E.U. – U.S. and Swiss – U.S. Privacy Shield Policy

Effective day October 1, 2018

We, AMZ Advisers, LLC (“AMZ Advisers” “we” or “us”), are committed to protecting your
privacy. This Policy sets out the privacy principles we follow with respect to transfers of
personal data from the European Economic Area (“EEA”) and Switzerland to the United
States, including personal data we receive from individuals residing in the EEA or
Switzerland who visit our web and mobile sites or apps and/or who use any of our
services or otherwise interact with us (“you”).

AMZ Advisers, LLC complies with the EU-US Privacy Shield Framework and the Swiss-
US Privacy Shield Framework as set forth by the US Department of Commerce
regarding the collection, use, and retention of personal information transferred from the
European Union and Switzerland to the United States.
AMZ Advisers has certified to the Department of Commerce that it adheres to the
Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn
more about the Privacy Shield program, and to view our certification page, please
https://amzadvisers.com/eu_swiss_privacy/ With respect to personal data received or transferred pursuant to the Privacy Shield
Frameworks, AMZ Advisers is subject to the regulatory enforcement powers of the U.S.
Federal Trade Commission (FTC).

Section 1.  Types of personal data we collect and use

Our online privacy policy located at https://amzadvisers.com/privacy/ describes
the categories of personal data we may receive in the United States, as well as the
purposes for which we use that personal data. We will only process personal data in
ways that are compatible with the purpose we collected it for, or for the purposes you
later authorize. Before we use your personal data for a purpose that is materially
different from the purpose we collected it for or that you later authorized, we will
provide you with the opportunity to opt-out. We maintain reasonable procedures to
help ensure that personal data we collect, and use is reliable for its intended use,
accurate, complete, and current.

Section 2. Data transfers to third parties
●Agents, consultants and service providers: We may share your personal data with our contractors and service providers who process personal data on our behalf to perform certain business-related functions. These companies include database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including personal data, in connection with their performance of such functions.

● Our Group Companies: We may also share your personal data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Policy.

● Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.

● Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

● Legal Requirements: We may disclose your personal data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency ,or in the good faith belief that such action is necessary (a) to comply with a legal obligation, (b) to protect or defend our rights, interests or property or that of third parties, (c) to prevent or investigate possible wrongdoing in connection with the Services, (d) to act in urgent circumstances to protect the personal safety of Users of the Services or the public; or (e) to protect against legal liability. AMZ Advisers’ accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, AMZ Advisers remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless AMZ Advisers proves that it is not responsible for the event giving rise to the damage. AMZ Advisers is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Section 3. – Security
We maintain reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
Section 4. Access Rights
In general, when processing personal data to provide our services, we do so only on behalf of our customers and in accordance with their instructions. This means that if you wish to access any personal data we process on behalf of a AMZ Advisers customer and request that we correct, amend, delete it if it is inaccurate or processed in violation of Privacy Shield, you should contact that customer with your request. We will then help them to fulfill that request in accordance with their instructions.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also may correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should submit a written request to   [email protected]  If requested to remove data, we will respond within a reasonable timeframe.

These access rights may not apply in some cases, including where providing access isunreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Section 5. Your Choices

You may choose to change personal data or cancel an account by contacting us using
the contact details below. You can also unsubscribe from our marketing
communications by following the instructions or unsubscribe mechanism in the e-mail message.
We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to  [email protected]

Section 6. Questions or complaints

In compliance with the Privacy Shield Principles, AMZ Advisers commits to resolve
complaints about our collection or use of your personal information. European Union
and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy
should first contact us by email at [email protected]. We will investigate and
attempt to resolve any complaints or disputes regarding the use or disclosure of
personal data within 45 days of receiving your complaint.

AMZ Advisers has further committed to refer unresolved privacy complaints to, the BBB
EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus (the “BBB”),
an alternative dispute resolution provider located in the United States. If you do not
receive timely acknowledgment of your complaint from us, or if we have not addressed
your complaint to your satisfaction, please visit www.bbb.org/EU-privacy-shield/for-

eu-consumers for more information or to file a complaint. This services of the BBB are
provided at no cost to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not
resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Section 7. How to Contact Us

¡If you have any questions regarding this Policy or if you need to request access to or update, change or remove personal data that we control, you can do so by contacting
us at [email protected]

Changes to this Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy
Shield’s requirements.