Privacy

Effective as of April, 2012

Introduction

This privacy statement applies to Global Atlantic Partners LLC and its subsidiaries (the “Global Atlantic Partners U.S. Entities”).

If you as a visitor choose to register or submit information to the Global Atlantic Partners Entities via this website (the “Global Atlantic Partners U.S. website”), you agree to the use of such data in accordance with this privacy statement. Please note that the Global Atlantic Partners website contains links to other websites, including, without limitation, websites maintained by Global Atlantic Partners LLC, other member firms of Global Atlantic Partners LLC, which are not governed by this privacy statement. Also note that the Global Atlantic Partners U.S. Entities may use third parties to host all or portions of, or to assist in maintaining, the Global Atlantic Partners U.S. website.

If you have any questions regarding this privacy statement, or do not feel that your concerns have been addressed, please direct your questions to the webmaster of the Global Atlantic Partners U.S. website using the e-mail us link.

Information Collection

As a visitor, you do not have to submit any personally identifiable information in order to use the Global Atlantic Partners U.S. website. Personally identifiable information is not collected via the Global Atlantic Partners U.S. website unless it is specifically and voluntarily provided by visitors. Such information may consist of, but is not limited to, your name, current job title, company address, email address and telephone and fax numbers.

As a general rule, sensitive information (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) is not collected from visitors to the Global Atlantic Partners U.S. website. We will, where necessary, obtain visitors’ explicit consent to collect and use such information.

Cookies and Web Beacons

To ensure that the Global Atlantic Partners U.S. website is well managed and to facilitate improved navigation within it, cookies (small text files stored in a user’s browser) or Web beacons (electronic images that allow websites to count visitors who have accessed a particular page and to access certain cookies) are used on the Global Atlantic Partners U.S. website to collect aggregate data. Cookies and Web beacons may be used to track information and identify categories of visitors by items such as IP address, domain, browser type and pages visited. This information is used to analyze the number of visitors to different areas of the Global Atlantic Partners U.S. website to make sure that it is serving as a useful, effective information source.

These cookies and web beacons are not used to collect any personally identifiable information such as your name or e-mail address. Further, most browsers permit individuals to decline cookies. However, under specific circumstances, visitors may be denied access to some parts of the Global Atlantic Partners U.S. website if their browsers are set to decline cookies.

Information Use

Personally identifiable information submitted via the Global Atlantic Partners U.S. website is used only for limited purposes. For example, when you register to gain access to premium content, attend a hosted event, respond to a survey or request future communications about specific areas of interest, the information you submit may be used to respond to you: to create a personal profile that will allow the Global Atlantic Partners U.S. Entities to manage their relationship with you, such as providing you with information they feel would be of interest to you or to facilitate responding to further requests or inquiries from you: or to personalize your website experience. In addition, the webmasters may, where necessary, use your information for various site related tasks.

You may at any time request to be removed from emails or other communications generated in response to your registration on the Global Atlantic Partners U.S. website.

Disclosure of Information to Third Parties

Personally identifiable information may be provided to third party service providers for processing purposes or in connection with a third party service provider’s hosting or maintaining the Global Atlantic Partners U.S. website, but such information will not otherwise be shared with third parties unless so disclosed at the point of collection. Personally identifiable information may be transmitted internationally to third parties for the purposes identified above. This may include transfer to countries without data protection rules similar to those in effect in your country of residence. By providing information to the Global Atlantic Partners U.S. website, you are consenting to such transfers.

Where appropriate, personally identifiable information may be disclosed to law enforcement, regulatory or other government agencies, or third parties where necessary or desirable to comply with legal or regulatory obligations or requests or for the purposes identified above.

User Profiles

Visitors may review the personally identifiable information they have submitted to the Global Atlantic Partners U.S. website and correct any inaccuracies by accessing their user profile. In their user profile, they may correct and update their details, or delete their profile at any time.

Visitors who have any problem accessing their profiles, or would like to request a copy of the personal information contained in their user profiles, should contact the webmaster of the Global Atlantic Partners U.S. website using the e-mail us link. In all cases we will treat requests to access information or change information in accordance with applicable legal requirements.

Information Security

We have in place reasonable commercial standards of technology and operational security designed to protect all personally identifiable information provided by visitors via the Global Atlantic Partners U.S. website from unauthorized third party access.

Changes to our Privacy Policy

Global Atlantic Partners LLC reserves the right to modify or amend this privacy statement at any time and for any reason. Nothing contained herein creates or is intended to create a contract or agreement between the Global Atlantic Partners U.S. Entities and any user visiting the Global Atlantic Partners U.S. website or providing identifying information of any kind.

Children’s Privacy Protection

Global Atlantic Partners LLC understands the importance of protecting children’s privacy in the interactive online world. The Global Atlantic Partners U.S. website covered by this privacy policy is not designed for or intentionally targeted at children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.

Visitors’ Questions

If you have any questions or concerns regarding your privacy while using the Global Atlantic Partners U.S website, please direct them to the webmaster of the Global Atlantic Partners U.S. website using the e-mail us link.