Privacy Policy

Behringer Privacy Policy

Website Privacy Policy Effective Date: March 31, 2015

Introduction

The Behringer family of companies ("we" or "Behringer") has created this website (the "Website") privacy policy to demonstrate its commitment to your privacy. This Website allows users to learn more about our products and services and those of our parent companies, subsidiaries, affiliates, and affiliated funds. Also, our investors and their broker-dealers, financial advisors, IRA custodians, joint owners, and other similar parties may use the Website to access their accounts with us. Your use of the Website is conditioned upon your consent to be bound by our Website Terms and Conditions and to this Website Privacy Policy (as defined below) and the Behringer Privacy Policy. If you do not agree to be bound by our Website Terms and Conditions, this Website Privacy Policy, and the Behringer Privacy Policy, you may not use the Website.

The privacy provisions set forth below describe what non-personal information and non-public personal information we may collect or obtain through the Website, how we use this information, and to whom we may disclose this information (the "Website Privacy Policy"). This Website Privacy Policy only applies to information that we may obtain or collect through the Website. This Website Privacy Policy does not apply to information you may provide directly to Behringer, your broker-dealers, financial advisors, IRA custodians, or other third-parties, such as when purchasing products or services from Behringer or its parent companies, subsidiaries, affiliates, and affiliated funds.

If you enter into a business relationship with Behringer or its parent companies, subsidiaries, affiliates, and affiliated funds, the Behringer Privacy Policy applies to you and the information you provide. If you obtain Behringer products or services through a third-party broker-dealer, investment advisor, or other financial service provider, such third-party's privacy policy may also apply to the collection of information by such third-party.

Please note that third-party companies may operate and host the Website or portions of the Website on our behalf. If such companies do so, they will collect the information described below on our behalf and disclose it to us.

Visitors Located Outside the United States

The primary purpose of the Website is to provide information to its visitors. The Website is not intended to be used in connection with the offering or sales of securities outside of the United States. If you are a resident of a country outside the United States, you shall only use the Website to obtain information regarding Behringer and shall not transmit any personally identifiable information through the Website. Behringer makes no representations or warranties that this Website Privacy Policy meets or complies with privacy laws outside the United States.

Information We Collect and May Disclose

We may collect, use, and share information we obtain through the Website to conduct our business, to improve the functionality and performance of the Website, to make you aware of our products and services, to provide you with our products and services, and to comply with legal and regulatory requirements.

Non-Personally Identifiable Information

We may collect information through technology that does not identify you personally in order to make our Website more interesting and useful. This information may also be used to optimize Website performance within a given browser, increase the speed of navigation, or provide you targeted offers or advertisements based upon your use of the Website.

Cookies

We may use a standard feature in browser software called "cookies" to enhance your experience with our Website and/or to collect information regarding your use of the Website. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use this Website, cookies help us identify how many unique users visit this Website and track user trends and patterns. They also function to prevent you from having to re-enter information required to use this Website. Behringer may employ analytical software, tools, or services that use cookies and other markers to gather statistics on the use of the Website. Behringer may use the information gathered to improve web services for its Website visitors or to direct specific offers or advertisements to you. If you choose, you can prevent the Website from using cookies by disabling cookies in the preferences settings in your browser. Please note that by deleting cookies or disabling future cookies you may not be able to access certain areas or features of our Website.

Clear Gifs

We may also employ a software technology called clear gifs (also known as web beacons) that help us better manage content on our Website by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. Clear gifs and cookies are not tied to user's personally identifiable information.

Log Files

Like most standard website servers, Behringer may use log files. Information collected in log files may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the Website, track user's movement in the aggregate, and gather broad demographic information for aggregate use. This information is not personally identifiable.

Personally Identifiable Information

We may use and disclose certain categories of non-public personal information about you that we collect from your use of the Website, including information we receive from you through registering with the Website or requesting information about Behringer's products or services through the Website, such as name, address, e-mail address, login and password information, and telephone numbers.

How We Use and Disclose Information

The Behringer network of affiliated companies, sponsored investment programs, and third-party service providers work together to maintain an efficient and effective network of products and services. We may share the information collected through our Website with our companies and service providers to better serve your investment needs and also suggest services, products, or educational materials that may be of interest to you. We may use or disclose the non-public personal information we collect as follows:

Administrative Use.

We may use your non-public personal information for the purposes of furthering our business or improving the functionality and performance of the Website, which may include analyzing your information, matching your information with the information of others, resolving disputes, preventing fraud, and verifying your identity.

Aggregate Use and Disclosure.

We may use and disclose your non-public personal information on an aggregate basis. This means that we combine parts of your information with parts of the information from our other users without including your name, complete telephone number, complete e-mail address or your street address in the combination. Examples of how we use aggregate information include determining the most common ZIP code among the users of the Website and disclosing that ZIP code to other parties, or determining and disclosing demographic information such as the average income of investors in our investment programs.

Other Uses and Disclosures.

We may use and disclose your non-public personal information in order to:

  • Correct technical problems or malfunctions in how we provide our products and services to you and to process your information;
  • Protect the security and integrity of our Website and our Internet service, or to enforce our Terms and Conditions with you;
  • Protect our rights and property and the rights and property of others;
  • Take precautions against liability;
  • Respond to claims that your information violates the rights or interests of third parties;
  • Comply with applicable laws or regulations, or in response to a judicial process; or
  • Provide personal information, to the extent permitted by law, to regulatory or law enforcement agencies or for investigations on matters related to public safety.

Parties to Whom We Disclose Information

We may disclose non-public personal information obtained through the Website to the following types of third parties:

  • Financial service providers, such as for customer-initiated service requests, establishing and managing your investor accounts, completing your investor transactions, or pursuant to joint marketing agreements;
  • Non-financial companies, such as those marketing our own investment products and services, serving as our transfer agents, handling check printing, or providing data storage, processing, or analytics;
  • Others, such as broker-dealers, financial advisors, joint owners, IRA and other ERISA custodians, or other parties acting on your behalf; or
  • Regulatory agencies, other authorities, courts, or as otherwise required by law or legal order.

We may share non-public personal information with Behringer affiliates or with non-affiliated service providers who perform business functions on our behalf. But before we disclose non-public personal information to non-affiliated parties, we contractually require them to keep such non-public personal information confidential and secure, and to use it only as authorized by us.

We may also disclose non-public personal information to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements. Behringer does not disclose, sell, or rent your information to outside marketers who may want to offer you their own products and services. We require all joint marketers to have written contracts with us that specify appropriate use of your personal information, require them to take steps to safeguard your personal information, and prohibit them from making unauthorized or unlawful use of your personal information.

We may also share your non-public personal information with non-affiliated third parties as otherwise permitted by law.

Links to Other Websites

The Website may contain links to other third-party websites. You acknowledge that when you leave the Website using a link to a third-party website, you will be subject to the privacy policy of the third-party website. Accordingly, Behringer disclaims any liability arising from the privacy practices or the content of third-party websites.

How We Protect Your Information

Behringer will use commercially reasonable methods to ensure the electronic security of your non-public personal information stored or transmitted through the Website; however, no electronic storage method or data transmission over the Internet can be guaranteed to be 100% secure. Behringer shall not be liable for any unauthorized access or discovery of your personal information if it was using commercially reasonable methods to keep such information secure at the time of such access or discovery. We also restrict access to non-public personal information to those employees who have a legitimate business need for the information.

Our Commitment to Children's Privacy

Protecting the privacy of the very young is extremely important to us. No part of our Website is structured to attract or provide services for anyone under 13. We do not collect or maintain information at our Website from those under the age of 13. If we obtain actual knowledge that we have collected information about a child under the age of 13, that information will be immediately deleted from our records.

Changes to Our Website Privacy Policy

Behringer may amend this Website Privacy Policy at any time in our sole discretion and post the amended Website Privacy Policy on the Website. Behringer may provide notice of such changes through a general posting on its Website or through an e-mail to you. However, Behringer has no obligation to provide such notice. Thus, each time you use the Website, you are agreeing to the then-current Website Privacy Policy. Therefore, you should review the Website Privacy Policy regularly.

Questions about Our Website Privacy Policy

If you have any questions about our Website Privacy Policy and/or the personal information practices of our Website, please e-mail us at legaldept@behringerinvestments.com or call us at 866.655.3650.

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