Dated September 3, 2024

Mondrian Associates LLC and its members, officers, directors, owners, employees, agents, representatives, suppliers and service providers (collectively “Mondrian”) provides this website (the “Site”) for informational purposes only.

Use of and access to the Site and the information, materials, services, and other content available on or through the Site (“Content”) are subject to Mondrian’s Terms of Use and all applicable laws. This Privacy Policy describes how Mondrian Associates LLC (collectively, “Mondrian”) handles the personal information of individuals to whom we may market and provide advisory services, as well as the information we collect on our website, from third parties, and from other sources.

Information We Collect

When you interact with our services, we may collect:

• Account Information, such as your first and last name, email address, phone number, and primary address.
• Financial Information, such as your bank account number and credit or debit card information.
• Correspondence, such as information you provide via electronic correspondence.
• Device Data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 5G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Information We Get From Others. We may get information about you from other sources as required or permitted by applicable law, including public databases. We may combine the information collected from these sources with the information we get from the Site in order to comply with our legal obligations and limit the use of our services in connection with fraudulent or other illicit activities.
• Other Data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

We use the following tools for automatic data collection:

• Cookies, which are 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 navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Information

We may use your personal information to conduct research and analysis relating to our business. We may use the information we collect to market our services to you.

Compliance and protection. We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce the terms and conditions that govern our platform; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Personal Information

We may share your information with:

Service providers. Companies and individuals that provide services on our behalf or help us operate our business.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Your Choices

Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org. Use the following links to learn more about how to control cookies through your browser:

• Firefox; Chrome; Microsoft Edge; Safari

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Other Sites and Services

Our platform may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Information Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by email or updating the date of this Privacy Policy.

How to Contact Us

You can reach us by email at info@mondrianassociates.com or at the following address:
Mondrian Associates LLC
610 Fifth Avenue, New York, NY 10020

WHAT DOES MONDRIAN DO WITH YOUR PERSONAL INFORMATION?

Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Your contact details
• Transaction or loss history
• Account balances

When you are no longer our client, we continue to share your information as described in this notice.

How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Mondrian chooses to share and whether you can limit this sharing.

Reasons we can share your personal information

Mondrian may share the following, which clients cannot limit:

• For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.
• For our affiliates’ everyday business purposes - information about your transactions and experiences.

Mondrian does not share the following:

• For our marketing purposes - to offer our products and services to you.
• For joint marketing with other financial companies.
• For our affiliates’ everyday business purposes - information about your creditworthiness.
• For our affiliates to market to you.
• For nonaffiliates to market to you.

Questions? Go to our Support Page at www.mondrianassociates.com.

Who is providing this notice? Mondrian Associates LLC (collectively, “Mondrian”).

What We Do
How does Mondrian protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Mondrian collect my personal information? We collect your personal information, for example, when you

• Initiate an application for a financial product or service
• Open an account
• Make trades, deposits or withdrawals from your account

We also collect your personal information from others, such as banks, credit agencies and other third-party data aggregators.

Why can’t I limit all sharing? Federal law gives you the right to limit only:

• sharing for affiliates’ everyday business purposes
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.
What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account.

Definitions

Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you.