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PRIVACY POLICY

This privacy policy (“Policy”), effective June 16, 2014, describes how DJM Capital Partners, Inc., (“DJM”) treats personal information that you provide on its investor portal (the “Portal”). Neither DJM nor any of its services are designed or intended to attract individuals under the age of 13, and persons under the age of 13 are not authorized to use this Site.

We support the Do Not Track browser setting.  Do Not Track is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you.  If you request us not to track your activities on the Website, we will recommend that you refer to your web browser’s instructions to disable the tracking function.

What Information We Collect and Why

Personal Information

We collect personal information about you as part of your completion of the account registration process for the Portal.  The collection of this information enables us to authenticate you when you visit the Portal, and keep you apprised of information and developments concerning your investments with DJM that you may find of interest, and to allow us to better understand your needs.  The information you provide to set up your account including your account name, and e-mail address, and any personal information that may be contained in any reports accessible from your Account on the Portal, constitute the “personal information” to which this Policy applies.

Non-Personal Information

We may also collect the following information during your visit:
•         When you registered for the Portal;
•         When you last logged in;
•         When you viewed or downloaded a document; and
•         Whether you accepted the Terms of Use before downloading a document.

What Do We Do With the Information We Collect?

The information collected about you that is held or used in connection with the Portal will be collected by DJM or its third party service providers.
We use personal information, among other things, to verify user identity, authenticate your website visits and use, provide you the information that you have requested,and manage and improve our website and services.  We do not share your personal information except as permitted by law.

We use non-personal information to track and monitor aggregate use of our website and for internal analysis, quality control, and to improve our services for you and other customers. 

If you request, for the purpose of logging in (e.g., by checking “Remember Me” or similar item), DJM will deposit a persistent cookie that will remain on your device after you leave the DJM website or turn off your device.  Persistent cookies may be stored on your device as well by analytic companies retained by DJM to monitor your activity on DJM’s website.  DJM uses persistent cookies to remember your user name if you request, and to display the appropriate branding for your version of the Portal.  Consult your web browser documentation for information on removing a persistent cookie.

The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Because cookies allow you to take advantage of some of DJM’s features, we recommend that you leave them turned on.  For instance, if you block or otherwise reject our cookies, you may not be able to fully use or access the DJM website.
How Your Information Is Stored

DJM uses a range of physical, technical and administrative procedures to safeguard the information we collect.  This includes encrypting data using Secure Sockets Layer (SSL) Software encryption when the data is transmitted and when the data is at rest.

Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding your password, and other authentication information you use to access our services.  You should not disclose your authentication information to any third party and should immediately notify us of any unauthorized use of your password.  We cannot secure personal information that you release on your own or that you request us to release.

Despite DJM’s efforts to protect your personal information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet will be intercepted.
Correcting Your Information

If you wish to review or change your personal information, or if you no longer want DJM to maintain your information, please send your request to 
clientsupport@djmcapital.com, and we will comply with your request, and endeavor to do so within five (5) business days. 

Disclosing Your Information

We understand how important it is to keep your personal information private, so we will disclose personal information we have about you only in the following specific circumstances:

Required Disclosure

Under certain circumstances personal information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.  If we are legally compelled to disclose your personal information to a third party, we will disclose the information as required by law, but exercise commercially reasonable efforts to notify you of the disclosure unless doing so would violate the law or a court order.
 
Business Transitions


If DJM goes through a business transition such as a merger, acquisition by another company, or sale or other transfer of all or a portion of its assets, your personal information and non-personal information will likely be among the assets transferred.

Third Party Service Providers

We employ companies and individuals to perform certain functions on our behalf.  Examples include bookkeeping and financial reporting of investments, and operating the Portal.  They have access to both personal and nonpersonal information needed to perform their functions, but may not use your information for other purposes.  If you do not wish for these persons to collect your personal information from the Portal, you may opt-out by canceling your account.  Please contact 
clientsupport@djmcapital.com if you desire assistance in canceling your account.  
 
Policy Changes

Our Policy is posted on our Portal. We reserve the right to change this Policy at any time without notice. Should any new Policy become effective, DJM will post the changes to this Portal and will notify you by electronic mail at the address you provided for your account. The new policy will, thereafter, control the manner in which we handle private information. You will have the right to opt out at any time.

Governing Law

The laws of the State of California, without reference to any choice of law provisions, shall govern any claims relating to the materials on the Portal.

Contact Us

If you have any questions about this Policy or the Portal, please contact us at 
clientsupport@djmcapital.com.