PRIVACY POLICY

AUTHORIZATION OF USE

Thank you for visiting the Return On Intelligence Web site. By using this Web site, you agree to abide by the following terms and conditions. If you do not accept these conditions, do not use this Web site. Return On Intelligence may change this Privacy Policy and User Agreement (Agreement) from time to time, based upon any changes to our Web site and our users’ experience with it. If we make any substantial changes in this Agreement, we will post a prominent announcement on our home page.

PRIVACY POLICY

Return On Intelligence respects the privacy of visitors to this Web site. This policy describes how and when we gather information from visitors to our Web site.

AGGREGATE DATA

We generally record certain usage information, such as the number and frequency of visitors to this Web site. This information may include the Web sites that you access immediately before and after your visit to our site, the Internet browser you are using, and your IP address. If we use such data at all, it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally. We do not employ cookies.

PERSONALLY IDENTIFIABLE INFORMATION

If you voluntarily submit information to our Web site, for example, in a request for general information or through the submission of a business proposal, we may record and use any personally identifiable information, such as your name, phone number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request. We will not use your personally identifiable information for any other purpose without your permission.

We may use internal or external service providers to operate our Web site and employ other persons to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to the personally identifiable information you submit through the Web site, but only for the purpose of performing their duties. These persons may not use your personally identifiable information for any other purpose.

We will not provide any personally identifiable information to any other persons, except if we are required to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding. We can (and you authorize us to) disclose any such information in those circumstances.

USER AGREEMENT

Restrictions on Use

Any person using this Web site is permitted to copy and print individual Web site pages for non-commercial purposes. Users may also copy or print minimal copies of any research or reports posted on the site solely for informational, non-commercial use. These copies must not alter the original Web site content, including all legal notices and legends. Our prior permission is required for (i) any commercial use of materials on this Web site; (ii) making more than minimal copies of Web site materials; and (iii) copying large portions of our Web site, such as by bots, robots or spyders that “harvest” the Web site.

Linking and Framing

We do not permit others to link to or frame this Web site or any portion thereof. Please note that this Privacy Policy and User Agreement applies only to this Web site and not to other Web sites that may be accessible from this Web site via hyperlink. We are responsible only for the content of our own Web site. We encourage you to review the privacy policies and user agreements of all other Web sites that you visit.

Ownership

All content included on this Web site, such as graphics, logos, articles and other materials, is the property of our organization or others and is protected by copyright and other laws. All trademarks and logos displayed on this Web site are the property of their respective owners, who may or may not be affiliated with our organization.

Submissions

As our Web site indicates, we welcome your questions about us and our financial products and services. Please be advised that any comments, suggestions, ideas or other information that you send to us through our Web site will not be treated as confidential, and that we will own and have the right to use them as we choose, without payment to you.

International Use

Due to the global nature of the Internet, this Web site may be accessed by users in countries other than the United States. We make no warranties that materials on this Web site are appropriate or available for use in such locations. If it is illegal or prohibited in your country of origin to access or use this Web site, then you should not do so. Those who choose to access this site outside the United States do so on their own initiative and are responsible for compliance with all local laws and regulations.

Limitations of Liability

We are not responsible for any damages or injury, including but not limited to special or consequential damages, that result from your use of (or inability to use) this Web site, including any damages or injury caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, line failure, or other computer malfunction. You acknowledge that we provide the contents of this Web site on an “as is” basis with no warranties of any kind. Your use of this Web site and use or reliance upon any of the materials on it is solely at your own risk.

Governing Law

You agree that your use of this Web site, this Privacy Policy and User Agreement and any disputes relating to any of them shall be governed in all respects by the laws of the State of California. Any dispute relating to the above shall be resolved solely in the state or federal courts located in San Francisco, California.