PRIVACY POLICY

Effective Date: September ¹, ²⁰²¹

Sigma Point Capital (“we”, “us”, “our”) is committed to respecting the privacy rights of visitors and users of sigmapointcapital.com (“Site”). We created this Privacy Policy (“Policy”) to give you confidence as you visit and use the Site and to demonstrate our commitment to fair information practices.

This Privacy Policy describes how we collect, use and share your personal information if you:

• Use our website at sigmapointcapital.com;
• Use our financial advisory services or are eligible to access them as an employee benefit ("Client Services");
• Receive our marketing communications or engage with us on social media services.

We refer to the Site, the Client Services and other activities described above, collectively, as the "Service".

¹. Notice Concerning Children

This Site is a general audience website directed at individuals ¹³ years of age and older pursuant to the definitions detailed in the Children’s Online Privacy Protection Act and accompanying COPPA Rule.

². Information Collection Practices

^2.1 What Personally Identifiable Information Do We Collect About You?

A. Types Of Personally Identifiable Information.

The Site offers a variety of different interaction levels for visitors. Should you visit, signup for our free newsletter, interact with the Site or work with us directly, we will collect some or all of the following person information from you depending upon the particular action you take.

• Contact Data - such as your first and last name, email, mailing address, residence, phone number, professional title and company name;
• Profile Data - Such as your username and password that you set to establish an online account with us, age, gender, biographic details, interests, preferences, intended time of retirement, and information that may be related to a service, account or event that you register for;
• Identity Data - such as a national identification number (e.g., social security number where permitted, tax ID number, passport number, state or local identification number (e.g., driver's license of state ID number), and an image of the relevant identification card;
• Financial Data – such as your income, economic or financial status, financial institution(s), financial account details, investment holdings and preferences, investment changes, account balances and contributions, and ability to invest;
• Payment and Transactional Data – such as the information required to complete your transactions on or through the Service (including name, contact information, credit card information, and billing information), information about payments to and from you, and information that you provide to us via subscription agreements, investor questionnaires or other documents prepared in connection with the Client Service;

B. Data From Other Sources.

We may combine personal information we obtain from you with personal information we obtain from other sources, such as:

• Data Providers - such as information services and data licensors;
• Public Sources - such as social media platforms;
• Business Partners - such as joint marketing partners and event co-sponsors;
• Our Clients -  such as your employer when they engage us to provide client services as a benefit to its employees.

C. Data Collected Automatically.

We, our service providers, and our business patterns may automatically store information about you, your computer or mobile device, and your activity over time on the Site and other online services. The information stored includes:

• Device Data - such as your computer or mobile device operating system type and version, manufacturer, model, browser type, screen resolution, IP address, and general information such as location data;
• Online Activity - such as pages or screens you have viewed, how long you spent on a page or screen, navigation paths between pages or screens, and information about your activity on a page or screen, including but not limited to access times and duration of access;
• Precise Geolocation Data - such as your location, if you consent to provide it.

D. Cookies And Other Technology.

Like most online services, we use the following technologies:

• Cookies - text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you interact with the site efficiently, remembering your preferences, enabling functionality, and helping us understand user and activity patterns;
• Flash Cookies - locally-stored objects which are used on websites for purposes similar to cookies, but allow for the storage of a larger amount of data;
• Web Beacons - also known as pixel tags or clear GIFs, used to provide information about whether a webpage or email was accessed or opened, or that certain content was viewed or clicked.

E. Information About Others.

Users of the services may refer friends or other contacts to us and share their contact information with us.

³. Use And Sharing Of Information

^3.1. How We Use Your Personal Information

We use your personal information for the following purposes:

A. Service Delivery.

We use your personal information:

• To provide, operate and improve the service;
• To execute transactions on your behalf;
• To establish and maintain your user profile;
• To enable security and preference-related features of the service, such as enabling two-factor authentication;
• To provide support and respond to your questions, requests and feedback.

B. Improvements To The Client Service.

We may use your personal information to analyze and improve the Service and our business. As part of these activities, we may created aggregated, de-identified or other anonymous data from personal information we collect.

C. Marketing And Advertising.

We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes. These include:

• Direct Marketing - we may send you direct marketing communications as permitted by law. You may opt out of our marketing communications as described in the Opt-Out section below;
• Interest Based Advertising - we may contract with third-party advertising companies and social media companies to display ads on the Site. These companies may use cookies and similar technologies to try and tailor the ads you see online to your interests based on your activity over time across our Site and other sites. You may limit our interest-based advertising as described in the Advertising Choices section below.

D. Compliance And Operation.

We may use your personal information to:

• Comply with application laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
• Protect your, our, or others' rights, privacy, safety or property (including by making and defending legal claims);
• Review our internal processes for compliance with legal and regulatory requirements, and internal policies;
• Prevent, identify, investigate and deter unauthorized, fraudulent, harmful and illegal activity, including cyberattacks and identify theft.

E. Sale Of Site/Company.

Should all or part of the Site or Sigma Point Capital be sold at some point in the future, your personal information will be included as an asset in the transfer.

^4. Your Choices

^4.1. You Have The Following Choices

A. Access Or Update Information.

If you have an online account with us, you can modify and remove certain personal information by going to your “Account” profile when logged in to the Site. Alternatively, you may contact us using the “Contact Us” function on the Site for assistance.

B. Opt-Out Of Marketing Communications.

You may opt out of marketing-related emails by following the unsubscribe instructions at the bottom of the email, or by contacting us. We may continue to send you service-related and other non-marketing emails.

C. Cookies.

Most browsers let you remove or reject cookies. To do this, follow the instructions in the browser settings for the specific browser you are using. Many browsers accept cookies by default until you change the settings. Please note that if you disable cookies, some functionality of the Site and the Service may not operate correctly. For example, you may continue to a pop-up notification repeatedly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

D. “DO NOT TRACK” Signals.

We do not honor “do not track” signals from browsers per se, however, certain Google third party cookies used through the Site can be blocked by following the links in Section E below. You may also use programs such as Privacy Badger to block tracking.

E. Third Party Tracking - Google Remarketing And Analytics.

We use various Google services, including Google Universal Analytics, to help us evaluate the performance of the Site as well as implement marketing campaigns including remarketing. By visiting the Site, you consent to first and third party cookies being placed on your computer by us and Google to track you. This information will be used to tailor marketing materials to you and for remarketing purposes. To opt-out of these functions, you can visit the following pages:

Stop Google Tracking

Google Analytic Opt-out Browser

F. Third Party Tracking - Social Media.

We provide social media “buttons” on the Site so you may post particular pages to your accounts on social media sites as well as follow Sigma Point Capital on various social media sites. Anything you post via these buttons is viewable to the public unless you use appropriate privacy restrictions available on the particular social sites on which you share the information. Further, the social media sites can track your actions and create a data profile for you. You should perform due diligence in investigating the privacy policies for each of these sites as follows:

Facebook

Twitter

Instagram

LinkedIn

^5. Security

^5.1. Security Measures.

The Site has reasonable security measures in place to prevent the loss, misuse and alteration of the information we obtain from you, but we make no warranty or guarantee about our ability to prevent sophisticated attacks and hacks.

^5.2. Lost Or Stolen Information.

You must promptly notify us if the username or password for your account is lost, stolen, or used without permission. In such an event, we will remove that username or password from your account and update our records accordingly.

^6. Website Areas Beyond Our Control

^6.1. Third Party Websites.

From time to time, the Site may contain links to other websites. If you choose to visit those websites, it is important to understand our privacy practices do not extend to those websites. These sites contain information that has been created, published, maintained or otherwise posted by institutions or organizations independent of Sigma Point Capital. Sigma Point Capital does not endorse, approve, certify or control these websites and does not assume responsibility for the accuracy, completeness or timeliness of the information located there. It is your responsibility to review the privacy policies of those websites to ascertain their professional practices.

^6.2. Affiliate Programs/Strategic Alliances.

We may participate in affiliate programs or strategic alliances from time to time. If you choose a product or service available from a third party, please note the privacy policy and terms for the third party will apply to your interactions with that entity. You are strongly encouraged to read the legal documents on third party sites prior to making any decision requiring a financial transaction or the disclosure of your personal information.

^7. Changes To This Privacy Policy

If we modify or update this privacy policy, we will notify you by posting a notice on the Site and, if we have an email address for you, by sending you an electronic message. You may then choose whether you wish to accept said policy changes or discontinue using the Site. Any change, update, or modification will be effective ³⁰ days after posting to the Site.

^8. Contact Information And Policy Updates

^8.1. Contact Us.

If you have any questions about this Policy, please contact us using the “Contact Us” function on the Site.