bivio Inc. agrees to notify you of:

• What personal information is collected
• The organization collecting the information
• How the information is used
• With whom the information may be shared
• What choices are available to you
• How you can edit your information.

We also detail below what kind of security procedures are in place to protect the loss, misuse or alteration of information under bivio control.

bivio is the sole owner of the personal information collected on this site. bivio collects information from our users at several different points on our Web site:

• Registration. bivio collects information from you upon registration. At this point, you provide us with your name and an email address. The email address is used to contact you about the services on our site. It is optional for the user to provide their name, but encouraged so we can provide a more personalized experience on our site. All users must select a User ID and Password.
• Subscription. bivio collects information from you when you subscribe to one of our fee-based services. When you choose to pay by credit card (either online, by phone, or by postal mail), we collect your credit card number, expiration date, cardholder's name, and billing address zip code. By entering this information and clicking OK, you are authorizing us to charge your credit card for the amount specified on the subscription form.
• Club Data Import. Clubs have the option of importing club information from their current software solution. After uploading their club data file to bivio, club officers can select to have all information imported to bivio, or to import only accounting data while blanking out member contact information and/or Tax IDs.
• Club & User Information. bivio provides to each club and each user a private repository for contact information and for a Tax ID number.
  • As a club officer, you can view and edit the contact information and Tax ID number of other club members. You can also view but not edit the User ID of other club members or guests. You cannot view the Tax ID of guests.
  • As a club member or guest, you can view but not edit the contact information of other club members and guests. You cannot view the Tax ID of other club members or guests.
  • Other bivio visitors and users do not have access to your club and user information. Employees of bivio who need the information to perform a specific job (for example, our customer service representatives) are granted temporary access to club and user information. See "Offline Security" below.

• Transactions, Messages and Files. In the course of using the bivio accounting features, club officers will enter club transactional information (member payments, purchases of stock, etc) for the club. Clubs will also exchange messages and files. Club members and guests have the ability to view club transactional data, messages and files.

  Only club members and guests have access to club data, messages and files, unless your club opts to use the "Allow Public Access" features of bivio. Employees of bivio who need the information to perform a specific job (for example, our customer service representatives) are granted temporary access to club data, messages and files. See "Offline Security" below.

If your personally identifiable information changes (such as your zip code), or if you no longer desire our service, we provide you with a way to correct, update or remove your personal data provided to us. Contact information can be edited by visiting your info page.

If a user invites a friend to join their investment club, we ask them for the friend's name and email address. bivio will automatically send the friend a one-time email inviting them to join the user's club, along with a personal message from the club officer. bivio stores this information for the sole purpose of sending this one-time email. The friend may contact bivio to request the removal of this information from their database. Club invitations expire after two weeks.

We will share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person. These companies do not retain, share, store or use personally identifiable information for any secondary purposes. As an example, the 'Top Club Holdings' visible on the bivio home page are shared with third parties. In contrast, individual club portfolios are not shared with third parties.

We will cooperate with the appropriate legal authorities when presented with a subpoena or other government order.

bivio may reproduce and use your personally identifiable information as reasonably necessary to operate and maintain this site, and for us to provide our products and services. In connection with these activities, bivio may disclose your personally identifiable information to its employees and contractors on a need to know basis only, provided that such employees and contractors have confidentiality obligations to bivio no less stringent than those contained in this Privacy Statement. We will maintain the confidentiality of your personally identifiable information in accordance with the terms of this Privacy Statement, and will otherwise take reasonable precautions to prevent the unauthorized disclosure or use of your personally identifiable information.

This Web site contains links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.

We send all new members a welcome email with their User ID. Registered users will receive site and service announcement updates, unless they opt to not receive these communications. The bulletins contain important information about the service, and may also include information on new products and special deals. Out of respect for the privacy of our users we present the option to not receive these communications. Please see our choice and opt-out below.

From time-to-time our site may request information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and address), and demographic information (such as zip code or age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

Our users are given the opportunity to opt-out of having their information used for purposes not directly related to our site at the point where we ask for the information.

Users who no longer wish to receive our bulletin may opt-out of receiving these communications by changing their account preferences online, replying to unsubscribe in the subject line in the email, or emailing us at support@bivio.com.

Users of our site are always notified when their information is being collected by any outside parties. We do this so our users can make an informed choice as to whether they should proceed with services that require an outside party, or not.

If we decide to change our privacy policy, we will prominently post those changes so our users are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

This Web site takes every precaution to protect our users' information. When you submit information via the Web site, your information is protected both online and off-line. We maintain physical, electronic and procedural safeguards that comply with applicable law and federal standards.

Access to our site is protected by the Transport Layer Security (TLS) protocol which is the industry standard for secure data transfer software. Its proven protection is among the best software available today for secure online commerce transactions. TLS encrypts your personal information as it travels across the Internet. TLS is used by most Web sites, including online banking sites and other consumer retail sites to protect your information.

We also do everything in our power to protect user information off-line. Only employees who need the information to perform a specific job (for example, our customer service representatives) are granted temporary access to personally identifiable information. All employees are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable information on are kept in a secure environment, inside a locked cabinet.

A cookie is created when a bivio user is authenticated after logging in. A cookie is a piece of data stored on the user's hard drive containing a code which identifies the user to us. As an example, the cookie is used to allow members to access club information, and prevent non-members from accessing this same information.

In order to use bivio, cookies are required. However, only an authentication code is stored in the cookie. No personal information is stored.

Upon logging in, users are given the 'Save Password' option of making their cookie persistent so that they will not be logged out when the browser is closed. This allows users to login only once from computers which are in private locations.

Each time a user views a bivio page, log entries are made. Each log entry includes the exiting URL, referring URL, date/time, user IP address and browser type. Individual usage histories can be reconstructed from the logs. Log entries can also be linked to personally identifiable information. Logs are used to maintain optimal site performance and security, and improve the functionality of the service.

If you have any questions about the privacy or security of your data on bivio, please contact us by email at support@bivio.com, phone at +1 (877) 529-0585, or postal mail at 4800 Baseline Rd., #E-104-336, Boulder, CO 80303-2643.

This privacy statement was revised February 29, 2020.