Empaxis Data Management, LLC, like other professionals who advise on personal financial matters is required by federal law to inform its clients of its policies regarding the privacy of client information. Empaxis Data Management, LLC is committed to maintaining the confidentiality and security of our client’s personal and private information. Please take a moment to review our privacy policy.

In the course of providing our clients’ with certain advice, EDM and its third party vendors (collectively referred to as “EDM”) may receive non-public personal financial and private information from our clients, their advisors and attorneys and other third party representatives, such as broker statements, information from advisor systems and custodial websites, financial statements, documents and other personal information. All non-public information that we receive regarding our clients or former clients is held in the strictest confidence in accordance with our professional obligations, and is not released to people outside EDM except with your consent or as required by law. Client information is used only for our business purposes and we do not sell client information to anyone. At your direction, we may share certain information with other related or affiliated entities or third parties who assist us with providing our services, including but not limited to specified family members and a client’s related and affiliated entities, regulators or other governmental entities as permitted or required by law and other firms such as accountants, lawyers, financial institutions and electronic storage service providers as may be applicable, subject to the obligation of all such third parties not to use or disclose such information for any other purpose. Within EDM, access to a client’s non-public information is restricted to individuals who require that information in the ordinary course of servicing a client’s account. At times, client information may be reviewed by our outside service providers such as accountants, lawyers, consultants, etc.). In all cases, EDM will review the service provider’s privacy policies to ensure that clients’ information is not misappropriated or used in a manner that is contrary to our privacy policy.

Please be advised that EDM retains records relating to professional services that we provide so that we are better able to assist you with your needs and, in some cases, to comply with professional guidelines. While we strive to update changing client information on a contemporaneous basis, we ask you to monitor any such information for errors. In order to guard your non-public personal information from unauthorized disclosure, we maintain physical, electronic and procedural safeguards that comply with our professional standards. With respect to online privacy, we employ certain internet specific practices to maintain the security of your information, including but not limited to firewall barriers, encryption and authentication procedures.

In the event that these policies change, EDM will provide you with a sufficient amount of time to opt out of any disclosure provisions. Nevertheless, EDM will provide a copy of its annual privacy notice to all clients upon inception of our engagement. In addition, each of our active clients shall be provided with a copy of our privacy notice within ninety (90) days following the close of EDM’s fiscal year.

Safe Harbor Compliance (data transfers from the European Union and Switzerland to the United States of America): Empaxis Data Management complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Empaxis Data Management has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Empaxis Data Management’s certification, please visit http://www.export.gov/safeharbor/.

The U.S. Department of Commerce and the European Commission have agreed to a data protection framework called the “U.S.-EU Safe Harbor Framework” that consists of a set of privacy principle documents and related FAQs. The U.S. Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed to a similar data protection framework called the “U.S.-Swiss Safe Harbor Framework”. The Safe Harbor Frameworks describe how organizations that receive personal data from the European Union and Switzerland should provide information about purpose of collection (Notice), participation (Choice), Onward Transfer, Security, Data Integrity, Access, and Enforcement. A discussion of these data handling issues can be found at the Commerce Department’s Safe Harbor website at http://export.gov/safeharbor/ and the Safe Harbor Privacy Principles and FAQs of the U.S.-EU Safe Harbor Framework and the U.S. Swiss Safe Harbor Framework are currently are available in full at https://www.privacyshield.gov/welcome.

Communications relating to Empaxis Data Management’s Safe Harbor certification, and inquiries concerning the recourse mechanism for unresolved Safe Harbor complaints, can be sent to the company’s Safe Harbor compliance administrator.

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