EAGLE WEBSITE PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY (THIS “PRIVACY POLICY”) CAREFULLY BEFORE USING THIS SITE.

Eagle Trading Systems Inc. (“Eagle”) is committed to protecting the privacy of all individuals who utilize the www.eaglets.com (the “Site”) and any elements thereof or related thereto. The term “Eagle” used on the Site refers to the activities of Eagle Trading Systems Inc. and its affiliated entities. Eagle Investment Solutions is an alternate name for Eagle Trading Systems Inc.

WHEN YOU VISIT THE SITE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY AND EAGLE’S USER AGREEMENT (THE “AGREEMENT”), AND YOU ACKNOWLEDGE, UNDERSTAND AND ACCEPT EAGLE’S INVESTMENT RESEARCH AND OTHER INFORMATION DISCLOSURES (THE “DISCLOSURES”). BY USING THE SITE, YOU ARE AGREEING TO OUR COLLECTION AND USE OF SUCH INFORMATION CONSISTENT WITH THIS PRIVACY POLICY, AND TO BE BOUND BY THIS PRIVACY POLICY, THE AGREEMENT AND THE DISCLOSURES. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, THE AGREEMENT OR THE DISCLOSURES, YOU MAY NOT USE THE SITE.

EAGLE MAY MAKE CHANGES OR IMPROVEMENTS TO THE SITE AND/OR TO THIS PRIVACY POLICY AT ANY TIME. ANY MODIFICATIONS MADE WILL BE EFFECTIVE IMMEDIATELY UPON THE POSTING OF THE MODIFIED PRIVACY POLICY ON THE SITE. BY CONTINUING TO USE THE SITE AFTER ANY CHANGES OR IMPROVEMENTS ARE MADE, YOU ARE ACCEPTING AND AGREEING TO THE CHANGES AND IMPROVEMENTS. YOU AGREE TO REVIEW THE POSTED PRIVACY POLICY EACH TIME YOU ACCESS OR USE THE SITE SO THAT YOU ARE AWARE OF ANY MODIFICATIONS MADE TO THIS PRIVACY POLICY.

  1. User Agreement and Investment Disclosures

    The Agreement governs your access to and use of the Site. The Disclosures provide important disclosures and information about the investment performance and investment research information made available through the Site. By using the Site, you (a) are agreeing to be bound by the terms of this Privacy Policy and the Agreement; and (b) acknowledge, understand and accept the Disclosures.

  2. Data Use

    Eagle may use information collected from you and/or your computer or device in an effort to, among other things: improve your experience on the Site and/or communicate with you about Eagle and/or its services.

  3. Collection of Information

    Eagle may collect nonpublic personal information that may include a user’s name, address, social security number, nationality, employment information, birth date, bank account numbers and financial and investment information and qualifications. Eagle may collect nonpublic personal information about clients and investors from transactions or interactions with users, clients and investors.

  4. Disclosure of Nonpublic Personal Information

    Eagle does not disclose any nonpublic personal information it collects (as described above) to any nonaffiliated third parties or affiliated parties, except as permitted or required by law or upon consent. For example, under such guidelines, Eagle may share nonpublic personal information with nonaffiliated third parties or affiliated parties in the following situations among others:

    • To comply with federal, state or local laws, rules and other applicable legal requirements;

    • To protect against or prevent actual or potential fraud, unauthorized transactions (such as money laundering), claims or other liabilities;

    • To service providers in connection with the administration and operations of an account or a fund, which may include attorneys, accountants, auditors, administrators, or other professionals;

    • To effect, administer or enforce transactions requested or authorized; and

    • Upon the consent to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity.

  5. Confidentiality and Security

    Eagle considers the protection of nonpublic personal information to be a sound business practice and a foundation of trust. Eagle will restrict access to nonpublic personal information to employees who need to know that information in the course of their job responsibilities. Eagle will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal. Third parties with whom Eagle shares nonpublic personal information must agree to follow appropriate standards of security and confidentiality.

    Eagle also maintains and implements a written information security program to protect nonpublic personal information. The program identifies risks to the confidentiality and security of records containing personal information, and has procedures for assessing the likelihood and potential damage of such threats. Technical, physical and administrative safeguards are in place for the protection of nonpublic personal information, and are regularly monitored for effectiveness.

    ALTHOUGH EAGLE WILL USE VARIOUS TECHNOLOGIES AND TOOLS TO PROTECT YOUR NONPUBLIC PERSONAL INFORMATION AGAINST LOSS, DESTRUCTION, DISCLOSURE OR ACCESS, NO METHOD OF SECURING DATA IS FOOLPROOF OR COMPLETELY EFFECTIVE, AND THIRD PARTIES MAY UNLAWFULLY ACCESS OR INTERCEPT DATA TRANSMISSIONS, COMMUNICATIONS OR STORED DATA, AND MAY UNLAWFULLY USE THE DATA. THUS, ALTHOUGH EAGLE TAKES REASONABLE MEASURES TO PROTECT YOUR NONPUBLIC PERSONAL INFORMATION, EAGLE DOES NOT AND CANNOT GUARANTEE THAT YOUR NONPUBLIC PERSONAL INFORMATION WILL REMAIN PRIVATE OR SECURE.

  6. Use of Third Parties

    Eagle may contract with unaffiliated third parties to: assist Eagle in providing its services to you; assist in maintaining and managing customer information; and/or communicate with you. These companies are contractually restricted from using nonpublic personal information other than in connection with the foregoing, though they may use such information in an aggregated, de-identified form or in manners that you otherwise authorize. Eagle does not authorize any unaffiliated third party to make any use of nonpublic personal information other than as noted in this Privacy Policy.

  7. Third Party Sites

    If you reach the Site using a link or from another web site or search engine, or go to another site from the Site, information about your visit to the Site may be collected by the other website or search engine, and will be subject to the privacy policy of that site. You are encouraged to review the privacy policy of each of those sites or search engines.

    IN NO EVENT WILL EAGLE BE LIABLE, DIRECTLY OR INDIRECTLY, TO ANYONE FOR ANY DAMAGE OR LOSS ARISING FROM OR RELATING TO ANY USE, CONTINUED USE, OR RELIANCE ON ANY LINKED THIRD PARTY SITE, OR ANY LINK CONTAINED IN A LINKED SITE.

  8. Your California Privacy Rights

    Under California law, if you are a resident of California, you may make a written request to Eagle about how Eagle has shared your nonpublic personal information with select third parties for their direct marketing purposes. In response to your written request, Eagle will identify the categories of information shared, if any, and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. Please submit a written request to [email protected].

  9. Cookies and Persistent User Identifications

    Eagle may use “cookies” and/or other persistent identification methods (collectively, “Persistent IDs”) to enhance your experience with the Site and to improve the structure, content and offerings on the Site. “Cookies” are pieces of information that the Site sends to your browser while you are visiting and using the Site to store your preferences; other Persistent IDs use different technologies and methodologies. You can change your privacy preferences regarding the use of cookies and other technologies through your browser, including blocking all cookies and disabling other Persistent IDs; however blocking all cookies may affect your use of certain features of the Site and other websites and services online, and may prevent you from using all the features of the Site and other websites and services. At this time the Site does not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.

  10. U.S. Jurisdiction

    You should be aware that the United States and other countries have not harmonized their privacy regulations. This Privacy Policy satisfies United States regulations. If you are accessing the Site outside of the United States, you agree to the level of privacy protection set forth in this Privacy Policy.

  11. Contact Us

    If you have any questions about this Privacy Policy or the Site, please contact us at: [email protected].

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