Privacy

WILLOWBRIDGE ASSOCIATES INC.

WEBSITE PRIVACY POLICY

Effective Date:  June 21, 2017

Willowbridge Associates Inc. and its affiliates (collectively referred to as “Willowbridge,” “we,” “us,” or “our”) collect information about you when you take advantage of our online services or visit or interact with our website willowbridge.com and any other website owned and operated by Willowbridge that links to this privacy policy (the “Site”).  This privacy policy (the “Policy”) describes: (1) the types of information we may collect about you and your use of the Site; (2) how we may use and share that information; and (3) the choices you may make with respect to your personal information.  For more information about our privacy practices relating to your use of our services, please contact us for a copy of our Privacy Notice. Please note that we may use facilities outside of your home country to process, store or back up electronic information.

By providing your Personal Information (as defined below) to Willowbridge or otherwise using the Site, you agree to the terms of this policy and our website Terms of Use.

Personal Information We Collect and Use

When we use the term “Personal Information,” we mean information that can be used to identify you as an individual person. We may collect and use two categories of Personal Information through your use of the Site.

1. Personal Information You Provide To Us

We collect the Personal Information you choose to share with us through the Site. For example, when you:

· signup for our newsletter or account updates, we collect your contact information and communication preferences, which we use to manage how we communicate with you; and

· submit identifiable comments or other content to us, we collect whatever information you supply and use this information to communicate with you if requested, and otherwise fulfill the purpose of the content submission. This information will include any personal information you choose to provide, for example,your name, e-mail address, gender, date of birth, addresses, telephone number, trading experience, or financial information.

Please do not submit information that you do not want us to have.

2. Information Collected Automatically

We use various technologies to collect other types of data that do not directly reveal your identity (“Other Information”).  If we associate Other Information with Personal Information, we will treat the combined information as Personal Information in accordance with this Policy.

· Logging Functionality: As is true of most websites, we gather certain information automatically and store it in log files.  This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data.  We generally only use this data for purposes such as security, fraud detection, and protecting our rights.

· Cookies and Other Data Collection Technologies: We and our business partners and services providers may collect and store information about you and your use of the Site through cookies, tracking pixels, and other technologies (collectively, “Tools”).  Cookies are small text files that are stored by your browser on your computer’s hard drive.  We may collect, use, and modify this information to better understand, customize, and improve your experience with the Site as well as to manage our advertising.Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences.  For information on how to do this, access the “help” menu on your Internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies.  Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of the Site.

Additional Purposes For Which We Collect And Use Information

In addition to the uses described above, we may use your Personal Information for the following purposes:

· Operating our business;

· Contacting you to respond to your requests or inquiries and provide user support;

· Contacting you about programs, products, or services that you have requested or event invitations;

· Creating, improving and developing our products and services;

· Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Information, the Site or data systems; or to meet legal obligations;

· Investigating and resolving disputes and security issues and enforcing our Terms of Use and other agreements;

· Any other lawful, legitimate business purpose.

How We May Use & Share Your Personal Information

We share your Personal Information with third parties in the ways described below and elsewhere in this Policy.   

Service Providers:  We share your Personal Information with third party service providers who perform services on our behalf or for your benefit, such as web hosting or verifying user data.

Affiliates:  We may share your information with affiliated legal entities within our family of companies for purposes and uses that are consistent with this Policy. 

Legal Process, Safety and Terms Enforcement:  We may disclose your Personal Information to legal or government regulatory authorities in response to their requests for such information, to assist in investigations.  We may also disclose your Personal Information to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or us, or to enforce our legal rights or contractual commitments that you have made. 

Business Transfers: Your Personal Information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership.  You will be notified via email and/or a prominent notice on any affected website of any change in ownership or uses of Personal Information, as well as any choices you may have regarding Personal Information about you.

Do Not Track Disclosures

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers.  When a user turns on DNT, the browser sends a message to the website site operator requesting the website operator not to track the user.  At this time, we ignore these DNT signals.  We do not change our practices, described elsewhere in this Policy, in response to DNT browser settings or signals.  In particular, even if you have turned on DNT, we and others will continue to collect information about you and your activity through the use of cookies, tracking pixels, and other Tools.  For information about DNT, visit www.allaboutdnt.org.  Other parties may collect information about your online activities over time and across different websites when you use our Site or services.

Notice to California Residents

Under California law, California residents may request a list of all third parties to whom we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes.  If you are a California resident and would like to receive such a list, please contact us at 101 Morgan Lane, Suite 180, Plainsboro, NJ 08536.  For any such request, include the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code.   Please provide enough information for us to determine if this applies to you.  You must also attest to the fact that you are a California resident and provide a current California address for our response.  Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.

Accessing Personal Information

Please contact us if you have any questions or concerns about your Personal Information or require assistance in managing your choices.

To access, change, or delete your personal information, choose not to receive marketing or other promotional communications from us, or otherwise change your choices about how we use your Personal Information, or for any questions regarding this Policy, please: (1) update your account details online; (2) follow the unsubscribe instructions located at the end of any marketing communication from us; (3) e-mail us at info@willowbridge.com; (4) call us at 609-936-1100; or (5) write us at the following address with your message:

Investor Relations

Willowbridge Associates Inc.

101 Morgan Lane, Suite 180

Plainsboro, NJ 08536

Please be sure to include in any e-mail or postal mail your full name, e-mail address, postal address, and any message.  Please note that some requests may take up to ten (10) days to become effective.  Please note that where required by law to maintain certain information, we may not be able to fulfill requests to delete information.

Children

The Site is not designed to collect personal information from children who are under 13 years of age, and we do not intend to or knowingly collect such information.

Updates to Our Privacy Policy

From time to time, we may post updates to this Policy.  Any changes will be effective upon thirty (30) calendar days following our posting of the revised Policy.  If we make any material changes in the way we use your Personal Information, we will notify you by prominently posting notice of the changes on the Site and updating the effective date above. We may also make, without notice, minor changes to the Policy that will not significantly affect our use of Personal Information. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes. Continued use of the Site, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. We encourage you to periodically review this page for the latest information on our privacy practices.  This Policy was updated as of the effective date listed above.

Additional Information/Questions

If you have questions or concerns about our privacy policy or practices, please contact us at info@willowbridge.com or 609-936-1100.