Privacy Policy

Last revision January 20, 2014

INTRODUCTION

Palico SAS (“Palico”, “we” or “us”) provides this Privacy Policy (the “Privacy Policy”) to inform you of our policies and procedures regarding the collection, use, and disclosure of the information that we collect and receive from users (“Users” or “you) of our website, mobile applications and services (collectively the “Palico Network“).

This privacy policy (the “Privacy Policy”) applies to all Users. When you use or access Palico Network, you give us your consent to collect, process, use, store, and disclose, in accordance with this Privacy Policy, any information or data that identifies you as an individual, which you submit or convey through your use of Palico Network (“Personal Information”).

This Privacy Policy notifies you of our practices regarding our use of confidential Personal Information obtained through Palico Network. Unless otherwise expressly provided in any written account agreements you may have with us (“Account Agreements“), if any, that may currently be in effect, this Privacy Policy will govern.

BY USING PALICO NETWORK YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY, THE TERMS OF SERVICE AND ACCOUNT AND ALL DISCLAIMERS AND TERMS AND CONDITIONS THAT APPEAR ELSEWHERE ON PALICO NETWORK. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU AGREE THAT YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING PALICO NETWORK. ALTHOUGH YOU MAY “BOOKMARK” A PARTICULAR PORTION OF PALICO NETWORK AND THEREBY BYPASS THIS PRIVACY POLICY, YOUR USE OF PALICO NETWORK STILL BINDS YOU TO THIS PRIVACY POLICY.

All environments within Palico Network are for the exclusive use of adults, age 19 and older. We do not knowingly collect Personal Information from children under the age of 13.

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

1. UPDATES TO THIS PRIVACY POLICY

We may change or update portions of this Privacy Policy at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to the notice. We will indicate the notice’s effective date on the notice, and the revision date appearing on the first page of these policies underneath the title will identify the date of the last update or revision.

2. PERSONAL INFORMATION

Personal Information is information that identifies you specifically. The types of Personal Information we collect and share depend on the contract or service you have with us. Examples of the confidential Personal Information we may collect and maintain include: contact and financial information like your name, email and physical addresses, phone numbers, credit card numbers, Social Security number, taxpayer identification number, credit history and credit score; demographic information including age, investment objectives, investment experience, assets and income bracket; account balances and transactional history with us, our affiliates, or others; information from third party providers such as consumer reporting agencies, including but not limited to information to help prevent and detect fraud; and automated information that may be collected when you interact with Palico Network and emails, which may include but is not limited to: technical information such as your internet protocol address, your computer’s operating system and browser type, the address of a referring website, if any, and the path you take through our web pages; cookies used to recognize you as you use or return to Palico Network. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. The Help portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of Palico Network’s features; clickstream information such as the address (or URL) of the website that you came from before visiting Palico Network, which pages you visit on Palico Network, which browser you used to view Palico Network and any search terms you may have entered on Palico Network, among other things; and web beacons to allow us to know if a certain page was visited or an email was opened.

3. HOW WE USE YOUR INFORMATION

3.1 We may use your Personal Information to process and administer details of your membership, to communicate with you, to provide you with opportunities, and to keep you up to date with new developments at Palico. We may also use and analyze the information we collect so that we can administer, support, improve and develop our business, and we may contact you using information you voluntarily provide. 3.2 We do not disclose any confidential Personal Information to anyone, except as permitted or required by law, and may share your Personal Information only under the following limited circumstances: we may share Personal Information with our affiliates, service providers or suppliers (collectively, “Associates”) that help with our business operations and in connection with servicing your account, processing your transactions, or providing other services to you. We require these Associates to protect this information in a manner consistent with this policy. We may share Personal Information in special circumstances including in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may share certain Personal Information when we believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves. We may share Personal Information for our marketing purposes to offer our material and services to you. We may share Personal Information with companies or financial institutions that perform marketing services on our behalf or with other financial institutions with which we have joint marketing arrangements, subject to any legal requirements. We may transfer Personal Information in the event of a corporate sale, merger, acquisition, dissolution or similar event.

4. DATA TRANSFER

Palico Network is operated and controlled by us in the United States but may be accessed by Users in countries other than the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to, processed and stored in the United States (and/or other non-European Economic Area (“EEA”) jurisdictions). Similarly, if you are located in the United States, please be aware that information we collect may be transferred to, processed and stored outside of the United States. Please note that the level of legal protection provided in the United States or other non-EEA countries where Palico and its affiliates operate may not be as stringent as that under EEA privacy standards. By using Palico Network, or providing us with any Personal Information, you consent to the transfer, processing and storage of your information in the United States and other jurisdictions in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen, in connection with the purposes stated in this Privacy Policy.

5. INFORMATION SAFEGUARDING

5.1 Your authorized access to Palico Network is granted on a need-to-know basis and is limited to the tools available to you through Palico Network’s interface. Access to the underlying software is not authorized. You may only access the portions of Palico Network related to your User account, as available to you through your dedicated user name and password. Access to portions of Palico Network of another User with which you are not affiliated under any circumstances is strictly prohibited. You will at all times comply with all reasonable procedures and requirements established by Palico to verify the authenticity of Users, restrict each User’s access and use to their permitted level, to protect Palico Network from infection or attack by virus, worm, or other malware, or by hackers, and to otherwise maintain the security and stability of Palico Network.

5.2 Although we believe we maintain adequate physical, technical and administrative safeguards designed to guard all Personal Information, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee that only authorized persons will view your information or that information you share on Palico Network will not become publicly available.

5.3 Users may not be granted access their account information or certain investment information online until they have entered a user name and password. To place a financial transaction, a personal identification number (“PIN”) may also be required.

5.4 As a User, you are solely responsible for maintaining the secrecy of your password, PIN and other account information. You alone are responsible for the activities that occur in connection with their usage and as such should take steps to protect them from misuse. We have no duty to inquire as to the authority or propriety of any instructions given to us using your passwords or other security data and are entitled to act upon any such instructions without liability.

5.5 To maximize your level of protection, you should choose at least 8 characters, using a combination of letters, numbers and characters.

5.6 If you become aware of any unauthorized use of, loss or theft of your username, password, PIN, or other account information you will immediately inform a Palico representative.

5.7 User data transmitted via Palico Network may use a Secure Sockets Layer (SSL) protocol, and data may be encrypted on some pages of Palico Network. To the extent such technology is utilized on a given page, Users may be unable to use certain account or customization features of Palico Network unless their Web browser software supports such encryption.

6. EXTERNAL LINKS

Palico Network may contain links to other websites that are not affiliated with or maintained by us, including third party sites that display logos, trademarks, service marks, trade names, domain names, trade dress or other proprietary indicia of Palico. We do not monitor the privacy practices of these third-party sites, and we do not exercise any authority over the sites. As a result, we do not assume any responsibility for the content or data-collection policies and procedures of these sites. If you access any of these third-party sites, we cannot guarantee that your privacy will be protected in the same way it is on Palico Network. We recommend that you familiarize yourself with the privacy policy provided by that party.

7. REVIEWING, CHANGING OR DELETING YOUR INFORMATION

You are responsible for helping up maintain the accuracy and completeness of your Personal Information. You may review, update, correct or delete the Personal Information provided in your registration or account profile by contacting us at any time.

8. WARNING ABOUT FRAUDULENT E-MAILS

“Phishing” is a scam designed to steal your Personal Information. If you receive an e-mail that looks like it is from us asking you for your Personal Information and you have a doubt as to its authenticity, do not respond.

9. OTHER APPLICABLE LAWS

9.1 The practices described above are in accordance with United States federal law, including the Gramm-Leach-Bliley Act, and other laws applicable to Palico. You may have other privacy protections under applicable laws, including United States state laws. To the extent these other laws apply, we will comply with them when we share information about you.

9.2 In addition to this Privacy Policy, and in compliance with applicable laws, we have developed policies that are designed to protect Users’ Social Security numbers. Those policies prohibit unlawful disclosure of Social Security numbers and limit access to appropriate personnel, including third party service providers, who provide products, services, or information to investors.

California Residents. California Civil Code sections 1798.83-1798.84 give California residents the right to ask us for a notice describing the categories of Personal Information we share with third parties or affiliates for their direct marketing purposes. The notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it has been shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please contact us.

10. CONTACT US

If you have questions about our Privacy Policy or want to change your marketing preferences or update your Personal Information, please contact us.