you decide at some point to either terminate your Account, we will continue to adhere to this Privacy Policy, as may be amended from time-to-time.

 

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Platform.

 

Security of Information

We restrict access to customers’ Personal Information to those persons who need to know that information in order to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards. In furtherance of such safeguards, we have adopted a policy.

 

Do Not Track Disclosure

We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

Service Providers

We may employ third party companies and individuals to facilitate services.

Insofar as these third parties have access to your Personal Information, it is only to perform specific tasks on our behalf and they are obligated not to disclose or use your information for any other purpose.

 

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

 

International Transfer

Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your home jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to United States and process it   there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

Links to Other Sites

Our website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise that you review the privacy policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

Minors

Our website is not to be used by anyone under the age of 18 and, as such does not knowingly collect Personal Information from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Information to us. If you are a parent or guardian and have become aware that your child under the age of 18 has provided us with personally identifiable information without your consent, please contact us at info@aflatworld.com and we will delete such information from our files.

 

Changes to this Privacy Policy

Our policy about obtaining and disclosing information may change from time-to-time. In all such instances, we will provide you with notice of any material change to this policy before implementing the change.