KWP Markets Consulting Privacy Policy Updated: June 19, 2018 KWP Markets Consulting is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Privacy Policy describes the types of information KWP Markets Consulting, as a data controller, may collect from you or that you may provide and our practices for collecting, using, maintaining, protecting and disclosing that information, including the following: Personal data we collect or process, including from our website kwpworks.com (the “Site”); How we use the data; Legal grounds for the processing of your data; With whom we may share the personal data; Your European privacy rights and choices; California disclosures; Retention Periods and protection of your data; Children’s privacy; Information about international transfers; Links to other sites; Privacy Policy updates; and How you can contact us. Personal Data We Collect or Process The Site captures some information about you automatically utilizing background local storage and session storage technologies (“Cookies”), subject to any opt-out preferences. Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of our Site (including certain third-party services and features offered as part of our Site). Examples of information of this type are your IP address, the browser you are using, the operating system you are using and the pages on the Site that you visit. Session cookies are deleted when you close your browser session. We may also collect information from publicly available sources. We do not link information obtained from Cookies to other personal data. You may change your browser setting to decline the use of Cookies. This Privacy Policy does not cover the use of Cookies by other websites, over which we have no control. The Site also collects information that you provide to us voluntarily. KWP Markets Consulting collects the information that you provide to us when you send an inquiry about our services, sign up to receive newsletters, advisories, announcements and invitations and contact us by email. We use this information only to respond to your comments, requests or questions. If you inquire about a career at KWP Markets Consulting, you have the option of sending to us a resume containing personal data about you and which we will use solely for employment evaluation purposes. Providing this information is completely voluntary. Please do not submit sensitive personal information to us. We also act as a service provider for third parties, including those that perform market research. In such capacity we may come into contact with personal data that is collected by others but which we process in order to perform our contractual obligations to the data controller who collected the data. How We Use the Data We use the personal data we collect to respond to your inquiries, provide or enhance the services you request, perform our contractual obligations, inform you of new services or changes in services, administer the Site, fill employment positions, enter into contracts for services, fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes. KWP Markets Consulting distributes newsletters and other publications to clients and friends of the company from time to time. If you wish to unsubscribe from any newsletter or promotional materials, please contact us by email at privacy@kwpworks.com. Legal Grounds for Processing Your Personal Data We rely on the following legal grounds to process your personal information: Consent. We may use your personal data as described in this Privacy Policy subject to your consent. To withdraw your consent, please contact us at privacy@kwpworks.com. You may also refrain from providing, or withdraw, your consent for Cookies via your browser settings. Performance of a contract. We may need to collect and use your personal information to enter into an agreement with you or to perform under an agreement that you have with us. When we process personal data on behalf of third parties, we do so in performance of agreements with such third parties. Legitimate Interests. We may use your personal information for our legitimate interests to provide our services and to improve our services and the content on our Site. We process information on behalf of third parties who have legitimate interests in operating their business, such as performing market research. We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law. With Whom We Share Personal Data KWP Markets Consulting is a global provider of services headquartered in the United States, and as such may need to share information with internal personnel located in different geographic locations in order to fulfill our contractual and legal obligations. We may also share, as controller or as processor performing at the direction of our clients, your personal data to third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our technology providers, administrative and support personnel and providers, professional advisors and translators. We may disclose information (within or outside your country of residence) if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you or our clients enter into with us. Your information may be transferred to another entity (within or outside your country of residence) in connection with a merger or reorganization or, when we are acting as a data processor at the direction of our client (data controller), at the request of the client. We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes. We use analytics tools and other third-party technologies, such as Google Analytics to collect non-personal information in the form of various usage and user metrics when you use our site. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and demographics, and other similar information. You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: www.tools.google.com/dlpage/gaoptout. KWP Markets Consulting may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Site, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them. Your European Privacy Rights and Choices If you reside or otherwise find yourself in the territory of Europe, we are committed to facilitate the exercise of your rights granted by the European Data Protection law. Otherwise you can contact us at any time to discuss your privacy concerns. Privacy rights under the European data protection law include: Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time. Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal, ethical and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at privacy@kwpworks.com. Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time. Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal, ethical and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal or ethical requirements. Right to data portability. You have the right to data portability of your own personal data by contacting us. Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you. Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement. California Disclosures California Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to privacy@kwpworks.com with “California Privacy Rights” in the subject line. California Do Not Track Disclosure: Depending on the browser you are using, you may be able to choose to block third party cookies or browse in a private browsing mode. Our Website is accessible even when private browsing is turned on. The information we collect is governed by this Privacy Policy. Retention Periods and Protection of Your Personal Data We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual obligations, and for any applicable statute of limitations periods. We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, written commitments from third parties that may have access to your data that they will protect the data with safeguards that are substantially equivalent to those used by KWP Markets Consulting. No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control and for unauthorized access to information by those who have gained access through illegal means. Children’s Privacy Our Site is a general audience site and does not offer services directed to children. If we obtain actual knowledge that a user is under 18, we will take steps to remove that user's personal information from our databases. By using the Site, you are representing that you are at least 18 years old. You also represent, by accessing or using the Site, that you are of legal age to enter into legal agreements, or if you are not, that you have obtained your parent’s or legal guardian’s consent to accept the terms in this Privacy Policy. Information about International Transfers KWP Markets Consulting is a Minnesota limited liability company. If you are visiting our Site from outside the United States, please be aware that your information will be transferred to and stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By visiting our Site or using our services, you understand that your information will be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy. Links to Other Sites KWP Markets Consulting may include links to third party sites on its Site. The inclusion of any link does not imply that we endorse the products and services offered at such linked site. These third party sites have separate and independent privacy policies which we encourage you to review. We therefore have no responsibility or liability for the content and activities of these linked sites. Privacy Policy Updates We may update this Privacy Policy from time to time in our sole discretion to reflect changes in our information practices. If we modify or update this Privacy Policy, we will post changes and updates on this website page so that you will always be aware of what information we collect, use and disclose. Your continued use of our Site after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal data to us. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy. How you can contact us To make a request or to ask us a question about our data practices, please contact us via email at privacy@kwpworks.com. In addition, you may contact us at: KWP Markets Consulting, LLC 625 Spring Hill Road Wayzata, MN 55391

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