Use of Terms and Definitions
PERSONAL AND NON-COMMERCIAL USE LIMITATION
NO SECURITIES OFFERING OR INVESTMENT ADVICE
The information on the Site is intended to enable investors to understand the nature of RAMCO's financial advisory services. It is not intended as and does not constitute investment advice or legal or tax advice, or an offer to sell any securities to any person or a solicitation of any person of any offer to purchase any securities. The information in the Site should not be construed as any endorsement, recommendation or sponsorship of any company or security by RAMCO. There are inherent risks in relying on, using or retrieving any information found on the Site, and RAMCO urges you to make sure you understand these risks before relying on, using or retrieving any information on the Site. You should evaluate the information made available through the Site, and you should seek the advice of professionals, as appropriate, to evaluate any opinion, advice, product, service or other information.
RAMCO's services are designed to integrate with the services provided by its clients' other financial, legal and tax advisers, not to replace their services. RAMCO advises its clients from time to time on non-investment related matters, but clients must rely on their other professional advisers for final approval and/or implementation of non-investment matters.
You acknowledge that any requests for information are unsolicited and any information provided shall neither constitute nor be construed as investment advice by RAMCO to you or constitute the formation of an investment advisory relationship, or any other client relationship. It is strongly recommended that you seek outside advice from a qualified securities professional. RAMCO does not guarantee the suitability or potential value of any particular investment or information source. RAMCO may invest or otherwise hold an interest in companies or securities that may be discussed on the Site.
As a condition to your use of the Site, you represent and warrant to, and agree with RAMCO that, all of the information that you provide shall be truthful, accurate and complete.
DISCLAIMERS AND LIMITATION OF LIABILITY
THE INFORMATION, SOFTWARE AND SERVICES PUBLISHED ON THIS WEBSITE MAY INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS. DUE TO VARIOUS FACTORS, INCLUDING THE INHERENT POSSIBILITY OF HUMAN AND MECHANICAL ERROR, THE ACCURACY, COMPLETENESS, TIMELINESS AND CORRECT SEQUENCING OF SUCH INFORMATION, SOFTWARE AND SERVICES AND THE RESULTS OBTAINED FROM THEIR USE ARE NOT GUARANTEED BY RAMCO OR ANY PERSONS CREATING OR TRANSMITTING SUCH INFORMATION, SOFTWARE AND SERVICES.
RAMCO AND/OR ITS RESPECTIVE SUPPLIERS MAY MAKE IMPROVEMENTS AND/OR CHANGES IN THE CONTENT AND OPERATION OF THE SITE AT ANY TIME WITHOUT NOTICE. THE SITE MAY BE TEMPORARILY UNAVAILABLE FROM TIME TO TIME DUE TO REQUIRED MAINTENANCE, TELECOMMUNICATIONS INTERRUPTIONS OR OTHER REASONS.
RAMCO AND/OR ITS RESPECTIVE SUPPLIERS MAKE NO REPRESENTATIONS ABOUT THE SUITABILITY OF THE INFORMATION, SOFTWARE, PRODUCTS AND SERVICES CONTAINED ON THIS WEBSITE FOR ANY PURPOSE. ALL SUCH INFORMATION, SOFTWARE, PRODUCTS AND SERVICES ARE PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND. RAMCO AND/OR ITS RESPECTIVE SUPPLIERS HEREBY DISCLAIM ALL WARRANTIES AND CONDITIONS WITH REGARD TO THIS INFORMATION, SOFTWARE, PRODUCTS AND SERVICES, INCLUDING ALL IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT AND AVAILABILITY. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, THE ABOVE EXCLUSION MAY NOT APPLY TO YOU.
YOUR USE OF THE SITE IS AT YOUR OWN RISK. YOU ARE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM, LOSS OF DATA OR ANY OTHER DAMAGE OR LOSS THAT RESULTS FROM THE DOWNLOAD OF ANY CONTENT FROM THE SITE. IN NO EVENT RAMCOLL RAMCO AND/OR ITS SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN ANY WAY CONNECTED WITH OR RELATING TO THE USE OF OR ACCESS TO THIS WEBSITE OR WITH THE DELAY OR INABILITY TO USE THIS WEBSITE, OR FOR ANY INFORMATION, SOFTWARE, PRODUCTS OR SERVICES OBTAINED THROUGH THIS WEBSITE, WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, EVEN IF RAMCO OR ANY OF ITS SUPPLIERS HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU.
OWNERSHIP OF CONTENT
NO UNLAWFUL OR PROHIBITED USE
REFERENCES TO PUBLICATIONS AND OTHER COMPANIES
References to any publication or any other company in the Site are for reference and informational purposes only and are not intended to suggest that any of such companies endorse, recommend or approve of the services, analysis or recommendations of RAMCO or that RAMCO endorses, recommends or approves the services or products of such companies. News stories reflect only the author's opinion and not necessarily that of RAMCO.
LINKS TO THIRD PARTY WEBSITES
The Site may contain hyperlinks to websites operated by parties other than RAMCO, which may not have been screened or reviewed by RAMCO and which may contain inaccurate, inappropriate or offensive material, products or services. RAMCO does not control such websites, and RAMCO assumes no responsibility or liability with regard to the accuracy, reliability, legality or decency of such third-party websites, content, products or services. Such hyperlinks are provided for your convenience only. RAMCO's inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.
MODIFICATION AND MONITORING OF WEBSITE
TERMINATION AND CANCELLATION
RAMCO reserves the right to modify or terminate the Site and to terminate your access to the Site, without notice at any time and for any reason.
JURISDICTIONAL ISSUES AND APPLICABLE LAW
Unless otherwise specified, RAMCO controls and operates the Site from its offices within the State of California, United States of America.
• RAMCO does not claim that materials in the Site are appropriate or available for use in locations other than California. If you choose to access the Site from other locations, you do so on your own initiative, and you are responsible for compliance with any applicable local laws.
• Software from the Site is further subject to United States export controls. Software from the Site may not be downloaded or otherwise exported or re-exported outside the United States. By downloading or using such software, you represent and warrant that you are not located in, under the control of, or a national or resident of any country or territory outside of the United States.
Your Privacy Is Important to Us
At Ramparts, we believe the confidentiality and protection of your information is one of our fundamental responsibilities. While it is necessary for us to obtain information about you in order to provide quality service and products to serve your financial needs, we know that one of our most important assets is our client's trust. Therefore, Ramparts has established a wide-ranging policy of protecting confidential information about you and your transactions. Described below are the circumstances under which we may receive and obtain non-public personal information about you and our policies to protect your privacy.
If you have any questions about your privacy, information you are providing the Company, information the Company may obtain about you, how we use information provided to us, or any of our policies or services, please write to us at Ramparts Asset Management Company, LLC, 1 Embarcadero Center, Suite 4100, San Francisco, California 94111.
A. Categories of Information Which We Collect
In order to provide you with a product or service you have requested, we may collect 'non-public personal information' about you. The information we collect, may also be collected by other financial institutions when you obtain a product or service from them.
B. Categories of Information Which We Disclose and When It Is Disclosed
We do not share non-public personal information with any other non-affiliated party or affiliate of the Company unless required or permitted to do so by law or regulation. However, our web-site may contain links to other entities which will gather information about you if you visit that site. (See Section C.) Ramparts does not disclose or share account numbers or access codes with nonaffiliated third parties for the purpose of direct marketing or telemarketing the nonaffiliated third party's services or products.
C. Nonaffiliated Parties to Whom We Disclose Information for Routine Business Purposes
The following are the categories of Nonaffiliated Third Parties to whom we disclose information. Disclosure of information to each of these parties in these categories is permitted under the privacy laws and regulations. Each financial institution will share your non-public personal information under similar circumstances. Should you not wish to have your non-public personal information as described in this Policy and Disclosure Statement shared under the following circumstances you may wish to inquire as to what information will be shared before you request the service or product.
• When it is necessary for completing transactions, such as information which we must provide to our data processing vendors or financial service providers.
• To comply with a regulatory, government agency, court order, law or regulation under which the information is requested.
• To other companies, vendors, consultants, or financial institutions which may be involved in processing, monitoring or reviewing your transactions.
• When you have authorized us to provide the information to another party.
• Upon your request, or to complete transactions, including sharing with third parties we engage to help deliver our services to you.
• To verify individual's identities in order to reduce identity theft or fraud.
Accuracy of Information
Ramparts maintains procedures to insure that not only is the personal information you submit is accurately recorded and maintained, but that any inaccurate or incomplete information is corrected in a timely manner. If you have any reason to believe that your Personal Information is incorrect, please call us at 855-2-RAMPARTS (272-6727). You may also write us at 1 Embarcadero Center, Suite 4100, San Francisco, California 94111
Privacy as a Former Customer
If you decide to end your client relationship with Ramparts, we will continue to treat and safeguard your non-public personal information as described in this Disclosure. Our policies and procedures regarding your personal information associated with a closed account is the same as that of any open account you may have. Closed account information is retained for at least the period required by law or regulation.
Employee Access to Customer Information
Each Company employee is personally responsible for maintaining the confidentiality of customer data. The Company requires all of its employees to agree in writing to protect the confidentiality of client information and to use it only for the Company's purposes. Internal access occurs only to the extent appropriate to evaluate, structure and facilitate the services you have requested or to inform you of services or products you have requested or inquired about.
Information Security and Integrity
Ramparts is committed to preventing others from unauthorized access to your personal information, and we maintain procedures and technology designed for this purpose. These include policies and procedures about the appropriate physical security of workstations and records. Our physical, electronic and procedural safeguards comply with federal regulations regarding the protection of customer information. We also protect your information by maintaining backup copies of your account data, using computer virus detection and eradication software, using firewalls and other safeguards to attempt to protect against unauthorized access to our computer systems. However, "perfect security" does not exist on the Internet.
Collection of Information
In general, you can browse the non-password protected sections of the Site without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users' demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.
If you apply for a password to access password-restricted areas on this Site, you must provide to us your name, mailing address, email address, phone number, personal financial data, investment portfolio and other investment information.
Use and Disclosure of Information
We may use your information to send correspondence and perform services on your behalf in connection with investment related activities.
You agree that we may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site's content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.
We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
Control of Your Password and Personal Information
You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to any third parties. You may not allow others to use your user name or password to access or use any part of this Site. If your password has been compromised for any reason, you should contact us immediately for a new password.
You can review and change the information you submit to us by contacting RAMCO at email@example.com. You can change your User ID, email address, contact information, financial information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate.
Upon your request, we will deactivate your password and remove your contact information and financial information from our active databases. To make this request, email firstname.lastname@example.org. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy and applicable law.
Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, "firewalls" and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company. However, "perfect security" does not exist on the Internet.
Children (persons under the age of 18) are not eligible to use the Site.
Conditions Of Use
Changes to this Policy
Protecting and Restricting Use of Your Personal Information
If you believe that someone has obtained unauthorized access either to your account with us or to non-public personal information about you, please notify a RAMCO customer service representative immediately. You should also report the crime to your local law enforcement agency. For information regarding identity theft and ways to protect your personal information you may contact the Federal Trade Commission ("FTC") web site at http://www.consumer.gov/idtheft.