QEX Asset Management

QEX ADVISORS, LLC

PRIVACY NOTICE

Our Commitment to You

QEX Advisors LLC (“QEX” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

This Policy is addressed to any current clients and/or prospective clients of QEX (“you” or “your”) whose public and non-public personal information QEX collects and controls to conduct its business, including on our website (“Site”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. QEX (also referred to as “we”, “our” and “us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

QEX does not sell your personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

Why you need to know?

Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account(s). Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information through the sources identified below and on our Site. In particular, this Policy describes how we collect and use your personal information about you during and after your working relationship with us. In particular, this Privacy Policy describes the basis upon which and for what purposes we process your personal information, as well as your privacy rights under certain privacy laws including, where applicable, under US Privacy Laws and the General Data Protection Regulation (“GDPR”), and how we protect your personal information. To the extent GDPR applies to this policy, personal information and nonpublic information includes personal data, as defined under the GDPR.

To affirm our continued commitment to the proper use of client information and protecting your privacy, we have set forth the following privacy policies.

Changes to Our Policy

We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.

Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.

What information do we collect from you?

When you establish a relationship with us, you are requested to furnish personal and financial information to assist in assessing your financial objectives and goals. The information you share with us is private and confidential, and we are committed to protecting your privacy. In addition to the information collected, during the course of our relationship we may also collect a variety of nonpublic and public personal information from other sources.

Social security or taxpayer identification number	Assets and liabilities
Name, address and phone number(s)	Income and expenses
E-mail address(es)	Investment activity
Account information (including other institutions)	Investment experience and goals

The specific types of personal information we collect and share depend on the service you have with us. This information can include:

personally identifying information such as name, telephone, address, date of birth, social security number, government identification, and marital status;
digital footprint data such as e-mail, login information, and IP addresses;
biographical data such as age and gender;
employment data such as salary information, job position, and tax information;
financial Information such as bank information, salary information, credit card numbers, and pension.

What Information do we collect from other sources?

Custody, brokerage and advisory agreements	Account applications and forms
Other advisory agreements and legal documents	Investment questionnaires and suitability documents
Transactional information with us or others	Other information needed to service account[s]

How is your personal information used?

We will only use your personal information with the purpose to provide you with our investment services. In managing your investment for you, we will use your personal information to:

monitor, audit, evaluate and otherwise administer our services;
provide you with access to protected areas of our Site;
provide continuous service to you and to conduct business processing functions including by providing personal information to our related bodies corporate, contractors, service providers or other third parties;
assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of QEX and its contractors and service providers;
communicate with you and respond to your inquiries;
conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms;
for other purposes required or authorized by law, including other purposes for which you have provided your consent;
protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; and/or
perform data analyses (such as market and customer research).

In the event that we use personal information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such personal information.

What lawful basis for processing do we have to process your personal information?

QEX may have one or more of the following lawful bases to process your personal information:

Consent: your freely, informed, and voluntary consent to process your personal information in connection to our investment services.
Contract: processing your personal information is necessary in order to fulfill a contract.
Legal Obligation: processing is necessary to comply with applicable rules, laws, and regulations.
Legitimate Interests: processing is necessary to the legitimate interests of our firm and/or a third party.

How do we share your information?

An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.

All financial companies need to share client’s personal information to run their everyday business. It is the policy of QEX to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide services in furtherance of the client’s engagement of QEX.

In that regard, QEX may disclose the client’s information:

to individuals and/or entities not affiliated with QEX, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by QEX in furtherance of the client’s engagement of QEX (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.);
required to do so by judicial or regulatory process; or
otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

Clients and/or prospective clients will be deemed to have automatically authorized QEX to share any information contained in any document completed by a client and/or prospective client to QEX for the purpose of facilitating the business relationship with any corresponding nonaffiliated third party service provider in connection to QEX providing such services (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.).

We limit access to nonpublic personal information to only those employees who have a business or professional reason for knowing it and who have signed a copy of QEX’s Privacy Policy to have access to client information. Employees violating QEX’s Privacy Policy will be subject to QEX’s disciplinary process. QEX limits access to nonaffiliated third parties as permitted by law. Additionally, whenever QEX hires other third party organizations to provide services to QEX’s clients, QEX will require them to sign confidentiality agreements and/or the Privacy Policy.

We do not provide your personal information to mailing list vendors or solicitors for any purpose.

Disclosure of any nonpublic personal information about our former clients is handled in the same manner as for our current clients.

In the section below pursuant to U.S. Federal Laws, we list the reasons financial companies can share their customers’ personal information; the reasons QEX, LLC chooses to share and whether you can limit this sharing.

Basis for Sharing	Do we share?	Can you limit?
Servicing our Clients We may share non-public personal information with non- affiliated third parties (such as administrators, brokers, custodians, regulators, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations.	Yes	No
Marketing Purposes QEX does not disclose, and does not intend to disclose, personal information with non-afffiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where QEX or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your account(s), not for marketing purposes.	No	Not Shared
Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).	Yes	Yes
Information About Former Clients QEX does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.	No	Not Shared

Can you limit our sharing?

To the extent U.S. Federal laws apply to your personal information, you have the right to limit only:

sharing for affiliates’ everyday business purposes;
affiliates from using your information to market to you; and
sharing for nonaffiliates to market to you.

U.S. state laws and individual companies may give you additional rights to limit sharing.

What are your individual rights?

To the extent permitted by the applicable law of your jurisdiction, in relation to your personal information, you may request:

to have your personal information corrected, for example, if it is incomplete or incorrect;
to opt out of receiving marketing communications at any time;
the right to file a complaint with an applicable government regulator such as a Data Protection Authority.

In addition to the foregoing, if you are located in the European Economic Area (“EEA”), to the extent permitted by applicable law, in relation to your personal information, you may request:

to access the personal information held by us about you;
the right to restrict or object to the processing of your personal information, or request that your personal information is erased;
the right to receive a copy of the personal information which you have provided to our firm, in a structured, commonly used and machine-readable format (known as “data portability”);
have a copy of the personal information we hold about you provided to you or another controller where technically feasible;
where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information.

To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

How do we protect your information?

To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information.

We require third parties that assist in providing our services to you to protect the personal information they receive from us.

Internet Security

Although we have made efforts to secure data that you submit to us on our Site, as our Site is linked to the internet which is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links to Third-Party Web Sites

As a convenience to you, QEX may provide hyperlinks to web sites operated by third parties. When you select these hyperlinks you will be leaving our Site.

QEX has no control over third party web sites, their content, or security. Accordingly, when you access these third party web sites it is at your own risk. We encourage you to read the associated privacy policies by such third party web sites to learn more about their data privacy management practices. QEX may, in its sole discretion, block links to our Site and Content without prior notice.

To the extent permitted by applicable law, we retain your personal information for the period necessary to serve the purposes for which we obtained it. We may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.

How do we keep your information accurate and up to date?

We will endeavor to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your personal information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.

How long do we retain your information?

Does our Site collect information about children?

Our Site is not directed to children under the age of 18 years. By using our Site, you represent and warrant that you are at least 18 years old. We do not knowingly solicit or collect personal information on our Site from children under the age of 18 without prior verifiable parental consent.

How we protect transferred data?

We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries (such as the United States, United Kingdom, Ireland or Cayman Islands), we will protect that information as described in this Policy.

If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision.

Do we use “cookies” or Obtain Personal Information by Automated Means?

We may use “cookies” to help us tailor our Site to better suit your needs (for example, we may use cookies to enable us to save any personal preferences indicated by you) and to provide a more effective route to various components of our Site.

Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable Sites to function or to provide information to the owners of a Site.

Automated Decision Making. Our Site contains cookies that function as an automated decision-making mechanism to determine user location.

Third party cookies. Third party cookies are cookies set by a web site other than the web site you are currently visiting. When you visit our Site, if we have link to third-party web site, you may receive cookies that are set by that third party. These cookies are used for the purposes described in the bullet points above. We do not control the setting of these third party cookies, so we suggest you might wish to check the third party web sites for more information about their use of cookies and how to manage them.

Amending internet browser settings to disable cookies. You can configure your browser to send accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You are free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Site. In addition, a number of companies offer utilities designed to help you visit Sites anonymously.

For more information about cookies and how to disable them please visit www.allaboutcookies.org, or you may consult the vendor documentation for your specific software.

For more information on how our firm utilizes cookies, please refer to our Cookies Policy.

How do We Respond to Do Not Track Signals?

We do not track users across time or over multiple Sites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms. However, as noted above, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Amending your internet browser’s Do Not Track signal: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform Sites and services that they do not want certain information about their webpage visits collected over time and across Sites or online services.

To learn more about setting up a Do Not Track signal, please visit allaboutdnt.com.

For more information on how our firm responds to Do Not Track signals, please refer to our Cookies Policy.

Who is the data controller?

As identified under applicable law, the data controller for this policy is QEX, located at the address below.

Any Questions?

If you have any questions regarding this privacy policy or would like to exercise your rights, you may contact our Chief Compliance Officer using the information below:

Phone: 609-484-8408
E-mail: info@qexmanagement.com

Definitions

Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.

QEX does not have any affiliates.

Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.

QEX does not share with nonaffiliates so they can market to you.

Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial services to you.

QEX does not jointly market.