PRIVACY POLICY

This privacy notice is provided to prospective purchasers as a result of the privacy notice and disclosure regulations promulgated under certain U.S. federal laws and explains the manner in which the Token Issuer collects, utilizes and maintains nonpublic personal information about each purchaser of Tokens.  This notice applies only to investors who are individuals or to certain entities that are essentially “alter egos” of individuals (e.g., grantor trusts, IRAs, and similar individual self-directed estate planning or investment vehicles).

The Token Issuer receives or may receive personal information (such as a purchaser’s name, address, social security number or similar identifying information, and the amount of its investment in Tokens) from the Subscription Agreement, responses to the purchaser questionnaire set forth on the Token Issuer’s website and the records of the Token Issuer.  In servicing a Token holder’s account, the Token Issuer provides personal information to their respective affiliates (including those who are involved in the operation, service, administration or management of the Token Issuer or in the sale of Tokens) and unaffiliated service providers, only as permitted by law. For example, the Token Issuer may share such information in connection with the administration and operations of the Token Issuer (including disclosure to attorneys, accountants, service providers, auditors or administrators and the Token Issuer).  The Token Issuer does not provide information on holders (or former holders) of Tokens (including names, addresses, or investor lists) to outside companies except in furtherance of its business relationship with a holder, or as otherwise permitted by law.

Within the Token Issuer, and among their respective affiliates, access to nonpublic personal information of the holders of Tokens is restricted to employees and personnel who need to access that information to provide products or services to investors.  To guard Token holders’ nonpublic personal information, physical, electronic, and procedural safeguards are in place that comply with U.S. federal standards.

The Token Issuer reserves the right to change this notice, and to apply changes to information previously collected, as permitted by law. Token holders will be informed of any changes as required by law.