PRIVACY POLICY
Avalon supports the highest standards of integrity for every online visitor. When you register at the Avalon Site, our goal is to respect your privacy. This Privacy Policy sets forth how we handle information we obtain from you and learn about you when you visit our Site, including:

• The information we collect;
• The choices that are available to you regarding how the information is used and to whom it is disseminated;
• Your rights to access and correct or update your personally-identifiable information; and
• Our pledge to have reasonable security procedures in place to protect against the loss, misuse or alteration of information under our control.

As a user of any of the public portions of the Avalon website, you are not required to provide us with any personal information. We will only collect personal information from you that you provide directly to us in connection with your use of this site and we will use that information only to facilitate your use of this site and the delivery of our services.

Avalon may collect two types of information about you when you visit our site: personal information that you provide (including, by way of example only, your name, address, telephone number and e-mail address) and non-personal, aggregate information (such as information regarding the pages on our site that you have visited and your IP address).

1. Personally-Identifiable Information
The only personally-identifying information we collect and store about you is the information that you choose to provide to us. If you register to use the password-protected portions of our site, we will ask you to provide us with certain information about yourself. If you send us an e-mail, we will use the information to respond to your e-mail. We may also use personally identifiable information to send you notifications about our service. Business partners and professional visitors requesting access to specialized content areas of this Site may be required to provide identifying information.

2. Sharing Your Information
We will not sell your personal information. We may share your personally-identifiable information within Avalon.

To the extent that we may engage unaffiliated companies to assist in providing services on this site, those service providers will be subject to strict contractual requirements to maintain the confidentiality of any personal information that they may obtain in the performance of their services. Those service providers may use personal information only in the course of providing services to Avalon and only for the purposes that we dictate. In addition, we will make every effort to ensure that they receive only the minimum amount of personal information necessary and will be allowed to retain that information only for as long as required for the provision of these services.

3. Non Personally-Identifiable Information:
The Avalon Site may collect non-personally identifiable information during your visit, such as type of browser, operating system, domain name, or IP address. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers -- the computers that support Web pages -- automatically identify your computer by its IP address. When you visit pages on Avalon's Site, our servers log your IP address. We do not link IP addresses to any personally identifiable information. IP address information is used only to improve the service of the Avalon site.

Avalon may also collect information through “referrers” and various environmental variables. A “referrer” is information the Web browser passes along to Avalon's Web server that references the URL from which you came. “Environmental variables” include, among other things, the domain from which you access the Internet, the time you accessed our Site, the type of Web browser and operating system or platform used, the Internet address of the Site you left to visit Avalon, the names of the pages you visit while at our Site, and the Internet address of the Site you then visit. We may collect all of this information to allow us to detect broad demographic trends, to provide information tailored to your interests and to enhance your experience on Avalon's Site. Avalon may store “referrer” information for a limited period of time prior to deleting this information.

To help us improve our Site and to ensure that we make every effort to provide you with information and offers that are of interest to you, we may merge your personally-identifiable information with click-stream data and other data we have (including cookies and off-line data). We will provide notice of this, as well as an opportunity to opt-out of it, at the time and place of information collection and before data is entered on our system.

We may also develop a non-identifiable profile on you based on the pages within our site that you visit.

4. Disclosure
We may disclose information in order to cooperate with legal authorities or to protect our rights and interests and those of our business partners.

We may, when and to the extent appropriate, disclose your personal information to law enforcement or regulatory authorities.

We may also disclose your personal information as necessary to perform credit checks, enforce our legal rights, collect debts or otherwise protect our interests and property.

5. Links
This Site may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to read the privacy statements of each and every Site that they visit. This privacy statement applies solely to information collected when you visit our Site.

Avalon is not responsible for the content, or the privacy practices, of these other web sites. Although we have tried to create a secure and reliable Site for our users, the confidentiality of any communication or material transmitted via our Site or by e-mail cannot be guaranteed. When disclosing any personal information, all users should remain mindful of the fact that it is potentially accessible to others and, consequently, can be collected and used by others without user consent. Accordingly, users should consider carefully if they want to submit sensitive information that they would not want disclosed and should recognize that their use of the Internet and our Site is solely at their own risk. We have no responsibility or liability for the security of personal information transmitted via the Internet. Please see our Legal Terms for more information on the use of our Site.

6. Security

Avalon is committed to protect the privacy and confidentiality of your personal information.

We make every effort to have reasonable security procedures in place to protect the loss, misuse or alteration of information under our control.

Only authorized Avalon employees or agents will have access to your personal information. All of our employees, service providers and marketing partners are held to stringent standards of privacy and security and are bound by confidentiality agreements.

Users of the non-public areas of this Site may be required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password or Personal Identification Number (PIN).

Security is a cooperative effort between Avalon and the users of this site. Please remember that your password and PIN are personal to you and should not be made available to any other person. Also, you should discontinue their use and advise us if you have any reason to suspect that someone else may be using them.

7. Other

Notification of Changes
If we decide to change our privacy policy, we will post those changes on the Site so you will always be aware of what information we collect, how we use it, and under what circumstances we disclose it. We will use information in accordance with the privacy policy under which the information was collected.

Special Policy Regarding Information from Children Under Thirteen
This Site is not targeted to children under the age of 13, and we do not knowingly request personally identifiable information from any child under the age of 13 without parental consent. When we do receive such information, we delete it as soon as we discover it.

LEGAL NOTICES

Terms and Conditions
Please read the following terms and conditions before using the Avalon Group, Ltd. and Avalon Securities, Ltd. (together “Avalon”) Web site (the “Site”). By accessing and using the site, you acknowledge that you have read, understood, and agree to comply with the terms and conditions.

Avalon may amend these terms and conditions at any time. Your continued use of this Site is conditioned on the terms and conditions stated at the time of your use. You should review this material prior to using this Site to determine the current terms and conditions to which you are bound.

Access
This Site and the information, tools and material contained in it are not directed to, or intended for distribution to or use by, any person or entity who is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to law or regulation or which would subject Avalon to any registration or licensing requirement within such jurisdiction.

No Offer
The information, tools and material presented in this Site are provided to you for informational purposes only and are not to be used or considered as an offer to sell or solicitation of an offer to buy securities or other financial instruments, or any advice or recommendation with respect to such securities or other financial instruments. The Site's contents may not be reproduced in whole or in part or otherwise made available without the prior written consent of Avalon. Information and opinions presented in this Site have been obtained or derived from sources believed by Avalon to be reliable, but Avalon makes no representation as to their accuracy or completeness. Avalon accepts no liability for any loss arising from the use of the material presented in this Site. In jurisdictions where Avalon is not registered or licensed to trade in securities, commodities or other financial products, any trade will be made only in accordance with applicable legislation which will vary from jurisdiction to jurisdiction and may require that the trade be made in accordance with applicable exemptions from registration or licensing requirements.

Avalon or its affiliates may, to the extent permitted by law, participate or invest in financing transactions with the issuer(s) of the securities referred to in this Site, perform services for or solicit business from such issuers, and/or have a position or effect transactions in the securities or options thereon. Avalon may, to the extent permitted by law, act upon or use the information or opinions presented herein, or the research or analysis on which they are based before the material is published. Additional information is available on request.

Disclaimer of Warranties
Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied is made regarding future performance. Opinions and estimates reflect a judgment at original date of publication by Avalon and are subject to change. The value and income of any of the securities or financial instruments mentioned in this Site can fall as well as rise. Foreign currency denominated securities and financial instruments are subject to fluctuations in exchange rates that may have a positive or adverse effect on the value, price or income of such securities or financial instruments.

Private placements or structured securities are complex instruments, typically involve a high degree of risk and are intended for sale only to sophisticated investors who are capable of understanding and assuming the risks involved. The market value of any private placements or structured security may be affected by changes in economic, financial and political factors (including, but not limited to, spot and forward interest and exchange rates), time to maturity, market conditions and volatility and the credit quality of any issuer or reference issuer. Any investor interested in purchasing a structured product should conduct its own investigation and analysis of the product and consult with its own professional advisers as to the risks involved in making such a purchase.

This Site is subject to periodic update and revision. Materials should only be considered current as of the date of initial publication appearing thereon, without regard to the date on which you may access the information. Avalon maintains the right to delete or modify information on this Site without prior notice.

Avalon may have issued other reports that are inconsistent with, and reach different conclusions from, the information presented in this Site. Such other reports may reflect different assumptions, views and analytical methods of the professionals who prepared them.

AVALON HEREBY EXPRESSLY DISCLAIMS ALL WARRANTIES, EXPRESS, STATUTORY OR IMPLIED, REGARDING THE SITE, AND ANY RESULTS TO BE OBTAINED FROM THE USE OF THE SITE, INCLUDING BUT NOT LIMITED TO ALL WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR USE, AND ALL WARRANTIES ARISING FROM COURSE OF PERFORMANCE, COURSE OF DEALING AND USAGE OF TRADE OR THEIR EQUIVALENTS UNDER THE LAWS OF ANY JURISDICTION. AVALON DOES NOT WARRANT OR GUARANTEE THE ACCURACY, TIMELINESS, SUITABILITY, COMPLETENESS OR AVAILABILITY OF THIS SITE OR THE INFORMATION OR RESULTS OBTAINED FROM USE OF THIS SITE, OR THAT THIS SITE OR THE INFORMATION OR RESULTS WILL BE FREE FROM ERROR.
UNDER NO CIRCUMSTANCES AND UNDER NO THEORY OF LAW, TORT, CONTRACT, STRICT LIABILITY OR OTHERWISE, SHALL AVALON BE LIABLE TO ANYONE FOR ANY DAMAGES RESULTING FROM ACCESS OR USE OF OR INABILITY TO ACCESS OR USE THIS SITE REGARDLESS OF WHETHER THEY ARE DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY CHARACTER, INCLUDING DAMAGES FOR TRADING LOSSES OR LOST PROFITS, OR FOR ANY CLAIM OR DEMAND BY ANY THIRD PARTY, EVEN IF AVALON KNEW OR HAD REASON TO KNOW OF THE POSSIBILITY OF SUCH DAMAGES, CLAIM OR DEMAND.

Use Restriction
Avalon gives you permission to electronically copy and print in hard copy portions of the Site for your personal use. However, Avalon retains the copyright on all text and graphics. This means that any other use, including, but not limited to, modification, distribution, or republication without Avalon's prior written permission is prohibited.

Corporate Identification and Trademarks
The trademarks expressly listed as such in this Site and all other marks on the Site are trademarks of Avalon and/or its affiliates. You may not use, copy, reproduce, republish, upload, post, transmit, distribute, or modify these marks in any way without Avalon’s prior written permission. The use of Avalon's trademarks on any other Site without Avalon's prior written permission is prohibited.

Links
Avalon prohibits the use of Avalon's trademarks as a "link" on or to any other Site unless Avalon has approved the link in writing in advance.

Site Context
Unless expressly provided otherwise, Avalon provides the content on this Site "AS IS" and WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, TO THE FULLEST EXTENT ALLOWABLE BY LAW. THIS INCLUDES ANY IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. Avalon does not warrant uninterrupted or error free functions contained in this Site or its content or that the Site or its server are free of viruses or other harmful components.

Limitation of Liability
Avalon makes reasonable efforts to place accurate information on this Site. However, Avalon assumes no liability for any errors or omissions in the Site content. Under no circumstances shall Avalon be liable for direct, incidental, consequential, special, or punitive damages resulting from the use or inability to use this site, whether Avalon has been advised of the possibility of these damages. This includes damages for negligence or gross negligence.

Jurisdiction and Governing Law
This site is intended and directed to residents of the United States and all advertising and claims contained in this site are valid only in the United States.

Any claim relating to this Site and the materials contained in this Site is governed by the laws of the state of New York without reference to its conflicts of law rules. Your use of this site constitutes your consent to jurisdiction in courts of competent jurisdiction in the state of New York to resolve any interpretation or disputes arising from your use of this site.

Copyright
All designs, graphics, texts, arrangements, and software that make up this Site are Copyright of Avalon. All rights reserved.