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We thank you for visiting the Acorn Trade Finance website (“Acorn”, “we” or the “Company”). Acorn’s commitment to you is based on reverence of your privacy as a visitor of this website (the “Site”). This Privacy Policy (“Policy”) was developed to assist you, as the user, to understand that the Company collects information about you when you visit the Site, and how this information is utilized.

By visiting the Site, you have agreed to become subject to this Privacy Policy and Acorn’s Terms of Use.  Both the aforementioned may be updated by the Company at any time at Acorn ’s discretion.  If and when updated, the new Privacy Policy and Terms of Use will be posted for viewing and any changes will be effective subsequent to the revised posting.

The Acorn Privacy Policy only relates to the Information contained in this Site and does not govern any other website, articles, or information that the Site is linked.  Please review and familiarize yourself with the privacy policy of the other websites if you visit these other websites via links from the Acorn Site.

In addition, it should be noted that this Privacy Policy only governs your interface with the Site and not any other collaboration with Acorn.  Lastly, this Policy does not purport to represent any Company Non-Disclosure Agreement in relation or respect to any nonpublic personal information that may be disseminated or obtained as a lender / investor in Acorn or in affiliated managed funds, Special Purpose Vehicles, sponsored entities, etc.

Please feel free to contact us with any questions or comments regarding the Policy at

I. Information Collection

Upon entering the site, Acorn may collect two types of information: 1) Provided Information or 2) Technology Collected Information:

a)    Provided Information:

As a way of accessing certain information or materials on the Site, you may be required to provide information that is collected and stored to allow Acorn to create a Personality Profile.  This Personality Profile may include, but is not limited to, name, mailing address, e-mail address, facsimile number and other relevant information (investor type).  As such, the Company may retain all communications and notes garnered from you in the Personality Profile.

b)    Technology Collected Information:

The other method of collecting information will be via Technology Collected Information (“TCI”).  A TCI example would be Internet Protocol (“IP”) address identification each time you request a page during a visit to the Site.  Occasionally, Acorn may utilize IP addresses to gather information regarding user frequency.

Other TCI methods, which may include TCI utilized by Acorn or an outsourced contractor authorized to collect information by the Company, could incorporate tracking and analysis of Site traffic patterns and frequency.  These technical methods may be transmitted in e-mails that are sent to Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails.  Additionally, this type of TCI may be potentially converted to a Personality Profile.

In certain cases, software tools may be utilized to collect session information, including page response times, length of visits, page interaction information (click, scrolling), and methods used to browse away from the page. Acorn may use this information to measure Site activity, develop ideas to improve the Site and for any other purpose to the extent permitted by applicable law.

c)     Cookies:

1)    Cookies are usually small text files that are stored on your computer's browser directory or program data subfolders. Cookies are created when you use your browser to visit a website that uses cookies to keep track of your movements within the site, help you resume where you left off, remember your registered login, theme selection, preferences, and other customization functions.  The website stores a corresponding file to the one they set in your browser and in this file, they can track and keep information on your movements within the site and any information you may have voluntarily given while visiting the website, such as email address.

2)    Acorn will and expects to utilize cookies to consume anonymous analytics to enhance the Site.  This could include, but is not limited to, compiling statistical information such as Site frequency, visited pages, duration of visit, as well as information about your computer, operating system, browser, language, and user country.  Acorn will NOT use cookies to store any personal information that could be read or disseminated by others outside of the Company.

3)    Depending on your comfort level, Internet Browsers provide the option of having your computer alert you when a cookie is being sent from a server / computer or can select an option to turn off all cookies.  For additional information regarding Internet Browser settings regarding cookie modification, please consult with your Information Technology specialist or the Internet Browser Help menu.

II. Utilization of Personality Profile

a)    Acorn will not disclose any nonpublic personally identifiable information about its Site users to any nonaffiliated third party, except as set forth below.

1.    The Company may use or disclose certain personally identifiable information collected when you visit and browse the Site as part of the normal business operations or to send communications either about your interactions with Acorn or Site features, including any future changes to the Privacy Policy.

2.    Acorn may use contracted service providers to facilitate and enhance the Site services. These companies and individuals may have access to your personally identifiable information, as needed, to perform their functions, but will be prohibited from utilization for any other purposes which will be enforced via confidentiality agreements.

3.    The Company will use or disclose Personality Profiles when it is believed, in our sole discretion, that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request.  For example, it may be necessary, under Anti-Money Laundering (“AML”) and similar laws, to disclose information about investors in order to accept subscriptions.  Lastly, in the event that Acorn, or substantially all of the assets of Acorn are acquired or merged with another entity, user information may be one of the transferred assets. Acorn may transfer all user information (which may include personally identifiable information) to our acquirers or successors. Acorn, however, reserves the right to use any personally identifiable information in any manner permitted by law.

III. Utilization of Non-Personally Identifiable Information

a)    Non-personally identifiable information is information that does not personally identify you, which includes anonymous information and aggregate data.  Acorn may use this information to research visitor demographics, interests and behavior, Site utilization, and provide users customized services and information and Site improvements.  In certain instances, this information may be combined with the Personality Profile and may be shared with others, including investors, for information or promotional purposes.  As stated previously, this information will only be utilized in a manner only permitted by applicable law, but any disclosure that identifies you personally will be governed by Section II.

IV. Customer Tracking

a)    Acorn may track its customers during long term durations or across third party websites to provide targeted advertising.  As such, the Company does not respond, or honor Do Not Track (“DNT”) signals. DNT is a technology and policy proposals that enables users to opt out of tracking by websites they do not visit, including analytics services, advertising networks, and social platforms.

b)    It must be noted that various third-party websites track browsing activities when they serve content, which enables them to tailor what they present to you.  For additional information regarding these settings, please consult with your Information Technology specialist or other sources on the Internet.

V. Information Protection

a)    Acorn seeks to protect all personally identifiable information and utilizes various methods (physical, technical, and administrative) to maintain the integrity and security of any gathered information.  It must be noted that, despite Acorn ’s best efforts and methods, Internet “faultless security” is non-existent, and third parties may unlawfully intercept or access transmissions or private communications.  Acorn will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your Personality Profile.

VI. International Use

a)    Acorn cannot make any claim that Site materials are legally approved for use outside the United States.  Access to the Site from any country or jurisdiction that deems access illegal is prohibited.  In additional, all data is hosted and stored in the United States.  Any access to the Site outside of the United States will be done at your own risk and you consent to the transfer and storage of data within the United States. Lastly, those accessing the Site from outside the United States are responsible for compliance with local laws, rules, and regulations.

VII. Warranty Disclaimer and Limitation of Liability

a)    Acorn  shall in no event be liable to any party for any claims, liabilities, losses, costs or damages, including but not limited to, any direct, indirect, punitive, special, incidental, or consequential damages (“Damages”) arising out of or in connection with any access, use or distribution of the Site, including Damages caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft, destruction or unauthorized access to, alteration of or use of any asset, whether for breach of contract, tortious behavior, negligence or under any other cause of action, or any content obtained through use of the Site. This will remain true even if Acorn has been advised of the possibility of such damages or losses.

b)    Acorn, respective officers, directors, managers, partners, members, shareholders, employees, affiliates and agents (collectively “Related Persons”) make no representations or warranties and specifically disclaim any and all warranties of any kind, express or implied, with respect to the Site, including any representations or warranties with respect to title, non-infringement, availability, security, accuracy, freedom from viruses or malware, completeness, timeliness, functionality, reliability, sequencing or speed of delivery.

c)    While reasonable efforts are utilized to obtain information from reliable sources, Acorn does not warrant that the Site information is accurate, reliable, complete, or correct or that the Site will be available at any and all particular times or locations. Information or materials are provided “as is” and “as available”.

VIII. Governing Law

The laws of the State of New York govern these Terms of Use. Any dispute relating to these Terms of Use or your use of the Site shall be resolved solely in the state or federal courts located in New York County, New York, or the United States District Court for the Southern District of New York located in New York County, New York. You agree to waive trial by jury in any such action.