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Privacy Policy

Last modified November 17, 2017.

Introduction

Welcome to skbcos.com (the “SKB website”), a website operated by ScanlanKemperBard Companies, LLC (“SKB Companies”) and SKB Securities, LLC (“SKB Securities”), a registered broker-dealer and member FINRA/SIPC, and a wholly-owned subsidiary of SKB Companies (collectively, the “SKB Entities”). The SKB Entities have created this privacy statement in order to demonstrate our commitment to the privacy of the users of the SKB website. This Privacy Policy discloses our information gathering and dissemination practices for the SKB website.

By visiting the SKB website, you are accepting the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the SKB website. Use of the SKB website is also governed by our Terms of Use and Terms of Service.

Collection and Use of Information

Personally identifiable information. You will not be asked for any personally identifiable information unless you choose to register; in which case the information you provide will be collected. In addition, if you fill out an investor questionnaire and agreement additional information will be collected.

The personally identifiable information we collect may include, but is not limited to: name; address; telephone numbers; email address; social security number; date of birth; driver’s license number; occupation; place of employment; income and assets; bank account and routing numbers; financial information necessary to process investor questionnaires, determine accredited investor status, and facilitate the offering of investment products; and information relating to investor transactions. Such information may be used in a number of ways, including, but not limited to: allowing you access to password-protected pages; processing investor questionnaires; verifying your identity; protect against fraud; communicating with you; transmitting documents and other information to you regarding products and services offered through the SKB website; facilitating funds transfers and disbursements; following your instructions as authorized; other everyday business purposes of SKB; and complying with and enforcing applicable laws, industry standards, rules, and regulations.

ANY PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT WILL ONLY BE USED IN ACCORDANCE WITH THIS PRIVACY POLICY. IT WILL NOT BE SOLD OR RENTED TO THIRD PARTIES TO ADVERTISE OR MARKET TO YOU, IT WILL NOT BE USED BY ANY OF OUR AFFILIATES TO MARKET TO YOU, AND WE WILL NOT USE IT TO MARKET PRODUCTS OR SERVICES TO YOU OTHER THAN THOSE IN WHICH YOU HAVE EXPRESSED AN INTEREST. However, such information may be shared with: affiliates of the SKB Entities in connection with any investments offered through the SKB website, including but not limited to the SKB Entities; and/or any other party or parties sponsoring or issuing any investments (“Sponsor”) in which you express interest or purchase. By expressing an interest in a particular investment you are authorizing us to share personally identifiable information with the Sponsor in accordance with this Privacy Policy. You may revoke such authorization by contacting us, but such revocation may preclude you from receiving further information regarding an investment or completing a purchase.

The information may also be disclosed to the extent required by legal proceedings, such as responding to a subpoena when required by law, rule, or regulation. We may also disclose the information to thirty party service providers that assist us in providing services to you; however, in such cases such third party providers will be bound by this Privacy Policy. In the event that all or some of the business or assets of any of the SKB Entities is acquired by or merged with another entity, we also may disclose your information to such entity in order that the new entity can continue to serve you. You will be notified if such an event occurs and the new entity will inform you of its own privacy policies.

We may obtain personally identifiable information about you from third parties such as credit reporting agencies, and if such information is combined with personally identifiable information you provide directly to us, the combined information will be treated in accordance with this Privacy Policy.

In the event that you terminate your relationship with us, we may retain certain personally identifiable information about you to the extent required by law, rule, regulation, or industry standard. Such information will be treated in accordance with this Privacy Policy so long as we retain it.

Server log information. We routinely collect certain information if you view on the SKB website and/or download information, which information may include: the name of the domain from which you accessed our Website; your Internet Service Provider (ISP) and your Internet Protocol (IP) address; the date and time you accessed the SKB website and the pages that you visited; the type of browser and operating system used to access the SKB website; and the address of any other site you access immediately before or after accessing the SKB website. This information is used solely for the purpose of evaluating and maintaining the SKB website.

Cookies. Cookies are small text files that are stored in your computer’s memory when you visit our Website. They enable our SKB website to function and to provide information to us, and are used for the following purposes: to track your personal session and your activity on our Website, to record when forms have been completed or a user has consented to the terms and conditions of SKB website policies such as this one, for authentication purposes. Your web browser may allow you to block or reduce the use of cookies, although doing so may prevent our SKB website from functioning properly.

Clear GIFs. We may use clear GIFs (also referred to as web beacons) to track the online movements of visitors to the SKB website. Clear GIFs are small, transparent graphic images (about the size of the period at the end of this sentence) with a unique identifier. Any information collected by clear GIFs is not tied to visitors’ personally identifiable information.

Service Providers. We may use in-house or third-party service providers to operate our SKB website and use others to perform work on our behalf, such as analyzing SKB website traffic, sending communications via mail or email, process or enforce transactions you have authorized, receive or disburse funds, develop or maintain software, verify information and comply with certain federal and state regulatory requirements. These providers and others may have access to personally identifiable information you have submitted to us through our Website, but only to perform the services they have been authorized to perform, they are required to keep the information confidential, and they are not permitted to use the information for any other purpose and comply with the terms of this Privacy Policy.

Third Party Websites

We may establish links from our SKB website to other, external websites operated by third parties. The SKB Entities have no control over, and are not responsible for, the content or privacy policies of such other websites.

Children

Our online services are not intended for children under the age of 18, but we are concerned about the privacy of children using the Internet. Therefore, we do not knowingly solicit personally identifiable information from anyone under the age of 18 without parental consent.

Security

Our SKB website has security measures in effect, including data encryption, to protect the information under our control. Also, only authorized employees, agents, and contractors (who have agreed to keep information secure and confidential) have access to that information. All such employees, agent and contractor will be bound by this Privacy Policy. However, no data transmission over the Internet can be 100% secure, and so the SKB Entities cannot guarantee or warrant the security of any information you submit to us through the SKB website. If you have created a password to access certain pages of the SKB website, you are responsible for keeping your password confidential and for not sharing it with any other person or permitting anyone to access the SKB website through the use of such password.

Changes to Privacy Policy

The SKB entities reserve the right to modify or update this Privacy Policy at anytime. Any modifications or updates will be posted on this page and will be effective upon posting. By continuing to use the SKB website after we have posted any such modifications or updates, you are agreeing to the terms and conditions of this Privacy Policy as modified or updated.

Contact Us

If you have any questions about this Privacy Policy, please contact us.

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