Introduction

This privacy policy (“Privacy Policy”) describes the ways Ilan Investments, LLC and its affiliates and subsidiaries (“We”, “Us”, or “Ilan”) collect, store, use, disclose, and protect your personal information. We use the term “personal information” to describe information that can be associated with you and can be used to identify you. Personal information does not include information that does not identify a specific person. You agree to the practices regarding your personal information described in this Privacy Policy when you use Ilan online services (collectively, “Ilan online services”).

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Information We Collect

When you use Ilan online services, we may collect certain information relating to that use, some of which may be personal information. Examples of personal information include your name, address, telephone number, email address, other means to contact you, and Social Security number. If you register with Ilan online services, we will collect data that may include personal information, such as your contact information, financial information submitted by you or others in connection with your use of Ilan online services, and verification information that we use to identify you. In addition, we may collect information such as your Internet Protocol (IP) address and/or domain, the type and version of your Internet browser software and operating system you use, the date, time, and duration of your Ilan online services access, the specific pages, buttons, images, links, and forms that you access while visiting Ilan online services, the type of device you use to access Ilan online services (such as a BlackBerry, iPhone, or iPad), your mobile carrier and/or Internet Service Provider. Collection of this data does not personally identify you. We may also use third party applications and services to collect and analyze this information in the aggregate. Representatives of Ilan may collect personal and financial information from you for entry into the Ilan database. This information may include your name, address and telephone number. We may also collect information about you that you otherwise submit to us, such as through email and other means.

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Our Use of Personal Information

We may use your personal information to (i) provide information you request in Ilan online services; (ii) verify your identity when accessing these services; (iii) enforce our terms of use and any other agreements between you and Ilan; (iv) improve, modify, customize, and measure Ilan online services; (v) compare information for accuracy and verify our records; and (vi) detect and prevent fraud or other criminal activities.

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Sharing Personal Information in Connection with Ilan Online Services

To provide Ilan online services, we may share some of your personal information with other entities who perform services for Ilan. We may share your personal information with service providers who are authorized to use your personal information only as necessary to support our business operations, such as those who provide data storage, payment, technology support and services, customer service, risk solution provision, analytics, fraud prevention, and marketing services. We may also share some of your personal information as otherwise permitted or required by law or as authorized by you.

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Updating and Correcting Your Personal Information

Keeping your information accurate and up to date is very important. If your personal or account information is incomplete, inaccurate or not current, please contact Ilan at 281-444-1585.

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Cookies and Similar Technology

When you access Ilan online services, we, or third parties we hire to track how our website is used, may place small data files called “cookies” on your computer or other access device. Cookies are pieces of data stored on your device and are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server.

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A “session cookie” may be sent to your computer or other access device when you log in to Ilan online services. This type of cookie recognizes you if you visit multiple pages on a site during the same session, so that you do not need to be prompted for your password on each page. Once you log out or close your browser, this cookie expires and no longer has any effect. “Persistent” or longer-lasting cookies can be used for other purposes, such as to record user experience preferences when you use a website. These cookies do not expire once you log out or close your browser. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of Ilan online services.

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We and our third party service providers may also use technologies similar to cookies to track your interaction with Ilan online services. Some of these technologies include web beacons, pixels, tags and Flash objects. As with cookies, you are free to decline such technologies if your browser permits. You should refer to your browser’s instructions to remove cached history and images from your device. Deleting or disabling cookies will not remove Flash objects. You should refer to Adobe’s website (www.adobe.com) for more information on how to disable these objects.

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Ilan and the third parties who assist in operating Ilan online services do not respond differently or limit their practices under the terms of this policy when you access those online services with a browser that uses a do not track signal or similar mechanism.

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Storage and Protection of Personal Information

We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of personal information. In order to help secure personal information collected from you as an Ilan online services user, including sensitive financial data, the information is protected by SSL encryption? when it is exchanged between your web browser and Ilan online services. However, the internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by Ilan in connection with Ilan online services. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, and physical, or other operational, safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary. By using Ilan online services, you agree that the procedures provided for in this Privacy Policy and the procedures implemented on Ilan online services to protect personal information and to verify the identity of Ilan online services users including, but not limited to, those procedures described in the foregoing paragraph, constitute commercially reasonable website security and customer verification procedures.

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Suspicious Email

It is our policy not to email you or send you electronic communications to request non-public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from Ilan but you suspect may be from another source and might be fraudulent, please email us at investor.relations@ilaninvestments.com.

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Social Media

You may also find additional information on our products and services through our social media sites such as Facebook, LinkedIn, or Twitter. Please keep in mind that any information you share is visible to all participants on these social media sites and you should never post any sensitive personal information (such as account number or tax identification). Please carefully review the Terms of Use and Privacy Policy on these social media sites as they may be different than our own policies.