IvyLine Capital Advisors, LLC
PRIVACY POLICY
Last Updated on June 6, 2018
IVYLINE CAPITAL PRIVACY POLICY 

Last updated June 4, 2018

The IvyLine privacy policy (the “Privacy Policy”) is intended to inform you of our  policies and practices regarding the collection, use and disclosure of any information you submit to us through the IvyLine research network. By using our Web Site (the  “Site”), you agree that this Privacy Policy will govern your use of our Site and any dispute over our privacy issues. IvyLine Capital Advisors, LLC d/b/a IvyLine the provider of the Site www.ivylinecapital-commentaries.com (referred to as “IvyLine,” “us” or “we”), is committed to protecting your privacy online. We recognize your need for appropriate protection and management of any information you share with us. As such, IvyLine respects the privacy of registered users (collectively referred to 
as "users"), particularly with regard to the storage, access, and use of personally  identifiable data collected online. Secured information on www.ivylinecapital-commentaries.com will be maintained by IvyLine and, except as set forth herein, at no time will we permit anyone to access your confidential information. 

Collection of Information
Ivylinecapital-commentaries.com collects data from users in the following ways:
• During the process of subscribing to become a user
• When speaking to a representative on the phone
• When chatting to a representative on-line
• When signing up for any of our contests or other promotions
• Referrals
• In e-mails sent to/from IvyLine to/from users
• Through automated means such as communications protocols and cookies
Personally Identifiable Information That You Provide  “Personally Identifiable Information or PM” is information that identifies a specific End User, such as your name, e-mail address, user identification number and other nonpublic information that is associated with you. Currently, we do not require you to provide Personally Identifiable Information in order to have access to the free content available on our Site. However, in order to provide you with some of the Site’s services, you must elect to become a registered subscriber at zero cost. As a registrant, you must create a profile and provide a valid email address. You may also be asked for your first and last name, street address, zip code, date of birth, and country of residence. Providing your email address enables us to send you email notices about us, our content, and our offers. If you purchase a service from us in our online store, you must also provide your full mailing address. We use Personally Identifiable Information to provide additional content to you. We also use Personally Identifiable Information to administer contests, enhance the operation of the Site, improve our marketing and promotional efforts, analyze Site use, improve our offerings, and to tailor your experience with third parties. Such information may also be used to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Website Terms of Use and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities. 
Non-Personally Identifiable Information
Also referred to as “Anonymous Information,” “Non-Personally Identifiable Information”  is information that is not associated with or linked to Personally Identifiable Information and does not permit the identification of individual persons by itself. This type of information may include things like the Uniform Resource Locator (“URL”) of the page you visited before and/or after coming to our Site, the links you clicked on, the type of 
browser you are using and your Internet Protocol (“IP”) address. We, and/or our  authorized third-party service providers (“Third-Party Service Providers”), may  automatically collect this information when you visit our Site and as you navigate through our Site through the use of electronic tools (see Information Collected Via Technology below). We use Non-Personally Identifiable Information to troubleshoot, 
administer the Site, analyze trends, and gather demographic information, measure traffic patterns and user interest on our Site, to improve the Site, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third-Party Service Providers to measure the overall effectiveness of our online advertising, content, and distribution. 
E-Mail And E-Mail Addresses  
If you send e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files, and other information you provide. Additionally, we may use your email address to contact you for things such as notifications of limited offers and other related information if you have opted in to receive such notifications. You may indicate your preference to stop receiving further promotional communications at any time by choosing to opt-out. To do so you will need to unsubscribe when you receive a promotional e-mail or contact our customer service personnel at info@ivylinecapital.com . Our Terms of Use govern your submission of materials to us (https://www.IvyLine.com/).- reference disclosure page 

Information Collected Via Technology
IvyLine receives data from you as part of the standard communication connection.  As you use ivylinecapital-commentaries.com, certain information may also be passively collected and stored on our or our service providers’ server logs. This information often consists of network routing (where you came from), equipment information (browser type and operating system), date and time, IvyLine will check requests you make to IvyLine services to see if there are any "cookies" accompanying those requests. Cookies are small pieces of information that a web site sends to your computer’s hard drive while you are viewing that website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience with IvyLine. IvyLine uses cookies to collect information about users’ identities as they interact with the Site and to manage personalized settings on the Site. Cookies provide a convenience for users by creating a more streamlined login process, keeping track of transactions, and preserving order information between sessions. The information collected from cookies is used to improve the functionality of IvyLine.com by avoiding 
duplicate data entry, facilitating navigation, increasing the relevance of content and enhancing security. 
Cookies on www.ivylinecapital-commentaries may collect the following information: a unique identifier, user preferences and profile information to personalize content, and membership information to access specific services on www.ivyLinecapital.com.  You can set your browser to alert you when a cookie is being used, the duration of the cookie, and to inform you of where your information is being returned. You then have the opportunity to accept or reject the cookie. Additionally, you may set your browser to refuse all cookies or accept only cookies returned to the originating servers. Persistent Cookies can be removed by following your Internet browser help file directions. Users may generally disable the cookie feature on their browser without affecting their ability to use www.ivyLinecapital.com, except in some cases where cookies are used as an essential feature to allow the successful completion of a transaction. However, disabling cookies may limit your use of many convenience features offered by www.ivylinecapital-commentaries.com . We may use other industry standard technologies like pixel tags and web beacons to track your use of our Site pages and promotions, or we may allow our Third-Party Service Providers and/or Marketing Partners (entities associated with IvyLine that receive compensation for referrals on a per customer basis) to use these devices on our behalf.  Pixel tags and web beacons are tiny graphic images placed on certain pages on our Site, or in our emails that allow us to measure and improve our understanding of visitor traffic and behavior on our Site, as well as give us a way to measure our promotions and performance. Pixel tags and web beacons are not used to access users’ Personally Identifiable Information; they are a technique we may use to compile 
aggregated statistics about Site usage. You may not decline pixel tags and web  beacons, however, they can be rendered ineffective by declining all cookies or modifying your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. 

How We Use Information  
With your approval, we collect and use the information you provide us in the following ways: 
• To establish identity of the user. Contact information (Pll) is collected at  the user level during the process of subscribing and when your purchase or redeem a product or service. 
• To provide notice of our services and support. Contact information and  customer age is collected. This information is used to provide IvyLine registrants with free commentary and content, guest interview and 
scheduled events reminders, trade idea alerts, and updates on products and service offerings in the online store, and notices of changes in usage and other policies.  
• To better tailor our marketing to user needs. Information on IvyLine.com use is analyzed to help us create website content and functionality that is relevant and user friendly in order to enhance the 
overall user experience.  
We seek to have long-term relationships with our users. Thus, we do not wish to profit from the unwanted distribution of your private information or to inundate you with unnecessary e-mails or other material. You can unsubscribe from these e-mails at any time by e-mail at info@ivylinecapital.com. This process usually completes within 72 hours but can take up to 10 days in rare situations. However, if you later register for ivylinecapital-commentary.com again, your name will be removed from the Unsubscribed List. We will not share, sell, rent, or trade your Personally Identifiable Information with other parties except as provided below: 
Data Protection and Privacy 
Any time you call IvyLine customer service, we may request that you provide identification information such as your home address, phone number, and zip code. We will use this data to facilitate and process refunds, to detect fraud and to comply with applicable laws and regulations. Authorized Third-Party Service Providers 
We provide services and products through third parties. These “Third-Party Service  Providers” perform functions on our behalf, like sending out and distributing our administrative and promotional emails, administering contests, removing repetitive information on customer lists, analyzing data, providing marketing assistance, search results and links, operating the Website, troubleshooting, and providing customer service. We may share your Personally Identifiable Information with Service Providers to accomplish our administrative tasks. We require our Third-Party Service Providers to agree not to use your Personally Identifiable Information, except to the extent necessary to perform the services we have engaged them to perform. We may also collect personal information about you from individuals and companies (“Affiliates”) with whom we have business relationships. 

Third-Party Payment Processors
IvyLine does not collect or store payment data. We utilize third-party payment  processors. As users shop on our site, they click a button to pay using their bank account, credit card, debit card or PayPal account. In all cases, they are taken to a secure, third- party-hosted page. Payment information is protected during transmission from the user directly to the third-party payment processor by a Secure Sockets Layer (SSL) connection. Once stored, this information is protected through various security measures in place at the credit card processor’s data center. Third-party payment processors must annually attest to maintaining Payment Card Industry (“PCI”) Data Security Standard (“DSS”) compliance. This includes building and sustaining a secure network to protect payment card and cardholder information, encrypting data in transit, 
implementing strong access control measures and regularly monitoring and testing  networks and technological elements such as firewalls to meet security requirements. Security and Sharing of Information 
We take security seriously and take numerous precautions to protect the security of  Personally Identifiable Information. At any time, a user can edit his or her own personal information and view his or her own website activity on the user’s tasty profile page. You can access your Personally Identifiable Information on our Website through a password and your email address. This password is encrypted. We recommend that 
you do not share your password with anyone. In addition, your Personally Identifiable  Information resides on a secure server that only selected personnel and contractors have access to. We encrypt certain sensitive information using Secure Socket Layer (SSL) technology while communicating with your computer to ensure that your Personally Identifiable Information is safe as it is transmitted to us. We also encrypt personally identifiable information stored in backups of our database so that the data is not easily accessible while being stored offline. We also use Third-Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our Users to administer our Website and constantly improve its quality. We may also publish this information for promotional purposes. We may disclose this information to any of our business partners, advertisers and other third parties as we may choose. Please note that this is 
not Personally Identifiable Information, only general summaries of the activities of our  Users. Such data is collected on our behalf, and is owned and used by us. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Likewise, IvyLine may be required to store some sensitive data in relation to our transactions with you as a result of our internal records requirements, as dictated by financial regulations or as dictated by state or federal law. Such data will also be encrypted in storage, but no encryption system is 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, we cannot guarantee the security of any information transmitted to or from the Website, and are not responsible 
for the actions of any third parties that may receive any such information.  IvyLine does permit third-party advertising on our Site. We may remarket your information. Remarketing is a way for us to connect with users using a variety of advertising networks, based upon your past interactions with the Site. We may hire 
third- party marketing vendors to perform remarketing services. As a result, third-party  vendors may show IvyLine ads on sites you visit on the Internet. We may share your information in a Business Transfer. As with any other business, we could merge with or be acquired by another company. If this occurs, the successor 
company would acquire the information we maintain, including Personally Identifiable  Information. However, Personally Identifiable Information would remain subject to this  Privacy Policy. We may share your information for our Protection and the Protection of Others. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Website; to cooperate with law enforcement; enforce or apply this Privacy Policy, our Website Terms of Use or other agreements; or protect the rights, property or safety of the Website, its Users or others.  

Links to Other Sites
Our Site may contain links to other sites. Other sites may also reference or link to our  Site. We are not responsible for the privacy practices or the content of such other sites. This Privacy Policy only addresses the use and disclosure of information we collect from you on https://ivylinecapital.com and https://ivylinecapital-commentaries.com.  Other websites that may be accessible through this Site have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you review the website’s privacy policy. 

Children
Minors under the age of 18 may not use the Website. We do not intentionally collect or
maintain personally identifiable information about anyone under the age of 18. If we
obtain actual knowledge that a user is under 18, we will take steps to remove that user's
Personally Identifiable Information permanently from our databases. By using our Website, you represent to us that you are 18 years of age or older.

Changes to Privacy Policy
If we decide to change our privacy policy, we will post those changes to this privacy  statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of notice on our home page. We will note the date of the most recent changes in the beginning of our Privacy Policy under “Last Updated.” 

Your California Privacy Rights 
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to the address below. This privacy policy is incorporated into and is a part of the IvyLine Terms of Use. Contacting Us IvyLine Capital 

IMPORTANT UPDATES AND DISCLOSURES UNDER THE GENERAL DATA PROTECTION REGULATION OR (GDPR)
Transferring "Personal Data"  From the European Union
"Personal Data" that we collect and receive from your submission may be stored on our database, processed, and transferred between any of the countries in which we operate. The European Union does not find the United States of America and numerous other countries to have an adequate level of personal data protection of "Personal Data" under Article 45 of the GDPR. Our company relies on actual derogations for specific situations as defined in Article 49 of the GDPR. For European Union customers and users, with your consent, your "Personal Data" may be transferred outside the European Union to the United States and other countries. We will use your "Personal Data" to provide the services, memberships, and/or information you request from us to perform a contract with you or to satisfy a legitimate interest of our company in a ethical manner that does not outweigh your rights. Wherever we transfer, process or store your "Personal Data", we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our website, services, or memberships, you agree and give consent to the transfers of your "Personal Data" described within this section.

Your Data Protection Rights Under General Data Protection Regulation (GDPR):

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. IvyLine Capital aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:
1) The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your "Personal Data" by emailing info@ivylinecapital.com. 
2) The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
3) The right to object. You have the right to object to our processing of your Personal Data.
4) The right of restriction. You have the right to request that we restrict the processing of your personal information.
5) The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
6) The right to withdraw consent. You also have the right to withdraw your consent at any time where IvyLine Capital Advisors, LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).



IvyLine Capital Advisors, LLC
205 Weldon 
Mount Joy, PA 17552
Customer Service Inquiries | info@ivylinecapital.com
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IvyLine Capital Advisors, LLC  - All Rights Reserved