Privacy policy - Securing Your Financial Future

Working Hard to Keep Pace with very heigh Demand

How we handle your data The privacy practices of this Website Privacy Policy apply to our services available under the domain and subdomains of www.axtoltrades.com (the “Website”). We recognize that privacy is important to our users, so we design and operate our Website with the protection of your privacy in mind. This Website Privacy Policy outlines the types of personal information we may gather when you visit our Website or use our services, as well as some of the steps we take to safeguard it. Please read this Website Privacy Policy to learn more about the ways in which we protect, use and disclose your personal information. By visiting the Website, you agree to be bound by the terms and conditions of this Website Privacy Policy. If you do not agree, please do not use or access the Website. By accepting the Website Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Website Privacy Policy. This Website Privacy Policy is incorporated into and subject to the Terms of Use. This Website Privacy Policy is effective when accepted by new users, and is otherwise effective on December 1, 2014, for all users. At Orion Elite Contracts (“PA”) maintaining our customers’ trust and confidence is of paramount importance. We are committed to safeguarding your personal information and providing you with facts and options about how this information may be shared. Please read this notice to learn more about our privacy policies and the options available to you. This notice replaces all previous statements of our website privacy policy, and may be amended at any time. Orion Elite Contracts maintains a separate Privacy Policy for non-website interactions which is available upon request. Those investors to which PA Capital provides investment advisory services will be provided with annual reminders of our non-website policies and with revised policies if there are any changes in how we handle the investor’s personal information. If an investor ends their relationship with PA, we will continue to adhere to the policies and practices described in our non-website Privacy Policy. Information That We Collect. As part of providing you with our services, we obtain nonpublic personal information about you, which may include the following: Information we receive from you on applications or other forms including name, address, social security number, assets and income. Information about your transactions with us or others. Information That We Share & Why It Is Important. We use or share information in a limited and carefully controlled manner. We do not disclose any nonpublic information about our customers or former customers to anyone, except as permitted by law, unless authorized by you. Instances in which we may share your information with nonaffiliated third parties include: Inclusion of certain names (institutional clients only) on a Representative Client List. The Representative Client List is contained in our standard marketing material and examples of those who may receive the list include: existing clients, prospective clients, consultants for prospective clients and prospective hedge fund managers. The majority of PA’s assets under management are institutional assets. As a result, institutional assets in general are perceived as stable capital sources and hedge fund managers tend to be biased towards favoring these assets. As we meet with prospective hedge fund managers, we believe our Representative Client List gives PA an advantage when trying to gain access to funds that accept capital on a limited basis. (NOTE: The Representative Client List includes language stating that the names on the list are not to be construed as an endorsement or recommendation of PA’s services.) Disclosure to companies that provide services necessary to effect a transaction that you request or to service your account such as prime brokers, accountants, banks, attorneys or administrators. Disclosure to government agencies, courts, parties to lawsuits, or regulators in response to subpoenas. In such cases, we share only the information that we are required or authorized to share.

Collection of Information

In general, you can browse the non-password-protected sections of the Website without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Website or not), to which URL you next go (whether this URL is on the Website or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services. We also may use data collection devices such as “cookies” on certain pages of the Website to help analyze our web page flow, measure effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a “cookie”. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Website and you may be required to reenter your password more frequently during a session. We use cookies to better understand how people interact with us. If you apply for a password to access password-restricted areas on this Website, you must provide to us with the following:

Your full name
Your mailing and email address
Your phone number
Your personal financial data
Your investment portfolio and other investment information

Use and Disclosure of Information

The security of your account information is important to us. Only those persons who need your information to perform their job have access to it. In addition, we maintain physical, electronic and procedural security measures that comply with federal regulations to protect your information. Our employees have limited access to your personal information based upon their responsibilities. All employees are instructed to protect the confidentiality of your personal information as described in these policies, which are strictly enforced. We use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use. If you apply for a password, we use that data to determine whether you are an accredited investor and have sufficient sophistication, investment experience and wealth to receive information about certain investment options. We may use your information to send correspondence and perform services on your behalf in connection with investment related activities. You agree that we may use personal information about you to analyze Website usage, improve our content and product offerings and customize the Website’s content, layout, and services. These uses improve the Website and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Website. In connection with providing our services, it also may be necessary for us to share information with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios. In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities. In those circumstances, we require such third parties to treat your private information with the same degree of confidentiality that we do. In some instances, the third-party service provider may collect information directly from you. In these cases, you will be notified of the involvement of the service provider, and all additional information you provide them and their additional uses will be strictly up to you. If you provide additional information to a service provider directly, their use of your personal information is governed by their applicable privacy policy. We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities. We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not described in this Website Privacy Policy. For example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Website. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private. If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties (through our Representative Client List), you may “opt out” of those disclosures. This means that you may direct us not to include your name on our Representative Client List (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may call our Chief Compliance Officer at PA’s main number: (804) 289-6000. You may exercise this right to opt out at any time.

Control of Your Password and Personal Information

You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your user name or password to access or use any part of this Website. If your password has been compromised for any reason, you should contact us immediately for a new password. You can review and change the information that you submit to us by contacting us at clientservices@pacapital.com. You can change your User ID, email address, contact information, financial information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate. On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy. We will retain in our files the personal information you have asked us to remove from our active databases to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and comply with legal requirements. Therefore, you should not expect that your personal information will be completely removed from our databases in response to your requests. However, such personal information will only be available to select employees, service providers and governmental persons or entities.

Security

Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company. However, “perfect security” does not exist on the Internet.

Children

Persons under age 18 are not eligible to use the Website.

Conditions of Use

If you choose to visit the Website, your visit and any dispute over privacy is subject to this Website Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the Commonwealth of Virginia. If you have any concern about privacy, please send a thorough description

Changes to this policy

This Website Privacy Policy may change from time to time. We may amend this Website Privacy Policy at any time by posting the amended terms on the Website. All amended terms shall automatically be effective 30 days after they are initially posted on the Website. If you have any questions about this Privacy Notice, you may call us at (778) 268-1148. Orion Elite Contracts

Your Rights

You have various rights with respect to our use of your personal data:

Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access will be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
Objection: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.
Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint to the applicable supervisory authority or to seek a remedy through the courts.

Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data.

When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

How long we keep your personal data

We will retain your personal data, whether or not your account is active, for as long as we believe it necessary or desirable to fulfil our business purposes and to comply with applicable law and regulation, audit requirements, regulatory requests or orders from competent courts. Personal Data collected will be retained pursuant to our record retention policy, and in most instances will not be retained longer than nine (9) years from the date you cease to be an investor in a PA Capital fund or a separately managed account.

Changes to our privacy notice

Any changes we make to our Privacy Notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Notice.