PRIVACY POLICY AGREEMENT

February 24, 2020

Valentus Capital Management ("Valentus") values its users' privacy. This Privacy Policy ("Policy")
will help you understand how we collect and use personal information from those who visit our
website or make use of our online facilities and services, and what we will and will not do with the
information we collect. Our Policy has been designed and created to ensure those affiliated with
Valentus Capital Management of our commitment and realization of our obligation not only to
meet, but to exceed, most existing privacy standards.

We reserve the right to make changes to this Policy at any given time. If you want to make sure
that you are up to date with the latest changes, we advise you to frequently visit this page. If at
any point in time Valentus Capital Management decides to make use of any personally
identifiable information on file, in a manner vastly different from that which was stated when this
information was initially collected, the user or users shall be promptly notified by email. Users at
that time shall have the option as to whether to permit the use of their information in this separate
manner.

 

This Policy applies to Valentus Capital Management , and it governs any and all data collection
and usage by us. Through the use of valentuspcapital.com, you are therefore consenting to the
data collection procedures expressed in this Policy.

 

Please note that this Policy does not govern the collection and use of information by companies
that Valentus Capital Management does not control, nor by individuals not employed or managed
by us. If you visit a website that we mention or link to, be sure to review its privacy policy before
providing the site with information. It is highly recommended and suggested that you review the
privacy policies and statements of any website you choose to use or frequent to better
understand the way in which websites garner, make use of and share the information collected.

Specifically, this Policy will inform you of the following:


1. What personally identifiable information is collected from you through our website;
2. Why we collect personally identifiable information and the legal basis for such collection;
3. How we use the collected information and with whom it may be shared;
4. What choices are available to you regarding the use of your data; and
5. The security procedures in place to protect the misuse of your information.

 

Information We Collect

It is always up to you whether to disclose personally identifiable information to us, although if you
elect not to do so, we reserve the right not to register you as a user or provide you with any
products or services.

 

In addition, Valentus Capital Management may have the occasion to collect non-personal
anonymous demographic information, such as age, gender, household income, political affiliation,
race and religion, as well as the type of browser you are using, IP address, or type of operating
system, which will assist us in providing and maintaining superior quality service.

 

Why We Collect Information and For How Long

We are collecting your data for several reasons:
· To better understand your needs and provide you with the services you have requested;
· To fulfill our legitimate interest in improving our services and products;
· To send you promotional emails containing information we think you may like when we
have your consent to do so;
· To contact you to fill out surveys or participate in other types of market research, when we
have your consent to do so;
· To customize our website according to your online behavior and personal preferences.

 

The data we collect from you will be stored for no longer than necessary. The length of time we
retain said information will be determined based upon the following criteria: the length of time
your personal information remains relevant; the length of time it is reasonable to keep records to
demonstrate that we have fulfilled our duties and obligations; any limitation periods within which
claims might be made; any retention periods prescribed by law or recommended by regulators,
professional bodies or associations; the type of contract we have with you, the existence of your
consent, and our legitimate interest in keeping such information as stated in this Policy.

 

Use of Information Collected
 

Valentus Capital Management does not now, nor will it in the future, sell, rent or lease any of its
customer lists and/or names to any third parties.

 

Valentus Capital Management may collect and may make use of personal information to assist in
the operation of our website and to ensure delivery of the services you need and request. At
times, we may find it necessary to use personally identifiable information as a means to keep you
informed of other possible products and/or services that may be available to you from
valentuspcapital.com

 

Valentus Capital Management may also be in contact with you with regards to completing
surveys and/or research questionnaires related to your opinion of current or potential future
services that may be offered.

 

Disclosure of Information

Valentus Capital Management may not use or disclose the information provided by you except
under the following circumstances:


· as necessary to provide services or products you have ordered;
· in other ways described in this Policy or to which you have otherwise consented;
· in the aggregate with other information in such a way so that your identity cannot
reasonably be determined;
· as required by law, or in response to a subpoena or search warrant;
· to outside auditors who have agreed to keep the information confidential;
· as necessary to enforce the Terms of Service;
· as necessary to maintain, safeguard and preserve all the rights and property of Valentus
Capital Management.

 

Non-Marketing Purposes

Valentus Capital Management greatly respects your privacy. We do maintain and reserve the
right to contact you if needed for non-marketing purposes (such as bug alerts, security breaches,
account issues, and/or changes in Valentus Capital Management products and services). In
certain circumstances, we may use our website, newspapers, or other public means to post a
notice.

 

Children under the age of 13

Valentus Capital Management 's website is not directed to, and does not knowingly collect
personal identifiable information from, children under the age of thirteen (13). If it is determined
that such information has been inadvertently collected on anyone under the age of thirteen (13),
we shall immediately take the necessary steps to ensure that such information is deleted from our
system's database, or in the alternative, that verifiable parental consent is obtained for the use
and storage of such information. Anyone under the age of thirteen (13) must seek and obtain
parent or guardian permission to use this website.

 

Unsubscribe or Opt-Out

All users and visitors to our website have the option to discontinue receiving communications
from us by way of email or newsletters. To discontinue or unsubscribe from our website please
send an email that you wish to unsubscribe to info@valentuscapital.com . If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific website to unsubscribe or opt-out. Valentus
Capital Management will continue to adhere to this Policy with respect to any personal
information previously collected.

 

Links to Other Websites
 

Our website does contain links to affiliate and other websites. Valentus Capital Management does
not claim nor accept responsibility for any privacy policies, practices and/or procedures of other
such websites. Therefore, we encourage all users and visitors to be aware when they leave our
website and to read the privacy statements of every website that collects personally identifiable
information. This Privacy Policy Agreement applies only and solely to the information collected by
our website.

 

Notice to European Union Users

Valentus Capital Management 's operations are located primarily in the United States. If you
provide information to us, the information will be transferred out of the European Union (EU) and
sent to the United States. (The adequacy decision on the EU-US Privacy became operational on
August 1, 2016. This framework protects the fundamental rights of anyone in the EU whose
personal data is transferred to the United States for commercial purposes. It allows the free
transfer of data to companies that are certified in the US under the Privacy Shield.) By providing
personal information to us, you are consenting to its storage and use as described in this Policy.

 

Security

Valentus Capital Management takes precautions to protect your information. When you submit
sensitive information via the website, your information is protected both online and offline.
Wherever we collect sensitive information (e.g. credit card information), that information is
encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in
the address bar and looking for "https" at the beginning of the address of the webpage.
While we use encryption to protect sensitive information transmitted online, we also protect your
information offline. Only employees who need the information to perform a specific job (for
example, billing or customer service) are granted access to personally identifiable information.
The computers and servers in which we store personally identifiable information are kept in a
secure environment. This is all done to prevent any loss, misuse, unauthorized access, disclosure
or modification of the user's personal information under our control.

 

Acceptance of Terms

By using this website, you are hereby accepting the terms and conditions stipulated within the
Privacy Policy Agreement. If you are not in agreement with our terms and conditions, then you
should refrain from further use of our sites. In addition, your continued use of our website
following the posting of any updates or changes to our terms and conditions shall mean that you
agree and acceptance of such changes.

 

How to Contact Us
 

If you have any questions or concerns regarding the Privacy Policy Agreement related to our
website, please feel free to contact us at the following email, telephone number or mailing
address.

 

Email: info@valentuscapital.com

 

Mailing Address:
Valentus Capital Management
99 Wall St, #1330
New York, New York
1005

 

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