THINKalpha Privacy Policy

The following describes the privacy considerations enacted by THINKalpha (“the Firm”) relating to the use of website visitors’ personal information.

Gathering of Personally-Identifying Information
Certain visitors to the THINKalpha website choose to interact with the Firm in ways that require the Firm to gather personally-identifying information. The amount and type of information that THINKalpha gathers depends on the nature of the interaction. THINKalpha collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor's interaction with the Firm. THINKalpha does not disclose personally-identifying information other than as described below. Visitors can always refuse to supply personally-identifying information, though doing so may prevent them from engaging in certain website-related activities.

Cookies and LocalStorage
Cookies and LocalStorage are strings of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. THINKalpha uses Cookies and Local Storage to help the Firm identify and track visitors, their usage of the Firm’s website, and their website access preferences. THINKalpha visitors who do not wish to have Cookies and LocalStorgae placed on their computers should set their browsers to refuse Cookies and LocalStorage before using the Firm’s website, with the drawback that certain features of the Firm's website may not function properly without the aid of Cookies and LocalStorage. Notice to California Residents - California law requires that THINKalpha obtain your affirmative consent before it shares your nonpublic personal information with non-affiliated third-party companies. It should be noted that THINKalpha does not currently share information about you with any non-affiliated third party that triggers this consent requirement. Accordingly, there is no need at this time for THINKalpha to seek your consent or for you to take any affirmative action telling THINKalpha not to share such information with non-affiliated third parties. California residents will receive an additional notice describing the privacy choices available under California law. Please mark the California Privacy Notice to indicate your preference with regard to sharing of your information.

Protection of Certain Personally-Identifying Information
THINKalpha discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process it on THINKalpha's behalf or to provide services available at THINKalpha’s website, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using THINKalpha's website, you consent to the transfer of such information to the Firm and its employees, contractors, and affiliated organizations. Other than to its employees, contractors and affiliated organizations, as described above, the Firm discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when the Firm believes in good faith that disclosure is reasonably necessary to protect the property or rights of the Firm, third parties or the public at large. THINKalpha takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally identifying and personally-identifying information.

Privacy Policy Changes
THINKalpha reserves the right to make changes to this Privacy Policy at any time in its sole discretion. When THINKalpha does, the Firm will let you know by appropriate means such as by posting or emailing the revised policy with a new “Last Updated” date. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise. THINKalpha encourages visitors to frequently check for any changes to its Privacy Policy.

Cyber Security Notice
THINKalpha collects and maintains certain investor personal information in its electronic databases in order to facilitate the processing of transactions on behalf of investors and to comply with applicable rules, regulations, and laws. The Firm may share this information with third party affiliates that require the information in order to perform their contractual obligations to THINKalpha (such as our client verification vendors). The investor personal information stored by the Firm is protected from unauthorized access, treated as confidential, and handled according to the terms of the Firm’s privacy policy.

The Firm has adopted procedures to protect investor personal information, including the following:
- The Firm has adopted written policies and procedures that are reasonably designed to protect investor personal information.
- Employees are trained on the requirements to protect investor personal information.
- Computerized investor personal information is accessed by password protection or other established controls within the Firm's system to ensure access is limited to active employees, vendors and affiliates on a “need to do basis”.
- The Firm’s website is protected by firewalls, a secure server, and anti-virus programs.
- Investor personal information is generally not stored on laptop computers or other portable devices. Laptops and other authorized remote devices must include security application software.
- Requests for investor information from outside parties such as regulators, the IRS, and other government or civil agencies, are referred to Compliance for review and response.
- The integrity of the Firm's internal computer systems, including privacy protection, is subject to regular review.
-If required by state law, states will be notified if investor information is stolen making it subject to potential identity theft.

Should a breach occur, management will promptly take action to secure information, mitigate the breach, and notify, on a timely basis, any investors whose personally identifiable information could have been compromised.
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