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EFFECTIVE DATE: May 22, 2023

1. INTRODUCTION. WBI Investments, LLC and CyborgTech, LLC (collectively, “us,” “we,” or “WBI-Cy”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Cy platform on (“the Cy Platform”). This Website Privacy Policy (“Privacy Policy”) is an agreement between WBI-Cy and you, as the user of the Platform (“you”). Please note that this Privacy Policy applies to information WBI-Cy collects from you via the Cy Platform, and information obtained and disclosed through offline correspondence or personal contacts with our customers. This Privacy Policy is only applicable to the Cy Platform, and not to any other websites that you may be able to access from the Cy Platform, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

2. INFORMATION COLLECTED. In order for you to gain access to information about the services that we offer via the Cy Platform you were required to create an account on (the “WBI Account”).  To create this WBI Account you were required to register and provide us with certain information that personally identifies you (“Contact Data”). Contact Data includes information such as name, user name, email and password. In order to purchase a seat license for the use of the Cy Model Portfolio Services available on the Cy Platform you must then provide certain payment information (“Personal Information”). Personal Information is provided via a third party payment processing vendor and includes financial data such as bank account or credit card information necessary to complete payment.   Once you establish an WBI Account and purchase a seat license to use the Cy Platform, you will enter additional Contact Data in order to create your account on the Cy Platform (the “Cy Account”).  Upon creation of your Cy Account or when subsequently logging into the Cy Platform, you will have the option to enter information (the “Optimization Information”), about the risk profile and rate of return requirements, in addition to other fields, that will inform the optimization engine about which optimized portfolio to display.  Certain programs on the Cy Platform require very few pieces of Optimization Information while others allow for a significant amount of client Optimization Information to be entered in order to provide a more customized result.  In order to obtain the more customized result, clients will have the opportunity to enter Optimization Information that includes, but is not limited to, current net worth, liquid assets, date of birth, age of planned retirement, current salary, income needs in retirement, etc.

We may collect information from you via the Cy Platform, including your use of, and activities on, the Platform.

The Personal Information and Optimization Information (together the “Information”), including any personally identifiable information, that you provide and that we collect will be stored and maintained by WBI-Cy for so long as we, in our sole discretion, believe is necessary or appropriate (a) to carry out the purpose(s) and the use(s) for which such information was collected, or (b) to comply with applicable laws, contracts, or other rules or regulations.

Upon our collection of the Information, WBI-Cy may use such Information, including any personally identifiable information, internally, separately or in combination with pre-existing information, for the purposes set forth below. We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

  • To provide Services to you;

  • To generate Cy Processed Data;

  • To contact you, including via email, to respond to your comments or requests for information;

  • To troubleshoot problems with the Platform, or any services, as requested;

  • To improve our products and services and identify, develop or offer new products and services;

  • To contact you with more information about WBI-Cy and its services;

  • To enforce the Terms of Use or this Privacy Policy;

  • To generate aggregate statistical studies and conduct research which may be used in marketing our Services to you or to third parties;

  • To offer you products or services offered by WBI-Cy’s authorized partners; or

  • To provide any legitimate business service or product.

We may combine personal information about you received from several sources, including without limitation, the information described above for the Subscription Purpose and/or to generate Cy Processed Data. As provided in the Terms of Service, we may share the Cy Processed Data, in an aggregated non-personally identifiable manner with third parties.

3. CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION. Except as otherwise provided in this Privacy Policy, we will keep your Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service. Your Information is stored on secure servers that are not accessible by third parties other than technology providers contracted to maintain the databases. The Information provided by you is maintained in a secured and encrypted database.

3.1. LOST OR STOLEN INFORMATION. You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.

3.2. PUBLIC INFORMATION. The Cy Platform may contain links to other websites. We are not responsible for the privacy practices or the content of such websites.

4. UPDATES AND CHANGES TO PRIVACY POLICY. You agree that we may, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Platform and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Cy Platform. It is your responsibility to review this Privacy Policy from time to time to see if modifications have been made. Your continued use of this Cy Platform following modification of this Privacy Policy will be conclusively deemed to signify your acceptance of the modification. WBI-Cy reserves the right, at any time, to modify or discontinue, temporarily or permanently, the Cy Platform or any part thereof without notice.

5. ASSIGNMENT OR TRANSFER. If WBI-Cy is involved in a transaction such as a merger, stock purchase, bankruptcy or sale of substantially all WBI-Cy’s assets, the Information, including any personally identifiable information may be transferred to the other party in such transaction. You will be notified via email and/or a prominent notice through the Cy Platform of any change in ownership (other than where the new owners are affiliates of WBI-Cy) or uses of your personal information, as well as any choices you may have regarding your personal information.

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