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Privacy Policy

Last Revision: March 20, 2020

The iCovest Group Group, Unincorporated Association (“iCovest,” “,” “iCovest Market,” “we,” “us,” and “our”) and its affiliates are committed to protecting the confidentiality and security of information we collect about our existing and prospective iCovest Market PCM and SBM Members (collectively “iCovest Members”).  We will not share non-public information about you (“Information”) with third parties outside of iCovest without your consent, except for the specific purposes described below.  This notice describes the Information we may gather and the circumstances under which we may share it.

Why We Collect and How We Use Information

We limit the collection and use of Information to the minimum we require to deliver superior service to you but also for your protection.  Such service includes processing various requests by you, assessing qualifications and capabilities, inventory and due diligence analysis, providing advice to you and administering our services.

How We Gather Information

We get most Information directly from you, when you apply for, access and use products, services and/or research offered through the iCovest Market – whether in person, by telephone or electronically.  We may verify this information or get additional information from both private and/or public sources.  This Information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions with iCovest Members, or others.

How We Protect Information

iCovest, iCovest Members and iCovest affiliates alike are required to protect the confidentiality of Information and to comply with our established policies.  They may access Information only when there is an appropriate reason to do so, such as to administer various services and/or distribute resources.  We also maintain physical, electronic and procedural safeguards to protect Information.  Those that violate this Privacy Policy are subject to disciplinary process and/or termination according to the iCovest Participation Agreement.

Disclosure of Information

We do not disclose any nonpublic information about our iCovest Members or former iCovest Members to anyone unaffiliated with iCovest without cause.  We may disclose any Information to or as directed by a iCovest Member or when we believe it necessary for the conduct of our iCovest affairs, or where disclosure is required or permitted by law.  Information may be disclosed for audit or research purposes, or to law enforcement and regulatory agencies, for example, to help us prevent fraud.  In addition, we may disclose Information to affiliated and non-affiliated third party service providers (i) to enable them to provide business services for us, such as performing computer-related or data maintenance or processing services, (ii) to facilitate the processing of transactions requested by you, (iii), to assist us in offering products and services to you or to assist our iCovest Members in offering products and services to you, or (iv) for review and reporting purposes.  Except in those specific, limited situations, without your consent, we will not make any disclosures of Information to any unaffiliated companies who may want to sell their products or services to you.  For example, we do not sell client lists and we will not sell your name to a catalogue company.  It is iCovest policy to require that all third parties, including our iCovest Members who are to receive any Information, acknowledge this Privacy Policy and related written policies and supervisory procedures of our iCovest protocol more particularly described in the iCovest Participation Agreement.

Important Note: iCovest has one agreement and several voluntary options for all prospective iCovest Members without partiality (i.e. house rules): they are non-negotiable and available for review upon receiving iCovest Member status.  As such, as we do not ordinarily acknowledge third party confidentiality agreements and similar documents, lest we find ourselves a “respecter of persons.”

Former Relationships

Even if you are no longer affiliated with iCovest, this Privacy Policy will continue to apply to you according to your iCovest Participation Agreement.

To Whom This Policy Applies

This Privacy Policy applies to iCovest Members exchanging products or services through the iCovest Market.

Access to and Correction of Information

If you desire to review any file we may maintain of your personal Information, please contact us.  If you notify us with any Information that is incorrect, we will review it.  If we agree, we will correct our records.  If we do not agree, you may submit a short statement of dispute, which we will include in future disclosures of the disputed Information.  Information collected in connection with, or in anticipation of, any conflict resolution proceeding will not be made available.

Further Information

We reserve the right to change this Privacy Policy.  The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive.  This Privacy Policy does NOT comply with enacted state, federal, or international law and/or respective securities regulations regarding privacy (e.g. iCovest will not disclose your personal Information to any government, or agency thereof, just because they ask for it).  You may have additional rights under other foreign or domestic laws that may apply to you.

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