THIS DOCUMENT SETS FORTH THE PRIVACY POLICY FOR THE SPG TREND ADVISORS, LLC (“SPG”) WEBSITE WWW.SPGTREND.COM (“SITE”). SPG VALUES THE PROTECTION OF INDIVIDUAL PRIVACY AND IS COMMITTED TO THE PRIVACY OF ITS VISITORS. THIS PRIVACY POLICY SETS FORTH SPG’S PRIVACY POLICY FOR THE SITE, AND GOVERNS THE MANNER IN WHICH SPG COLLECTS, USES, MAINTAINS AND DISCLOSES INFORMATION COLLECTED FROM USERS OF THE SITE. BY USING THE SITE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE SITE IN ANY MANNER. THIS PRIVACY POLICY DOES NOT GOVERN PRIVACY PRACTICES ASSOCIATED WITH OFFLINE ACTIVITIES OR ACTIVITIES OCCURRING ON WEBSITES NOT UNDER SPG’S CONTROL.

The Information SPG Collects and How SPG Uses That Information

Personal Information. During your interactions with the Site, you may be prompted to provide information identifying who you are, or information that is otherwise personally identifiable information or nonpublic personal information (collectively, “Personal Information”), such as when you register with the Site. SPG collects Personal Information in order to, among other things, provide you with the information and/or services that you have requested through the Site. SPG retains such Personal Information for as long as is necessary depending on the reason for your submission of such Personal Information.

Anonymous Information. SPG may also collect aggregate, anonymous, statistical data, such as usage, traffic patterns and user demographics based on your use of the Site and/or your Personal Information (“Anonymous Information”). Examples of Anonymous Information may include your Internet access provider, your computer’s Internet protocol (IP) address, your browser and operating system, the date and time of your visit, the pages you visit, and, if you linked to the Site from another site, the address of that other site. the SPG collects Anonymous Information in order to, among other things, provide you with or assist in the provision of information through the Site, to maintain the performance of the Site, and to make the Site more useful.

Personal Information Disclosure. SPG does not sell or otherwise disclose any Personal Information to any third parties other than: (i) as required by law; (ii) in the event of a sale, merger, public offering, bankruptcy or other change in control of SPG and/or the Site; or (iii) with your affirmative consent at the time you provide such information. While collecting Personal Information, SPG may ask whether you would like to “opt in” and allow disclosure of your Personal Information by SPG to certain specifically identified third party partners of SPG (collectively, “Partners”). In the event you opt in and allow such disclosure, your Personal Information will only be disclosed to the previously identified Partner(s).

Opting In Through Other Venues. Please be advised that if you “opt in” and allow SPG to disclose your Personal Information through one SPG venue (such as the Site), you will be deemed to have “opted in” through all SPG venues.

Disclosure to Agents of SPG. From time to time, SPG may share the information you provide to SPG, including Personal Information, with outside contractors, auditors, consultants, or others hired by SPG to assist in carrying out financial or operational activities on SPG’s behalf. SPG informs these parties about safeguarding Personal Information, and requires them to use such Personal Information only for an authorized purpose on behalf of SPG and consistent with this Privacy Policy.

Electronically Produced Data.

Cookies. SPG, like most standard website servers, may use cookies and other tools to collect information about how you use the Site (“Cookie Information”). A cookie is a small, unique text file that a website can send to your computer hard drive when you visit a site. SPG uses both “session cookies”, which terminate when a user closes his or her browser, and “persistent cookies”, which remain on the user's computer until manually deleted. Most web browsers can either alert you to the use of cookies or refuse to accept cookies entirely. If you do not want SPG to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie on your computer. Rejecting cookies may affect your ability to use the Site.

Action Tags. Like most standard website servers, SPG may employ a software technology called action tags (also known as “web beacons”, “single pixel gifs”, “clear gifs” or “web bugs”), which collect information and help to manage cookies, in order to gather information about Site usage. Action tags help SPG identify and track the performance of web pages on the Site, therefore allowing SPG to measure the performance and quality of the Site and to manage Site content. In addition, SPG may use action tags in emails. This allows SPG to gauge the effectiveness of certain communications by showing, for example, how many emails have been opened.

IP Addresses. An IP (Internet Protocol) address is a number that is assigned to your computer when you use the Internet. Like most standard website servers, SPG collects IP addresses and other technical information about your machine through your web browser such as your operating system, browser type and referring URL for the purposes of, among other things, system administration and to ensure the validity of user requests.

Log Files. Like most standard website servers, SPG gathers certain information automatically and store it in log files, which contain information such as, among other things, IP addresses, browser type, operating system, ISP, date/time stamps and referring pages. Among other things, this information allows SPG to track statistics and trends on an aggregate basis.

Maintenance of Information and Security

SPG maintains physical, electronic and procedural safeguards to protect the confidentiality and security of your Personal Information, including without limitation any credit card information you disclose to SPG. SPG utilizes what SPG believes to be industry standard security measures to protect the loss, misuse and alteration of Personal Information under SPG’s control, and SPG limits access to your Personal Information within SPG to those employees who need to know the Personal Information to provide information, services and/or products to you. However, due to the nature of the Internet, computer networks, systems and other factors, no transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of SPG to intercept or access transmissions or private communications unlawfully, regardless of SPG’s best intentions. As such, SPG cannot ensure or warrant the security of any information you transmit to SPG, including without limitation Personal Information.

Privacy of Children

Use of the Site is for adults 18 years of age or older. Anyone under the age of 18 is prohibited from using the Site, and must not send any personal information to us, including without limitation information such as such child’s name, address, or e-mail address. We do not knowingly collect personally identifiable information from children under 18. In the event that we learn we have collected any personal information from a child under the age of 13 without verification of parental consent, we will delete that information from our database as quickly as possible.

Other Information

Consent to Receive Notices Via the Site. By submitting any Personal Information to the Site, you are agreeing that SPG may deliver all privacy and opt out notices to you electronically, including via email to the most recent email address you have provided to SPG, or via posting on the Site.

Links. The Site may contain links to third party sites at which your Personal Information is collected and used. Your visit to any third party website is governed by the privacy and other policies applicable to that site. SPG cannot control nor is it responsible for any such third party collection or use of your Personal Information or the content or policies of such sites, and SPG expressly disclaims any liability related to such sites.

Web Logs and Other Forums. The Site may offer web logs, web postings, bulletin boards, chat rooms, newsgroups or other forums which permit users to interact online. Any information you transmit online in such forums will be made public and SPG cannot control nor is it responsible for the use any third party may make of such information.

Privacy Policy Changes. SPG reserves the right to change this Privacy Policy at any time at its sole discretion. All Privacy Policy changes will be posted on the Site. Consequently, you are advised to visit and review this Privacy Policy frequently. The last date on which this Privacy Policy has been updated is noted below.

Limitation of Liability. YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND SPG’S TERMS OF USE (INCLUDING ANY LIMITATIONS ON DAMAGES CONTAINED THEREIN) TERMS OF USE

SPG Contact Information. If you have any questions or comments regarding this Privacy Policy, please email SPG at info@SPGTrend.com

PLEASE RETAIN A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS.