Robbins Capital Management Respects Your Privacy

Robbins Capital Management and its subsidiaries respect your privacy and are committed to protecting it. Robbins Capital Management provides this Privacy Statement to inform you of our Privacy Policy and practices and of the choices you can make about the way your information is collected online and how that information is used. We've structured our websites so that, in general, you can visit Robbins Capital Management on the Web without identifying yourself or revealing any personal information. We make this notice readily available on our home page and at the bottom of every Robbins Capital Management Web page. Robbins Capital Management has also self-certified its privacy practices as consistent with U.S.-E.U. Safe Harbor principles: Notice, Choice, Onward Transfer, Access and Accuracy, Security, and Oversight/Enforcement. More information about the U.S. Department of Commerce Safe Harbor Program can be found at http://www.export.gov/safeharbor/. Sites covered by this privacy statement This Privacy Statement applies to all robbinscapitalmanagement.com-owned websites and domains, and our wholly owned subsidiaries ("Robbins Capital Management websites."). Links to non-Robbins Capital Management websites The Robbins Capital Management websites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the Robbins Capital Management website. Robbins Capital Management does not control those sites or their privacy practices, which may differ from Robbins Capital Management's. We do not endorse or make any representations about third-party websites. The personal data you choose to give to unrelated third parties is not covered by the Robbins Capital Management Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information. Some third-party companies may choose to share their personal data with Robbins Capital Management; that sharing is governed by that third-party company's privacy policy.   Types of information we collect This Privacy Statement covers personal information, non-personal data collection and aggregate reporting. Personal information is information that is associated with your name or personal identity. Robbins Capital Management uses personal information to understand better your needs and interests and to provide you with better service. Once you choose to provide us with personal information, you can be assured it will be used only to support your customer relationship with Robbins Capital Management. We take seriously the trust you place in us. Robbins Capital Management will not sell, rent or lease your personal information to others. On some Robbins Capital Management websites, you can order products or services, request information, subscribe to marketing or support materials, or register yourself or your Robbins Capital Management products. The types of personal information you provide to us on these pages may include name, address, phone number, e-mail address, user IDs and passwords, billing and transaction information, credit card information, contact preferences, educational and employment background, and job interest data. To personalize our websites, services or communications and improve our products and services, we may also ask you to provide us with information regarding your personal or professional interests, demographics, and experiences with our products or services. Providing this additional information is optional. Non-personal information is data about usage and service operation that is not associated with a specific personal identity. Robbins Capital Management collects and analyzes non-personal information to evaluate how visitors use the Robbins Capital Management websites. Non-personal data we collect may include the pages visited on the Robbins Capital Management websites, unique URLs1 visited within robbinscapitalmanagement.com, browser type and IP2 address. Most non-personal data is collected via cookies or other analysis technologies. robbinscapitalmanagement.com Web pages use cookies and other technologies for data analysis and personalization services. Robbins Capital Management also places ads on other websites that may use cookies. To learn more, read Robbins Capital Management use of cookies.   Children's privacy Robbins Capital Management is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Robbins Capital Management does not knowingly collect information from children under the age of 13 and Robbins Capital Management does not target its websites to children under 13.   How we use your information Robbins Capital Management uses your personal information to provide you with services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to provide service and support, to update you on services and benefits, to personalize promotional offers and to personalize some Robbins Capital Management websites. Occasionally we may also use your information to contact you for market research regarding Robbins Capital Management products or services. We will give you the opportunity to choose your privacy preferences regarding such communications (see section 7, "Your privacy preferences and opting out"). Credit card information is used only for payment processing and fraud prevention. Sensitive personal information is collected only to facilitate our financial service providers' credit decisions and will be shared with them only with your permission. Credit card information and sensitive personal data are not used for any other purpose by our financial services providers or Robbins Capital Management and will not be kept longer than necessary for providing the services, unless you ask us to retain your credit card information for future purchases. Personal data collected online may also be combined with information you provide Robbins Capital Management through other sources such as product registration, call centers or public events such as trade shows or seminars. Personal data given to Robbins Capital Management may be transferred across state and country borders for the purposes of data consolidation, storage and simplified customer information management. Non-personal data is aggregated for reporting about Robbins Capital Management website usability, performance and effectiveness. It is used to improve the customer experience, usability and site content.   Who we share your information with Robbins Capital Management will not sell, rent or lease your personal information to others. Robbins Capital Management will not share your personal information with third parties except in responding to your requests for products or services. Your permission will be requested when you submit your information. Robbins Capital Management shares customer information across Robbins Capital Management-owned business entities and companies working on our behalf, but only as described above in "How we use your information." Robbins Capital Management occasionally contracts with third-party service providers and suppliers to deliver complete products, services and customer solutions described in "How we use your information." Suppliers and service providers are required to keep confidential the information received on behalf of Robbins Capital Management and may not use it for any purpose other than to carry out the services they are performing for Robbins Capital Management. These service providers may change or we may contract with additional service providers to better accommodate our customers. Robbins Capital Management will not share personal information with any other third parties without your permission, unless required by law enforcement action, subpoena, or local law. Robbins Capital Management or its related entities could merge with or be acquired by another business entity or some or all of their respective assets could be acquired. If such a combination or acquisition occurs, Robbins Capital Management will make every reasonable effort to notify you in the event we share with the merging or acquiring entity some or all of your personal information to continue serving you.   Your choices Robbins Capital Management gives you the choice of receiving a variety of information that complements our products and services. You can subscribe to receive certain product- and service-specific information and Robbins Capital Management-wide marketing communications. Robbins Capital Management-wide communications may include new product information, special offers, or an invitation to participate in market research via email.  This option does not apply to communications for the purpose of administering order completion, contracts, support, product safety warnings or driver updates.   Your privacy preferences and opting out Non-subscription services Robbins Capital Management will not use your personal information for a different purpose than the one stated when you provided your data. Examples of unrelated uses include sending communications about special offers, product information, and marketing messages.   Subscription services To opt-out of receiving communications you have expressly requested (such as e-mail newsletters, software updates, etc.), use any of the following methods: Select the e-mail "opt-out" or "unsubscribe" link, or follow the opt-out instructions included in each subscription communication. Return to the Web page(s) where you originally registered your preferences and follow the opt-out instructions. Write to Robbins Capital Management - be sure to provide your name, e-mail and postal address, and relevant information about your Robbins Capital Management subscriptions and registrations.   Your information and third-party companies Certain Robbins Capital Management services are linked with those from unrelated third-party companies, some which offer you the option to share with both Robbins Capital Management and the third party personal data you provide. Examples include the ability to register software products from multiple vendors from a single Robbins Capital Management Web page, to request communications from Robbins Capital Management marketing or solution partners, or to enable order completion through a reseller. We will not share your personal information with those third-party companies unless you make that choice.   Access to and accuracy of your information Robbins Capital Management strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain customer data accuracy. We will provide you with access to your information, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data. Certain areas of Robbins Capital Management's websites may limit access to specific individuals through the use of passwords and other personal identifiers.   Keeping your information secure Robbins Capital Management is committed to protecting the information you provide us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, Robbins Capital Management has in place appropriate physical and managerial procedures to safeguard the information we collect. We use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data such as credit card information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the bottom of your browser window. Credit card numbers are used only for processing payment and are not used for other purposes.   Changes to this Statement If there are updates to the terms of Robbins Capital Management's Online Privacy Statement, we will post those changes and update the revision date in this document, so you will always know what information we collect online, how we use it, and what choices you have. For material changes to this Statement, Robbins Capital Management will provide notification to affected customers.   Contacting us We value your opinions. If you have comments or questions about our privacy policy, please email us or write to us at the following address: Robbins Capital Management 2922 Mabry Lane Atlanta, Georgia 30319   Phone:  (404) 995-8558   How Robbins Capital Management uses cookies on robbinscapitalmanagement.com and in third-party ads: Cookies A “cookie” is a small data file transferred by a website to your computer’s hard drive. Robbins Capital Management sends cookies when you surf our site, make purchases, request or personalize information, or register yourself for certain services. Accepting the cookies used on our site does not give us access to your personal information, but we may use the cookies to identify your computer. Cookies are typically classified as either “session” cookies or “permanent” cookies. “Session” cookies do not stay on your computer after you leave our website or close your browser. The aggregate information collected permits us to analyze traffic patterns on our site. This can enable us over time to provide a better experience on our site by improving content or personalization and making our site easier to use. “Permanent” cookies are those that remain on your computer. They are used to facilitate shopping, personalization and registration services. For example, cookies can keep track of what you have selected to purchase as you continue to shop and allow you to enter your password only once on Web pages where a login is required. “Permanent” cookies can be manually removed by the user. Most browsers automatically accept cookies by default, but you can usually refuse cookies or selectively accept certain cookies by adjusting the preferences in your browser. If you turn off cookies, there may be some features of our site that will not be available to you and some Web pages may not display properly. You can find information on popular browsers and how to adjust your cookie preferences at the following websites: Microsoft Internet Explorer: http://www.microsoft.com/info/cookies.htm Netscape Navigator: http://www.netscape.com/legal_notices/cookies.html   Web Beacons Currently no robbinscapitalmanagement.com web pages or HTML-formatted e-mail newsletters use Web beacons in conjunction with cookies to compile aggregate statistics about website usage. A Web beacon is an electronic image, called a single-pixel (1x1) or clear GIF. Web beacons can recognize certain types of information on a visitor's computer, such as a visitor's cookie number, time and date of a page view, and a description of the page where the Web beacon is placed. You may render some Web beacons unusable by rejecting their associated cookies.   Third Party Robbins Capital Management may occasionally post third-party ads on its website.  Robbins Capital Management may use third-party media companies to place ads for Robbins Capital Management products or services on other companies’ websites. If you view a Web page where Robbins Capital Management ads appear, the online media company may place a cookie or Web beacon on your computer. This allows the online media company to recognize the computer when it is used to return to that site, or to measure advertising response. This data is anonymous and is not linked to personal data on the user’s computer or any Robbins Capital Management databases. Some Robbins Capital Management newsletters delivered on Robbins Capital Management’s behalf by online media companies use the same technologies. In both cases, this data is also used by the online media company to measure advertising and content interest and relevance. Robbins Capital Management does not have access to the data collected by the online media company. To prevent online media companies from placing cookies on your computer, you will need to visit each media company’s website and use their cookie removal process or set your browser cookie filter accordingly. Rev. June 2004 1.  A URL (Uniform Resource Locator) is the global address of documents and other resources on the World Wide Web. For example, http://www.www.robbinscapitalmanagement.com is the URL for Robbins Capital Management's U.S. home page. 2.  An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, such as the World Wide Web. Networks use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet, browse and shop. Using this site means you accept the terms of Robbins Capital Management's Privacy Statement.