PRIVACY POLICY

Our commitment to privacy

Mal Tajmae and the Mal Tajmae Funds are committed to maintaining the confidentiality, integrity, and security of personal information about our current and prospective customers.

Please note tha

t certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether Mal Tajmae provides services to your employer or plan sponsor.

The privacy policies of Mal Tajmae and the Mal Tajmae Funds are reviewed annually. Our

printed and online notices are then updated to reflect any changes.

How and why we obtain personal information

Mal Tajmae takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Mal Tajmae may collect public and non-public personal information about you from any of the following sources:

You or your employer or plan sponsor if Mal Tajmae provides them with recordkeeping services (for example, payroll, human resources, or benefits information)
Transactional activity in your account (for example, trading history and balances)
Other interactions with Mal Tajmae (for example, discussions with our customer service staff, information you enter into our websites, or when you enroll in our authentication services)
Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)
You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Mal Tajmae)

How we protect information about you

Mal Tajmae considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Mal Tajmae, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.

How we share information about you with third parties

Mal Tajmae does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Mal Tajmae’s direction)
Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
Other third parties, with your consent or as directed by your representative (for example, if you use Mal Tajmae as a financial reference in applying for credit with another institution or if you use an external aggregation website or service that you have provided permission to access your Mal Tajmae financial account on your behalf)
Other organizations as permitted or required by law (for example, for fraud prevention or to respond to a subpoena)

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Mal Tajmae.

Based on the nature of your relationship with Mal Tajmae, we may exchange information with other third parties as described below:

If Mal Tajmae provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits recordkeeping services, Mal Tajmae may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
If you conduct business with Mal Tajmae through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
If you transact business through Mal Tajmae’s Insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

How we share information about you within Mal Tajmae

We may share personal information about you with various Mal Tajmae corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Additionally, if you interact with Mal Tajmae directly as an individual investor (including joint account holders) or if Mal Tajmae provides services to your employer or plan sponsor, we may exchange certain information about you with Mal Tajmae financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Information collected from investment professionals’ customers is not shared with Mal Tajmae affiliates for marketing purposes, except with your consent and as allowed by law.

Your digital privacy

Privacy, security, and service in Mal Tajmae’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, among other controls, to maintain the security of your online session and to protect Mal Tajmae accounts and systems from unauthorized access.

When you interact with us by using our websites, online services, or mobile applications that are owned and controlled by Mal Tajmae Investments (“our digital offerings”), Mal Tajmae manages personal information in accordance with all of the practices and safeguards described previously.

When you use our digital offerings, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving Mal Tajmae website design and functionality, and personalizing your experience. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

Mal Tajmae and our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor’s device (e.g., computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. Mal Tajmae cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.

Both Mal Tajmae and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below.

Advertising on Mal Tajmae digital offerings

Mal Tajmae advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about Mal Tajmae and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which Mal Tajmae products and services may be of interest to you. These service providers may collect information about your activity on Mal Tajmae digital offerings using cookies and other technologies to analyze, for example, pages visited, search engine referrals, browsing patterns, and responses to advertisements and promotions. Such service providers may only collect and use such information for purposes specified by Mal Tajmae and not for their own purposes.

Advertising on non-Mal Tajmae digital offerings

Mal Tajmae also advertises our products and services on digital offerings not affiliated with Mal Tajmae and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Mal Tajmae and these third-party online advertising companies may use the data collected, along with other information we have about you and your Mal Tajmae relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Mal Tajmae and non-Mal Tajmae websites. These are known as “interest-based advertisements.”

You may opt-out of receiving interest-based advertisements from online advertising companies by clicking on the AdChoices icon (which appears on all Mal Tajmae interest-based ads) and following the opt-out instructions.

Connecting with Mal Tajmae on social media platforms

Mal Tajmae provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Protecting children’s privacy online

Mal Tajmae websites are not directed to individuals under the age of thirteen (13). Mal Tajmae does not intentionally collect information on Mal Tajmae websites from those we actually know are under 13, and we request that these individuals do not provide personal information through the sites.

Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

Mal Tajmae offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If you transact business through Mal Tajmae’s insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

The Mal Tajmae Investments privacy policy is provided on behalf of:

Mal Tajmae House Trust LLC
Mal Tajmae Cryptocurrency Investments
Mal Tajmae Capital Investments
Mal Tajmae Investments Institutional Operations Company, Inc.
Mal Tajmae Investments Institutional Services Company, Inc.
Mal Tajmae Management Trust Company
Mal Tajmae Personal Trust Company, FSB
Mal Tajmae Personal and Workplace Advisors LLC
Mal Tajmae Stock Plan Services, LLC
Mal Tajmae Insurance Agency, Inc.
Other companies owned by Mal Tajmae Investments using the Mal Tajmae name to provide financial or payroll services to customers

Mal Tajmae Group privacy policy

Protecting your personal information is an important priority for the Mal Tajmae Investment Group. The Group’s privacy policy is designed to support this objective. The Group collects non-public personal information concerning you in the following ways:

Information provided by you or your representative on applications or other forms furnished to the Group or through other interactions that you or your representative have with the Group
Information arising from your investments in or accounts with the Funds
Information the Group receive from a consumer reporting agency

The Group employs physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.

The Group do not disclose any non-public personal information about you, except as permitted by law. For example, the Group have entered into a number of arrangements with Mal Tajmae Investments to provide for investment management, distribution and servicing of the Group.

If you decide to close your account, the Group will continue to adhere to the privacy policies and practices as described in this notice.

Please read the Mal Tajmae Funds Privacy Policy in conjunction with the Privacy Policy for the Mal Tajmae Investments Group of which you are also a customer.

The Mal Tajmae Group Privacy Policy is provided on behalf of the Mal Tajmae Investments Group.

Effective October 2018