THIS IS OUR OFFICIAL PRIVACY POLICY WHICH FORMS PART OF YOUR LEGAL AGREEMENT WITH US UNDER OUR TERMS AND CONDITIONS OF USE.  PLEASE READ OUR PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE COLLECT, USE AND SHARE INFORMATION ABOUT YOU.

Any terms not defined in this Privacy Policy are defined in our Terms and Conditions of Use.

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Axia Associates L.L.C. may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately. This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Axia” refers to The Axia Associates L.L.C. and its affiliates worldwide.

Introduction.

We are committed to safeguarding your privacy. We believe that the best way to protect the privacy of users of our Sites is to tell you what information we gather and ensure that you understand and consent to Axia's uses of information you provide.

Changes to Privacy Policy.

We may occasionally modify this Privacy Policy and will post a notice of the effective date of the revised Privacy Policy on this page so that you are always aware of what information we collect, how we use it and under what circumstances we use or disclose it. Your use of our Sites after the effective date of any modification, means you accept and agree to be bound by the Privacy Policy as modified. You should check the policy frequently to read the latest Privacy Policy. Please note that each Site may contain links to and from third party websites. We are not responsible for the privacy practices or the content of third party websites. The information practices of third party websites are not covered by this Privacy Policy.

Information we collect and how we collect it.

We use the term “Personal Information” to refer to any information you provide in connection with your use of any of our Sites by which you can be personally identified.  Personal Information may include such things as your name, telephone numbers, email address, location (e.g. U.S.) and the name of your organization.  We only obtain Personal Information about you when you submit it to us, such as when subscribing to a newsletter or an article or requesting information.  By using any Site and submitting Personal Information, you consent to the collection and use of your Personal Information by us as described in this Privacy Policy. Besides Personal Information, when you access or visit any of our Sites, we and our operational service providers and others who host our Sites may use technology that can recognize, collect, and transmit information that is associated with you, but which does not personally identify you.  Although the term "cookies" specifically refers to small pieces of information that is stored by your browser on your computer's hard-drive for record keeping purposes, we will use the term “cookie” to refer generically to any technology that can recognize, collect or transmit information about your visits to our Sites. “Cookie” information typically includes such data as your referring domain, type of internet browser, operating system software, screen resolution, date and time of visit and other technical data related to your visit.  No personally identifiable information is collected by this process.

Cookies allow our Sites to recognize a users' computer or access device each time it is used to visit our Sites and cookies can keep count of how often you return to our Sites.  Cookies can also track how you use our Sites, the pages you visit and your preferences for features and functions. Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent it from accepting cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. We have sought to set up each Site so as to notify you before a cookie is used. However, if you choose to reject all cookies, you may be unable to use parts of our Sites.

How we use information collected.

We use information collected or obtained when you use our Sites, including Personal Information, to ensure compliance with our Terms and Conditions and for our internal research purposes, such as to analyze trends, administer our Sites, track user movements on our Sites, gather aggregate demographic data about visitors so we can continually improve our Sites.  In addition, we may also use your Personal Information for the purposes set out below if you have indicated that you wish us to use your Personal Information in this way when submitting such information:

• Market research;
• Responding to feedback;
• Informing you about our services which may include contacting you by telephone;
• Sending you client bulletins or information that may be of interest to you

Disclosures of Your Personal Information within Axia.

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Axia may be given, or given access to, your personal information. For example, one Axia entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as corporate finance advisory and consulting services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information.

Disclosure of Information to Third Parties.

We always have the right to disclose your Personal Information to our operational service providers that we engage to assist us with our Sites such as hosting, storage fulfillment and disaster recovery.  We always request that our operational service providers protect your privacy and not disclose your Personal Information to third party marketers that are not associated with our Sites, nor are our operational service providers allowed to use your Personal Information for their own marketing or promotional purposes. We also reserve the right to make your Personal Information available:

• To other Axia offices & groups;
• When compelled by a governmental agency, law, regulation, a court or other legal process;
• If we believe your use of our Sites has or may violate any law, regulation or our Terms and Conditions  
• If we believe you are or may be a threat to safety, security, property, interests or rights of us or others;
• In order to investigate or respond to or resolve problems or inquiries or defend our interests;
• In a merger, acquisition, change of control, joint venture or other business combination.

Save as described above, we do not otherwise disclose information about your individual visits to any Site or information which identifies you to any third parties unless we have your prior consent.

Security.

We take the security of your data seriously. Therefore, once we receive your transmission, we make our best efforts to ensure its security on our systems. The servers we store Personal Information in are kept in a secure physical environment.  We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. It is our policy to virus check documents and files before they are posted on any Site. However, we cannot guarantee that documents or files downloaded from any Site will be free from viruses and we do not accept any responsibility for any damage or loss caused by any virus. Accordingly, for your own protection, you must use virus-checking software when using our Sites. You must not post or provide to us via any Site, any document or file which you believe may contain a virus. You must virus check any document or file which you intend to post or provide to us via any Site. Unfortunately no data transmission or security program can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. You remain responsible for the security of your computer at all times.

Online Security Tips
While Axia is committed to ensure the highest standard of security on our systems, you as the end-user also play an important role to ensure that you are adequately protected when you use the Internet. The following security best practices are recommended:

• Install anti-virus, anti-spyware and other internet security software on your PC. Use it regularly and keep it up-to-date.
• Take advantage of your PC's security features. Make sure your browser uses the strongest encryption available and be aware of the encryption levels of the sites and applications you use.
• Regularly update your PC's operating system and Web browser software with the vendor's software patches and updates to protect your PC against known vulnerabilities.
• Do what you can to prevent unauthorized people from using your PC.
• Change your passwords often. Be sure to choose passwords that are hard for others to guess.
• If you notice suspicious activity in your accounts, report it immediately to the appropriate parties.
• Do not download or open any attachments sent to you by unsolicited email. Once opened, these programs may contain malicious programs that can compromise your PC's security.
• Be on the alert for phishing scams.  Access Web sites by typing the Web addresses directly into your Web browser or by using Web addresses you have bookmarked, instead of via embedded links in unsolicited emails.

Additional Information:

If you require further information regarding our privacy policies and practices in the United States please contact:

Axia Associates, LLC
5023 N. Parkway Calabasas
Calabasas, CA 91302