Privacy

Last Updated: 12/2022

This Privacy Policy describes the processing of personal information by AlphaEdge Investment Management, Inc. ("AlphaEdge") through our websites (the "Sites"). Additional privacy notices AlphaEdge provides to you at the time of collection of your information may also contain information about our practices. For financial information-related services, our separate Financial Privacy Notice describes how we collect, use, and share information related to providing financial services.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. Any changes to this Privacy Policy will be effective as of the "Last Updated" date at the top of this page, unless otherwise expressly indicated.

We collect, use, disclose, or otherwise process your personal information for various purposes, as described when you provide such personal information or including the following:

• Provide Services. To provide you our Sites, including creating and activating your account, facilitate and manage purchases, processing payments, underwrite and rate your policies and accounts, process your transactions and claims, service your accounts, and assess user interactions and concurrent transactions, including ad impressions to unique visitors, ad quality of ad impressions.
• Research and Development. We may develop new features and to create new products or improve existing ones, including using personal information for internal purposes related to certain research. This may include when you participate in surveys or research activities.
• Advertising. We may personalize your experience with us and our Sites by conducting advertising, such as contextual, targeted, or behavioral advertising. For example, this allows us to recommend products you might like or find useful.
• Marketing Messages. We may use your personal information to communicate with you about products or services you have purchased or used; provide you with promotional messages and personalized advertising; to notify you of other products; to notify you of contests, challenges, sweepstakes, and other promotions; to notify you of services we think may be of interest to you; and, for other marketing purposes.
• Customer Service. We may use your personal information to respond to your requests for technical support, online services, product information or to any other communication you initiate, including requests, inquiries, and complaints.
• Promotions. If you enter into a promotion, such as a sweepstakes or contest, we may use your personal information to conduct the promotion, including publishing winners' lists.
• Security and Repairs. We may use personal information for security, such as to protect against unauthorized disclosure of personal information, as well as detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. We also may use personal information for debugging to identify and repair errors that impair existing intended functionality.
• Legal and Safety. We also use personal information to meet our legal obligations, work with law enforcement, and for public safety purposes. We may use personal information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our terms, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes and to protect against fraud and unauthorized transactions.

We may combine your personal information with data we obtain from our services, other users, or third parties. We reserve the right to convert, or permit others to convert, your personal information into deidentified, anonymized, or aggregated data, as permitted by law.

We, or our vendors, may collect information directly from you such as when you register for and update an online account with us, make a payment, participate in our promotions, or participate in a survey, participate in a focus group, or provide your thoughts.

We, and our vendors, may also receive personal information from a variety of sources, including from external parties such as advertising networks, service providers (including, but not limited to, Internet service providers or ISPs), operating systems and platforms, data analytics providers, government entities, social networks, data brokers, and consumer reporting agencies.

Personal information that we collect may include the following:

• Contact information. Name, email address, phone number, address, zip code.
• Unique identifiers. This may include your username (and password), IP address, and Social Security Number.
• Customer records. This may include your birth date, signature, payment information, and insurance information.
• Personal characteristics or traits. This includes demographic data such as gender.
• Commercial Information, such as information we receive from consumer reporting agencies, such as your credit scores, credit history, and creditworthiness.
• Internet/Network Information, such as browsing history, search history, usage information, information regarding a consumer's interaction with our website, application, or advertisement.

We may disclose your personal information, as described above, to:

• Affiliates and Partners. We may disclose information we collect about you with our subsidiaries, members, parent, and affiliates worldwide.
• Co-Branded Services. From time to time we may enter into an arrangement with another company that is not owned by or affiliated with us to provide additional features on the AlphaEdge Sites. These arrangements may include business partners, sponsors, and co-branded online services (referred to here as “co-branded services”). Any information, including personal information, that you provide on one of these co-branded services may be shared with these partners. By participating in activities or providing your information on these co-branded services, you consent to our providing your information to those partners. Separate privacy policies may apply to these partners' uses of your personal information.
• Service Providers and Vendors. We may disclose personal information to vendors to provide, improve, and personalize the services. For example, vendors may include insurance agents or insurance support organizations, insurance rate advisory organizations, guaranty funds or agencies, reinsurers, ratings agencies, and our attorneys, auditors, and accountants. When we disclose personal information to vendors, where necessary we enter into a contract requiring the recipient to keep that personal information confidential and only use it as necessary to perform business purposes or as otherwise permitted by applicable law. Our service providers may engage subcontractors to enable the service providers to perform services for us.
• Business Transactions. We may disclose your personal information in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, bankruptcy, or any other business transaction), including negotiations of such transactions.
• Legal and Safety Purposes. We may also disclose personal information for legal compliance, law enforcement, and public safety purposes. For example, to law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our terms, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of personal information and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of personal information.

You may be able to change your personal information through your account settings, if you have a registered account. Otherwise, you may also contact us as described below.

Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our services may provide a link or otherwise provide access to external online services. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for external online services.

If you have any questions regarding this Privacy Notice, please contact us: