Cleverdome Privacy and Data Protection Policy

Protecting the private information of you and your clients is our priority. We therefore provide our Privacy and Data Protection Policy on data collection and usage which is applicable to Excel Solutions, LLC dba Cleverdome, www.cleverdome.com, cleverdome and *.cleverdome.com (collectively, “Cleverdome”).

The Cleverdome website is a Cleverdome Storage Platform and Applications site. By using the Cleverdome website, you consent to the data collection and usage practices described in this Privacy and Data Protection Policy.

Collection of Personal Information

Cleverdome may collect personally identifiable information of your clients such as names, addresses, social security numbers, financial account numbers, driver license numbers or government issued identification documents. In addition to the personally identifiable information which you provide, Cleverdome may also collect a variety of non-pubic personal information from other sources such as:

• Information we receive from client agreement forms and account applications
• Information about client transactions through you or others.
• Information we receive from correspondent clearing firms, custodians, product sponsors and third party data aggregators.
• Medical information submitted as part of an insurance application such as a traditional life or variable annuity policy.
• Information received from service bureaus or other third parties.

All of the above is collectively referred to herein as “Personal Information.”

Collection of Business Related Information

In addition to the Personal Information of your clients, Cleverdome may collect personal and confidential information related to you and your business. If you purchase Cleverdome's products and services, we collect billing and credit card information to complete the purchase transaction. Information about your computer hardware and software may be automatically collected by Cleverdome. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Cleverdome website. This type of information is collectively referred to herein as “Business Related Information.”

Cleverdome encourages you to review the privacy statements of websites you choose to link to from Cleverdome so that you can understand how those websites collect, use and share your information. Cleverdome is not responsible for the privacy statements or other content on websites outside of the Cleverdome website.

We may gather additional business, personal or public information in the future in connection with providing Cleverdome’s products and services.

Use of Personal Information and Business Related Information

Cleverdome collects and uses Personal Information and Business Related Information to operate its website(s) and deliver the services you have requested.

Cleverdome may also use Personal Information and Business Related Information to inform you of other products or services available from Cleverdome. We may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Cleverdome may, from time to time, contact you on behalf of external business partners regarding a particular offering that may be of interest to you. In those cases, your Business Related Information is not transferred to the third party.

Cleverdome may keep track of the websites and pages our users visit within Cleverdome to determine what Cleverdome services are the most popular. This data is used to deliver customized content and advertising within Cleverdome to customers whose behavior indicates that they are interested in a particular subject matter.

Use of Cookies

The Cleverdome website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Cleverdome pages, or register with the Cleverdome site or services, a cookie helps Cleverdome to recall your specific information on subsequent visits. This simplifies the process of recording your personal information such as billing addresses, shipping addresses and other pertinent information. When you return to the same Cleverdome website, the information you previously provided can be retrieved so that you can easily use the Cleverdome features that you customized.Cleverdome; or (c) act under exigent circumstances to protect the personal safety of users of Cleverdome or the public.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Cleverdome services or websites you visit.

Limitations Regarding Sharing Personal Information and Business Related Information

Cleverdome does not disclose Personal Information or Business Related Information to anyone except as permitted by law. Cleverdome will disclose Personal Information or Business Related Information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to applicable laws, rules or regulations or to comply with legal process served on Cleverdome; (b) protect and defend the rights or property of

Cleverdome may disclose Personal Information and Business Related Information to trusted partners that perform statistical analysis, administrative services on our behalf, product sponsor companies, custodians, clearing firms, transfer agents, and certain data storage, management and protection servicers. All such third parties are prohibited from using Personal Information or Business Related Information except to provide the services which we have specified, and they are required to maintain the confidentiality of such information.

Cleverdome does not sell, rent or lease any information to third parties.

Security of your Personal Information

Cleverdome maintains physical, electronic and procedural safeguards that comply with applicable federal and state regulations to protect Personal Information and Business Related Information. To secure such information from unauthorized access, use or disclosure, Cleverdome uses the following:

GoDaddy Secure Certificate Authority Amazon Web Services: EC2, RDS and S3

All data depositories that hold Personal Information and Business Related Information are encrypted. When Personal Information or Business Related Information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

Industry standards and best practices are in place to screen Cleverdome employees prior to allowing access to Personal Information or Business Related Information.

Industry standards and best practices are in place to test and monitor compliance with our Privacy and Data Protection Policy.

Children Under Thirteen

Cleverdome does not knowingly collect personally identifiable information from children under the age of thirteen. Individuals under the age of thirteen must ask a parent or guardian for permission to use this website.

Opt-Out & Unsubscribe

We respect your privacy and provide an opportunity for you to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Cleverdome by contacting us at:

Changes to this Privacy and Data Protection Policy

Cleverdome reserves the right to change its Privacy and Data Protection Policy at any time. Cleverdome maintains its Privacy and Data Protection Policy on its website at _______________ and encourages you to periodically review its Privacy and Data Protection Policy to be informed of how Cleverdome is protecting information.

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