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Last Updated: 12/2024

Applied Finance (encompassing the Applied Finance Group, Applied Finance Capital Management, and Applied Finance Advisors) (“we,” or “us,” or “our”) cares about your privacy and recognizes the importance of protecting your personal information. This Privacy Policy (“Policy”) describes the kind of information we may collect during your visit to our websites (the “Sites”). By accessing the Sites, you agree to our collection and use of personal information as described in this Policy and in our Terms of Service.

Please note that we provide a separate Privacy Notice (“Notice”) related to our Applied Finance Advisors (Mutual Funds) and Applied Finance Capital Management (Separately Managed Accounts) as required under the Gramm-Leach-Bliley Act. In the event of a conflict between this Policy and the Notice, with respect to Applied Finance Advisors and Applied Finance Capital Management, the Notice will take precedence.

Personal Information We May Collect

We collect your personal information when you visit our Sites, activate a free trial, open an online account, request information about our services, register for mailing lists, or otherwise interact with the Sites, email, or call us, or when you voluntarily provide information to us through the Sites.

The information we collect may include personal information such as your name, email address, home or billing address, telephone numbers, Social Security Number, or financial account information. We may also collect records of products or services you purchased, obtained, or considered and payment information.

We may also collect personal information from you automatically when you visit our Sites. This information may include your IP address, your device and browser type, and information about your interaction with our Sites and advertisements. Please see the section below titled “Cookies and Analytics” for more information.

How We May Use Your Personal Information

We use your personal information to provide you with the information or services that you request or that are requested on your behalf. We may also use personal information to contact you from time to time to provide you with important reminders, customer support, required notices, advertisements and marketing promotions and offers about products or services we think may be of interest to you, including our own products and services as well as those of our affiliates.

As described on our Registration and Contact forms, by providing us with your contact information, you agree that we may contact you from time to time via telephone, email, or SMS text message. Standard messaging rates may apply. If you would like to opt-out of receiving any messages, please contact us per the Contact Us section of this Privacy Policy to request removal and allow up to 10 business days for us to process your request.

We also use personal information about your use of our Sites to monitor and improve our Sites; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.

How We May Share Your Personal Information

We may share your personal information with service providers that help us operate our business, including through payment processing, customer account maintenance, reporting to credit bureaus, verifying customer information, managing customer information and providing customer service, facilitating scheduling, facilitating email communications, providing security services and cloud-based data storage, hosting our Sites and assistance with other IT-related functions, advertising and marketing of our services and those of our affiliates, providing analytics information, legal and accounting services, among other business functions.

Additionally, we may share your personal information as described under Cookies and Analytics.

We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our or others’ rights, property, or safety, including to law enforcement agencies, and judicial and regulatory authorities. Additionally, we may disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may transfer or disclose your personal information to a third party in the event of an actual or proposed sale, merger, reorganization of our entity or other restructuring.

Cookies and Analytics

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit the Site, we may place a “cookie” or other online tracking device (e.g., web beacons) that recognizes you when you visit the Sites. These are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies, you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.

We use certain cookies or web tracking tools, including Google Analytics, Statcounter, ActiveCampaign, and Pardot to evaluate the use of our website. These tools use cookies and other trackers to collect information, such as how often users visit the website, what pages they visit when they do so, and what other websites they visited prior to visiting our website. To learn more about how Google Analytics in particular collects personal information, review Google’s Privacy Policy at https://policies.google.com/privacy?hl=en-US#infocollect.

Personal Information of Minors

Our products and services are not directed to minors under the age of 13 and we do not knowingly collect the personal information of minors under 13.

How We Keep Your Personal Information Secure

We implement and maintain reasonable security measures appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical, and technical safeguards to protect the security, confidentiality, and integrity of personal information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

Other Websites and Social Media Buttons

Our Site may contain links to other websites or social media buttons. We are not responsible for the privacy practices or the content of those websites or social media platforms. This Privacy Policy applies only to our business and the personal information we collect.

Changes to This Policy

We will review and update this Policy as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the website or update the “last updated” date of the Privacy Policy. If the changes are material, you will be notified via a notice on our website.

Contact Us

If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us using the information below.

privacy@afgltd.com

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