While Betterlab® has always considered the confidentiality of sensitive information to be sound business practice, in keeping with the applicable privacy rules and regulations, Betterlab® seeks to ensure the proper handling of non-public information relating to individual persons. In general, Betterlab® restricts access of current, former and prospective investors’ nonpublic personal information to our personnel, our affiliates and their personnel, our outside counsel and our outside auditors who need to know that information in order to (i) ensure compliance with applicable laws and regulations or (ii) provide products or services to our investors.

Betterlab® shall provide an initial privacy notice and an annual privacy notice to all of its clients not less than annually during the duration of the client relationship. Betterlab® shall maintain the practices, policies and protections that its privacy notices represent it will provide.

The information included on secure pages of the Site is confidential and is exclusively for the use of the Authorized User to whom access was granted. Authorized Users are responsible for maintaining the confidentiality of user names and passwords once they are issued.

The Site may provide links to third-party websites operated under privacy practices which may differ from our own privacy practices. This Privacy Policy does not cover any personal data that you choose to give to unrelated third parties.

Users can access and browse the Site without disclosing personal information. If you voluntarily submit information to the Site, Betterlab® may record and use any personally identifiable information, including name, address, telephone number, email address, a unique login name and a password. In addition, Betterlab® may collect nonpublic personal information about current and prospective investors from the following sources: information we receive from current and prospective investors on subscription documents and related forms (for example, name, address, social security number, birth date, assets, income, investment experience); and information about investors’ transactions with Betterlab®. Betterlab® uses this information for its internal business purposes, including to facilitate your relationship with us, as permitted by law or regulation.

Betterlab® may use internal or third-party service providers to operate the Site and may employ other persons to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to the personally identifiable information submitted through the Site, but only for the purpose of performing their duties. These persons may not use your personally identifiable information for any other purpose.

Betterlab® will not share non-public personal information with any other third parties without your permission, unless required by law enforcement action, subpoena, local law or when we reasonably believe that such disclosure is necessary to protect our systems, our business or the rights of others, or as otherwise provided in this Privacy Policy.

The Site may collect data through a variety of different methods. For instance, we may automatically log data by means of programming and we may link certain information as well. The Site may collect non-personal technical information about your session, such as your browser type, Internet service provider, platform type, internet protocol (IP) addresses, referring/exit pages, operating system, date/time stamp. If we use this information at all, it will be on an aggregate basis (which does not identify individual users) to analyze trends, diagnose problems with our server and administer the Site, to track user movement and use, and to gather broad demographic information. The Site may employ cookies.

Betterlab® follows generally accepted industry standards to protect the security of personal information submitted to us, both during transmission and once it is received. However, Betterlab® cannot guarantee or warrant the security of our servers nor can we guarantee that information you supply through the Site will not be intercepted while being transmitted over the Internet.

If, at any time in the future, it is necessary to disclose any of an investor’s personal information in a way that is inconsistent with this Privacy Policy, we will give advance notice of the proposed change so that the investor will have the opportunity to “opt out” of such disclosure. If there are updates to the terms of this Privacy Policy, we will post those changes and update the revision date in this document. By continuing to use the Site after any changes are posted, you acknowledge your acceptance of such changes.