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Privacy Practices

AlphaSimplex Group, LLC Web Privacy Statement

AlphaSimplex Group, LLC (“AlphaSimplex”), its officers, and employees are strongly committed to protecting the online privacy of all clients and/or visitors. In accordance with the Privacy Act of 1974, the Gramm-Leach-Bliley Act, and the subsequent Securities and Exchange Commission's Privacy of Consumer Financial Information Regulations (Regulation S-P) and Regulation S-AM requirements, this website uses standard encryption and password-protected protocols.

In the ordinary course of doing business, and in order to provide customized services and products, it may be necessary for AlphaSimplex to procure certain personal and non-personal information from clients and/or visitors to this website. In addition, AlphaSimplex may also periodically request other personal and non-personal data in order to initiate and maintain accounts and relationships and to provide for supplemental products or services specifically tailored to meet its clients' and/or visitors' ongoing needs.

AlphaSimplex is committed to ensuring the security of all personal information and as an integral part of its compliance program, AlphaSimplex has designed its privacy control policies and procedures to seek to prevent (to the extent possible) unauthorized disclosure and/or use of all such information. In certain circumstances, AlphaSimplex makes use of cookies or other web-originated electronic forms of information tracking to procure personal and non-personal information. Cookies are small amounts of data that a website sends to a web browser on a visitor’s computer. Our cookies help us to collect information about visitors to the AlphaSimplex website, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Cookies also may be used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on the AlphaSimplex website, or if you delete cookies, you may experience some inconvenience in your use of the AlphaSimplex website. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.

We may also use third-party service providers to help us collect information about your activity on the AlphaSimplex website using cookies and other technologies to analyze, for example, pages visited on the AlphaSimplex website, search engine referrals, browsing patterns within the AlphaSimplex website, and responses to advertisements on the AlphaSimplex website. Such service providers may only collect and use such information for purposes specified by AlphaSimplex and not for their own purposes.

When you access our website, we or our service providers may automatically or by registration collect non-personal data (e.g., type of internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, and pages viewed). We may use this data and share it with our affiliates to monitor the attractiveness of our website and improve its performance or content.

AlphaSimplex will, to the best of its abilities, limit the sharing of any accumulated personal data to select business affiliates, partners, vendors, and other parties authorized to act on its behalf and on behalf of its clients and/or visitors, subject to AlphaSimplex’s general privacy policy. All such groups and individuals will, of course, generally be bound by similar confidentiality agreements prior to AlphaSimplex releasing any information.

In addition, there are currently several states that require clients and visitors to provide "opt-in" permission for AlphaSimplex to share any information. To the extent that AlphaSimplex is made fully aware of the residency of such individuals, it will do its utmost to share any personal information with no other parties without consent. Currently, several states require firms to provide "opt-in" releases. Individuals should, therefore, provide AlphaSimplex with a state of residence along with any initial contact information. AlphaSimplex may not be held responsible in instances where the individual does not provide sufficient state of residency information.

Everyone must realize however, that restricting AlphaSimplex’s ability to share information with certain parties may negatively impact its ability to perform its duties on behalf of those clients.

Occasions may arise wherein the AlphaSimplex website may include links to unaffiliated third-party websites. These transfers are provided solely as a convenience to clients and/or visitors and should not be construed as part of the AlphaSimplex organization and AlphaSimplex cannot guarantee or be held responsible for any personal or non-personal information transported by the client through any such links. Although AlphaSimplex makes every attempt to limit linking to reputable sites, AlphaSimplex does not review or control other sites and makes no representation that those sites are competent, experienced, or compliant with current industry and government regulations. You should be aware that linked sites (either to or from this website) or outside sites on which we advertise may contain privacy or confidentiality provisions that differ from the provisions provided herein.

AlphaSimplex may provide experiences on mobile applications or social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

The AlphaSimplex website is not directed to individuals under the age of thirteen (13). AlphaSimplex does not intentionally collect information on the AlphaSimplex website from those we actually know are under 13, and we request that these individuals do not provide personal information through the sites.

AlphaSimplex reserves the right to change this statement at any time by posting revisions on the official AlphaSimplex website. Although AlphaSimplex will make every attempt to prevent the unauthorized use of client and/or visitor information, it can make no guarantees. This privacy policy is not intended to, and does not create any contractual or other legal rights in or on behalf of any party.

AlphaSimplex Privacy Policy

In accordance with the Gramm-Leach-Bliley Act (GLB) and subsequent Securities & Exchange Commission (SEC) Regulation S-P and Regulation S-AM requirements, AlphaSimplex has enacted certain policies and procedures regarding the protection of client information. AlphaSimplex’s general policy is set forth herein.

Privacy Act Policies and Procedures

AlphaSimplex, its officers, and staff are committed to protecting the confidentiality of all client information. In accordance with government regulations, AlphaSimplex will, to the best of its abilities, limit the sharing of any accumulated nonpublic personal data to select business partners, organizations, government officials, vendors, or third parties who are authorized to act on its behalf and/or on behalf of its clients.

Due to the various products and services offered by AlphaSimplex, any or all of the individual products and services or a combination of products and services may be offered to existing clients or prospective clients at any time. Thus, in order to provide multiple products and services, it will be necessary, in the ordinary course of doing business (including but not limited to processing transactions and maintaining or transferring accounts), for AlphaSimplex officers and staff members to share certain personal data with other employees, third-party vendors, and/or other industry or product related firms. Such information will be designated as restricted and provided to outside vendors, firms, or individuals only when/as authorized by AlphaSimplex supervisors or managers, and only on a need-to-know basis. In addition, AlphaSimplex will apply the same restricted access to information provided by former clients and former prospective clients. AlphaSimplex has also established compliance guidelines which restrict general access to specified client information yet permit the firm to pursue the best overall product and service options for its clients and prospective clients.

AlphaSimplex has policies and procedures in place designed to dispose of client and prospective client information in a confidential manner when/as appropriate. In addition to the above-mentioned confidentiality measures, AlphaSimplex must honor all properly submitted regulatory and/or other appropriate governmental requests. AlphaSimplex generally seeks to keep confidential holdings and transaction information, but may provide information on client holdings or transactions for legitimate business purposes (for example, to a client’s consultant, to rating agencies, for limited marketing purposes, etc.) and generally subject to obtaining a confidentiality agreement from the recipient.

Client Privacy Preferences

Clients and/or prospective clients may choose, at any time, to inform AlphaSimplex to limit its sharing of certain personal information with affiliated or non-affiliated firms or vendors by contacting AlphaSimplex toll free and "opting out" at 617-475-7100 or via mail directed to the Chief Compliance Officer, 200 State Street, Boston, MA 02109. Individuals who reside in California and Massachusetts must notify AlphaSimplex to “opt in.” That is, individuals of those states must specifically grant AlphaSimplex permission to share any information outside of AlphaSimplex. Clients and prospective clients must understand that “opting out” or failing to “opt in” may severely restrict or limit AlphaSimplex’s ability to carry on business on behalf of those clients and in certain circumstances could affect the client’s account and/or investment returns.

AlphaSimplex reserves the right to change nonmaterial information in this statement at any time without any specific public notification. All material changes to this statement will be posted to the official AlphaSimplex internet site alphasimplex.com with all disclosure documents amended and all clients notified as soon as is reasonably possible.

Although AlphaSimplex will make every attempt to prevent the unauthorized use of client or prospective client data, there can be no guarantees. This privacy policy is not intended to, and does not, create any contractual or other legal rights in or on behalf of any party. Please contact AlphaSimplex at the sources listed above with questions and/or concerns.