Privacy Policy

General. Protecting your privacy is very important to Starkwood, Inc. and its affiliates, as appropriate ("SW"). Consequently, SW has established a privacy policy that safeguards your personal information (e.g., institution name, individual user(s) and password) and we are committed to protecting its confidentiality. We will limit the collection and use of Client Information (defined below) to what is necessary to administer our business and provide you with the highest quality service. We will not disclose any personal information except in the limited circumstances specifically described below.

Types of Client Information. Client information ("Client Information") is any information, data or records that relate to your SW account or use of SW's Web site and identifies you or your individual user account. The two types of Client Information are: (a) "identity," such as your company name, street address, telephone number, email address, and password; and (b) "navigational and transactional information," such as information about where you go or what you download through SW's Website.

We may share your personal information with other companies within the SW organization in order to service your account. However, we will keep your information private in accordance with this privacy statement. Your personal data will not be disclosed to other outside organizations and/or individuals unless you have consented to the disclosure and/or the disclosure is necessary for us to comply with our legal and regulatory obligations or pursue our ordinary business activities.

The Internet. Please be aware that SW's Website is a proprietary Website, but the Internet is not. SW does not control the content, services, or areas available through the Internet, and providers of Internet sites or services have separate data and privacy practices independent of SW. While we strive to protect all information we receive online, we cannot guarantee the security of any information you transmit to us online, and you do so at your own risk.

Cookies. SW uses "cookies" to allow you to navigate SW's Website. The cookies are activated when you enter the password-protected area of the site.

Navigational and Transactional Information Collection. We may collect and store certain navigational and transactional information, such as page hits and PDF files you view, and the times and ways you use this Web site.

Use. SW uses navigational and transactional information to personalize SW's Website, for programming, editorial and market research and to offer new content that our users may like. Additionally, by entering the password-protected areas of our website, you consent to SW contacting you to discuss our management strategies and services from time to time.

Disclosure. SW will not disclose to third parties, navigational or transactional information, except to comply with legal/regulatory obligations.

Modification of Privacy Policy Changes. If we elect to change our privacy policy, we will post those changes here so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. Questions regarding the above statement should be directed to YOUR EMAIL.

Last updated: February 20, 2013

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