document: title: privacy policy
text: Effective Date:  April 10, 2017  


## Notice

This privacy statement describes how Green Clouds Education Solutions Pvt. Ltd. (collectively, “We”, “Us”, “Our or “GreenClouds”) collects and uses the personal information you provide on formistry.com  domain, application platform, service and website - www formistry.com and all sub domains within their ambit, including any mobile phone app that is owned and operated by GreenClouds under the Formistry banner. (Formistry is an Online Application Management Solution - that consists of a form and Management Console - that has been developed by GreenClouds and is deployed for Clients, Colleges, Universities and Institutions.

It describes the choices available to you regarding our use of your personal information, and also describes how you can access and update this information.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. 

The use of information collected through our service shall be limited to the purpose of providing the service for which a Client has engaged GreenClouds and for the purposes of pre fill and single click apply when an applicant / candidate wishes to pre fill a form with data already submitted in another form.

We collect the following kinds of personal information for our Clients and for the purposes of making your form filling process simple:

  * Contact Information such as name, email address, mailing address, pin code, phone number
  * Religious information and information pertaining to disability status.
  * Unique Identifiers such as user name, account number, password



We also collect the following information for our Clients:

  * Demographic information such as age, education, gender, interests, passport number, parents/ guardian name, address and income
  * Demographic information such as age, education, gender, interests and zip code



We use this information:

  * To contact you about your request, to assist you in the application process or to follow up with you about the programs and services in which you have expressed an interest
  * To provide you with customer support and to communicate regularly with you. While providing you with customer support (including where applicable through the live chat) we may also gather additional information from you.
  * To analyze the characteristics of our Client services and improve our services. We will periodically provide anonymized aggregated statistics about candidates/ applicants in reports made available to our customers, to third parties, or to the general public. These reports will not identify individual candidates/ applicants.
  * To send newsletters, webinars on the behalf of our Clients. You can unsubscribe to these by following the unsubscribe instructions that appear at the end of each communication.



We occasionally conduct online consumer surveys to learn about your views on important privacy issues. We do not collect personally identifying information in these surveys. We use the survey data for research and to improve our services.

## Policy

GreenClouds collects information through its application and domain Formistry under the direction of its Clients who invite applications for courses/ programs/ opportunities or directly from candidates to ease the application filling experience by using the pre fill or integration option that may be provided.

This policy will let you know about:

  * Changes in this Privacy Policy Statement
  * Our Reservation of Rights
  * Personally identifiable information collected from you through Formistry.
  * How we use tracking technologies
  * How candidate information obtained through Formistry is used
  * With whom GreenClouds shares candidate information collected from through Formistry
  * GreenClouds’ policy when there has been an allegation of fraud, misrepresentation or other inappropriate act or criminal allegation involving a candidate
  * Candidate’s choices regarding collection, use, and distribution of information
  * GreenClouds policy on allowing you to access, update, correct, or delete your personally identifiable information on Formistry.
  * The security precautions in place to protect the loss, misuse, or alteration of your information and how your information is stored, accessed and used by others
  * Posting of Testimonials
  * Social Media Widgets
  * Additional information and how you can contact us regarding this Policy.
  * Emails that you send us



Through our trustworthy independent web service providers, Amazon Web Services, Inc., GreenClouds, through its domain and application Formistry.com, collects, uses, processes, shares and makes available to authorised Clients, Colleges, Universities or Institutions personally identifiable information that you provide by registering and filling Formistry online application. All personal information that you submit to us is handled within the jurisdiction of India.

Please read carefully the following Privacy Policy before registering with us and completing an on-line user registration and application form on Formistry. Please note that this Policy only addresses GreenClouds's privacy practice concerning information collected through Formistry.com domain, sub-domains, application and mobile app and does not apply to information that may have been collected about you by others. This Policy also does not cover the privacy or information practices of those websites that may be linked to or referenced by the Formistry domain, website or app or the privacy or information practices of those Colleges, Schools, Universities or other partners that receive the personal information that is collected from our site and sent to them as part of the application / admissions/ recruitment process or other purpose.

Please also note that this Policy may change from time to time so please check back to review this Policy each time you visit or use our website or our mobile app.

## Changes In This Privacy Policy Statement

If we decide to change our Privacy Policy or email practices we will post those changes to this Privacy Policy statement, login page and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this Privacy Policy statement at any time, so please review it frequently. If we make material changes to this Policy, we will notify you here or by email, or by means of a notice on our login page and other places we deem appropriate prior to the change becoming effective.

## Our Reservation of Right

By using our Application or Service to apply to any of our Clients or subscribing members, you consent and we reserve the right to use your data collected in ways that are consistent with the current disclosed practice.

## Personally Identifiable Information Formistry Collects From You

If you are a candidate/ applicant, certain required and optional personal information (such GREEN CLOUDS EDUCATION SOLUTIONS PVT.LTD www.greenclouds.in  as your name, home and mailing address, email address, telephone number, citizenship, date and place of birth, parents' names and address, passport number, aadhar number including the names, telephone numbers and/or email addresses of your parents or legal guardian), is collected from you when you voluntarily provide this information to us through Formistry on-line Registration form. This personal information is collected from you voluntarily when you complete your "profile" screen as part of the registration and application process. During registration, we ask you to create a username and password. Your personal information including any personal information of your parents or legal guardian that you provide shall be considered to be “your personal information” for purposes of this Privacy Policy. Once you register you are no longer anonymous to Formistry and the email address and/or the mobile number that you provide to us becomes your “User Name” so that you are able to take full advantage of Formistry’s online authentication services.

If you are an Admissions Officer, Administrator at one of our Client colleges or universities who has deployed Formistry to receive student admission application data, we collect your name and email address to permit you to retrieve data of student applicants who have applied to your college or university. Please note that we do not collect, use, store or share personal identifying information of our Client administrators for any other purpose.

Wherever we collect personal information we make an effort to include a link or reference to this Privacy Policy on that page.

## How We Use Tracking Technologies

GreenClouds and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

We partner with a third party to [display advertising on our website or to manage our advertising on other sites]. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest- based advertising click here http://preferences-mgr.truste.com/ . Please note you will continue to receive generic ads.

As is true of most web sites and apps, we gather certain information automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do link this automatically-collected data to other information we collect about you.

## How Formistry Uses Candidate Information

When you seek to register with Formistry or with Colleges/ Universities who deploy Formistry Online application and/ or its associated services, we ask you for your name, email address, telephone number and mailing address among other items of personal information, including the names, telephone numbers, and/or email addresses of your parents or legal guardian. This information, requested by the Colleges and/or Universities, allows them to identify you and process your application upon submission.

Through our web application and or mobile app, we send you push notifications from time- to-time in order to update you about the admission/ application process. If you no longer wish to receive these types of communications, you may set your communication preferences in the, "Account settings’ of the form.

When you register on Formistry your personal information is available to Client organisations who deploy Formistry and who use Formistry services We will share your personal information with third parties only in the ways that are described in this Privacy Policy. 

Formistry makes available your personal information (including your cell phone number and email address) with Client Colleges and/or Universities who have deployed Formistry for the purposes of registration, admissions, enrolments or recruitments as the case may be. 

We also share your name, phone number and home address with service providers like Gmail or Facebook, solely to confirm or “validate” the accuracy of the email address that you entered and to authenticate your email. By voluntarily providing us with your personal information, you are giving us your express consent to share or provide access to your personal information with our trustworthy independent service providers (and subject to this Policy and/or their privacy policy and applicable law) so that we can provide the service for which you have registered. We may also share on a temporary basis your personal information (including, but not necessarily limited to, your name and date of birth) with other trustworthy third party organizations allowing us and/or them to generate de- identified aggregate data which we and/or the third party may publish, combine or enhance with other de-identified aggregate data obtained from other sources, and/or share or distribute the de-identified aggregate only data for monetary value with Clients/ colleges or universities that use Formistry or with other third parties. Note that even if you have only registered but not submitted an application through the Formistry, the Colleges and/or Universities will still have access to personal information downloaded as part of your registration data and such Colleges and/or Universities may contact you even prior to the time your application is submitted.

GreenClouds is not responsible for how any given Client College or University (after accessing or receiving your personal information through Formistry) will use, protect or store the information in their possession. You are encouraged to review that College/University's individual privacy policies and information practices as to how they use and protect your personal information and GreenClouds neither accepts nor assumes any liability or responsibility for the use, protection or storage of your personal information GREEN CLOUDS EDUCATION SOLUTIONS PVT.LTD www.greenclouds.in  by said College or University or Institution.

GreenClouds may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.

If GreenClouds is involved in a merger, acquisition, or sale of substantially all of its assets, we will post a prominent notice on the website informing you of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

## Formistry's Policy when there has been an Allegation Of Fraud, Misrepresentation or Other Inappropriate Act Involving An Applicant

Clients, Universities, Colleges, Institutions and candidates/ applicants are advised that Formistry is an Online application Solution through which candidates register/ apply for opportunities with Colleges and Universities or Institutions who have deployed Formistry or through which they register / apply for Colleges selected by the candidate/ applicant. As such, it is not our policy not to judge, evaluate, conduct any verification of or perform an investigation on any data provided on or about a candidate/ applicant regardless of the source of that data. That said, where we have been informed of an act of fraud, misrepresentation or other inappropriate act involving an applicant/ candidate, in certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. GreenClouds reserves the right to disclose your personally identifiable information as required by law or in any instance or circumstance when we believe that disclosure is necessary to protect our rights, the rights of our Clients and/or to comply with a judicial proceeding, police investigation, court order, or legal process served on our Web site or involving the Web Site, app or associated services. 

## Choices Regarding Communication

When you register with the Formistry or with Formistry deployments, you are given the following options to give your communication preferences. 

SEND ME MY ACCOUNT RELATED EMAILS ONLY. (Recommended) 

SEND ME PROMOTIONS AND OFFERS THAT ARE RELEVANT TO ME. 

You may provide your choices by appropriately changing the setting located on your "Account Settings" tab. You can access the “Account Settings” tab by clicking on the Settings icon in the upper right hand corner of your application after logging in.

If you initially opt-in to receiving all communications and later decide that you would like to opt-out, please click on settings tab on your account and change your communication preference.

Once registered, while you are free not to provide any personal information requested on Formistry or other applicant form, by doing so you will not be able to submit your application to Client, College, University or Institution. Users/candidates/ applicants can also decide not to provide information that is designated as "optional" on any application, supplement or other form.

GreenClouds is not involved in and cannot be held responsible for any admission outcome of any specific application.

## Formistry's Policy on Allowing You to Access, Update, Correct or Delete Your Personally Identifiable Information

Upon request GreenClouds will provide you with information about whether we hold any of your personal information. You may access and edit your registration information by using your User Name (your email address) and password. If you have forgotten your password, please click the "Forgot Password?" link to have password reset instructions emailed to you.

Where Formistry is deployed on behalf of Clients, Universities, Colleges or Institutions, GreenClouds has no direct relationship with the individuals/ applicants/ candidates whose personal data is processed on Formistry. An individual/ applicant/ candidate who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct her/his query to the Client, Universities, Colleges or Institutions (the data controller). If the Client requests GreenClouds to remove the data, we will respond to their request within 7 business days.

In case of data collected directly by GreenClouds on Formistry the individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Formistry support team at privacyquestions@formistry.com. We will respond to your request within a reasonable timeframe. The change will be effected in 7 working days.

Your User Registration information is password-protected. You may edit your User Registration information by using your User Name (your email address) and password.

We recommend that you do not divulge your password to anyone. Also remember to sign out of your Formistry registration account and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if you share a computer or other electronic device with someone else or are using a computer or other electronic device in a public place like a library or Internet "cafe." Also, to help ensure the security of your application, do not copy and paste links from within the online application into an email or share with others on a public forum. If you do not log out of the online system, users with technical knowledge may use these links to access your online application.

When you make submissions through Formistry, supplements or other applicant forms directly on the website or through Client, Colleges, Universities or Institutions or when you access your user registered account information from our Website, or our mobile app, or when you give us your permission to share certain of your personal information with Test Pre and Other organisations for the purpose of participating in tests/programs/ assessments, we offer the use of a secure server. The secure server software encrypts all information you input before it is sent to us. We also restrict access to the secure server through the use of firewalls.

When you provide your personal information on Formistry’s online application, this information is accessed by the Client, Colleges, Universities or Institutions that have deployed the Formistry application. Consequently, your personal information can then be viewed, printed and/or exported electronically to the Client, Colleges, Universities or Institutions which are located outside and separate from the Formistry web site and outside of the jurisdiction and perhaps country where you originally entered the information.

## Payments

Formistry is integrated with authorized bank or payment gateway providers to enable applicants/ candidates to pay application and other fees online. We DO NOT store credit card and other credit card related particulars of candidates/ applicants. The integration that is College/ Client/ University/ Institution specific is designed such that once the candidates/ applicant completes the form and clicks “Submit" he/she is directed to the payment gateway where payment is made. Sometimes if you click " Payment" link more than once, it is possible your account will have a duplicate charge. Our Client Colleges and/or Universities will reverse charges for any duplicate transaction. However, neither greenclouds, its client colleges or universities, nor third party independent contractors will be responsible for refunding any processing fees incurred by the incorrect use of this feature. Accordingly, to avoid duplicate charges, please do not click the payment SUBMIT button more than once.

## Data Retention

Your personal information obtained through Formistry is retained for a maximum of five consecutive application admissions cycles, depending on Client requirement. Your personal information is removed or "archived," after two consecutive application admissions cycles have lapsed, off the "live" servers and "backed-up" to a separate secured remote server for storage (at least until overwritten when space is needed to back-up more recent data) where no one can access it except on a very limited basis by us or our trustworthy independent web service provider responsible for storage of your personal information. Unless under court order, your application once archived remains irretrievable. Therefore, you are strongly advised to print for your own records a hard copy of all Formistry forms that you may have completed. We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. GreenClouds will retain this personal information as necessary to comply with our legal obligations, resolve disputes, GREEN CLOUDS EDUCATION SOLUTIONS PVT.LTD www.greenclouds.in  and enforce our agreements.

Note that the reasons for granting us continued limited access to your personal information from the remote server may include, but are not necessarily limited to, allowing us, our trustworthy independent web service providers or other partners, or authorized Clients Colleges/Universities to compile aggregate or historical information about applications submitted in previous years. For statistical purposes, your personal information will be used only in the aggregate meaning that personal identifying information such as your name and aadhar/ passport number shall not be used. For some historical purposes, however, we and our trustworthy independent web service providers or other partners, including Client, Colleges, Universities and authorized Institutions will have continued access to your archived personal identifying information as we and/or our trustworthy independent web service providers or other partners deem necessary.

## Security

The security of your personal information and our clients’ information is important to us. When you enter sensitive information such as login credentials or payment details we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to us online, including any information that you send or receive as an email or text message that is sent or received over your own email domain account, cell phone app or cell phone service, and you do so at your own risk.

Also, Formistry is not responsible and does not assume any liability for any texts, emails or other communications that you receive from or send to any of our clients, and we cannot accept liability for disclosure of any of your personal information due to errors in transmission or unauthorized or illegal acts of third parties.

## Greenclouds Identity Theft Policy

While rare, the risk of identity theft to on-line users of the Internet is on the rise and GreenClouds recognizes the importance of taking steps to help its student applicants, users, customers and members identify and detect patterns, practices or activities that may indicate the existence of identity theft involving Formistry including implementing the appropriate actions or responses to help safeguard against and/or mitigate the risk of future or continued theft. Please read carefully the identity theft portions of this Privacy Policy before using Formistry.

The identity theft portions of this Privacy Policy are to help all Formistry users identify identity theft and to provide them with information about what steps GreenClouds takes to detect identity theft, safeguard against, respond to and/or mitigate continued or future GREEN CLOUDS EDUCATION SOLUTIONS PVT.LTD www.greenclouds.in identity theft involving Formistry website, application and services

Please also note that the identity theft portions of this Policy also only address Formistry identity theft policy concerning activities involving its own web site, service and our mobile app and it does not apply to activities or identity theft policies of others or other web sites or apps independent from, referenced or linked to the Formistry Application or website e, such as web sites, apps or IT systems of Client Colleges or Universities or Institutions or other third parties or any individuals or officials that may be associated with these other institutions or third parties.

## Patterns, Practices or Activities that May Indicate the Existence of Identity Theft

In order to be on-guard for possible identity theft, all candidates, applicants, users, customers and members should be aware of the potential indicators of identity theft. These may include but are not necessarily limited to the following:

  * Receiving an alert, notification or warning from a consumer reporting agency
  * Receiving notification of a address discrepancy
  * Receiving notification of an account being involuntarily closed
  * Receiving or becoming aware of suspicious documents, information or photos provided for identification that appear to have been altered or forged or are inconsistent with other authenticated and accessible personal identifying information
  * Receiving or becoming aware of suspicious documents, information or photos provided for identification that appear to be associated with prior fraudulent practices or activities or are attribupolicy_texts to another student applicant, user, customer, member or other third party
  * Any unusual use of or suspicious activity involving or relating to any account that is held with Formistry



## Steps Formistry Takes to Detect Identity Theft

Formistry is used for students to apply for admissions/ opportunities with the Client organisation that deploys Formistry or can be used directly by candidates to explore possible Education and Employment opportunities. While Formistry through its trustworthy web service providers deploys several security measures to protect the personal identifying information of its users, such security measures may not always prevent the crime of identity theft due to the specific nature of this crime. Accordingly, GreenClouds must also rely upon the credible reporting of suspicious patterns, practices or activities of identity theft from its trustworthy student applicants, users, customers, members or school officials.

In this connection, any student applicant, user, school official or member that becomes aware of any suspicious pattern, practice or activity suggestive of an identity theft that also involves or relates to Formistry is urged to notify the GreenClouds via email at GREEN CLOUDS EDUCATION SOLUTIONS PVT.LTD www.greenclouds.in  privacyquestions@formistry.com. Please be sure to disclose your name, all relevant information about the suspected identity theft including information about how you may be contacted.

## Safeguard Against, Respond to and/or Mitigate Continued or Future Identity theft Or Breaches Of Personal Data

Upon receiving credible information about a possible identity theft or other possible related wrongdoing involving or relating to the Formistry service, the Formistry website or mobile app from a trustworthy student applicant, user, customer, school official or other trustworthy third party, GreenClouds will do what it reasonably can to investigate the merits of the claim by gathering up any other information within its reasonable control in order to evaluate whether there has been a possible attempt to commit identity theft or other possible related wrongdoing. If Formistry believes there are grounds for believing in good faith that an attempt at wrongdoing was made, we reserve the right to cancel or close an offending or possible tainted transaction or account, monitor a particular account or line of communication, change applicable security codes, notify law enforcement officials, notify the victim of the alleged attempted fraud or other wrongdoing, provide to the victim certain information (including the personal identifying information of another user) if reasonably requested or justified and/or do such other acts reasonable and/or necessary to protect Formistry and/or victim of the alleged theft or other possible wrongdoing and otherwise comply with any data breach notification or identity theft law that is applicable to the particular circumstance. Formistry also reserves the right not to take any action if no such action is warranted. Formistry reserves the right to rely upon its trustworthy independent web service providers to help implement, safeguard against and/or mitigate continued or future identity theft or other possible wrongdoing involving any student applicant, user, customer, member or school official when the alleged theft or other possible wrongdoing involves or is related to the Formistry service.

## Referrals

If you choose to use our referral service to tell a friend about the website, service or app, we will ask you for your friend’s email address. We will automatically send your friend this one-time email. Formistry does not store and only uses this address for the sole purpose of sending this one-time email to your friend.

## Social Media Widgets

Our Web site includes Social Media Features, such as the Facebook, Linkedin, Google+ and Twitter icon and Share button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site.

Your interactions with these Features are governed by the privacy statement of the company providing it.

## Links to 3rd Party Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of our domain Formistry.com or our Company Greencloud Education Solutions Pvt Ltd. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy statement of any Website you visit.

## Single Sign On

You can log in to our site using sign-in services such as Facebook Connect or Gmail or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

## Information Sharing

We will share your personal information with third parties only in the ways that are described in this Privacy Statement. We do not otherwise share your personal information to third parties without your prior consent to do so.

In certain situations, GreenClouds may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information as required by law, such as to comply with a subpoena, or similar legal or bankruptcy process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, to any other third party with your prior consent to do so.

If you decide to pay the fee via the online payment system that is linked to the application system or apply for test prep or assessments through integrated assessment & solution providers, we may need to share your name, address, and other personal contact information with the billing processor, assessment solution/services and mapping service providers to provide a map of the location you are looking for or the location you are currently in . These companies are authorized to use your personal information only as necessary to provide these services to us.

If GreenClouds is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

## Geo-Location Data

We collect your location-based information for the purpose of [locating a place that you may be searching for in your area]. We will only share this information with our mapping provider for the sole purpose of providing you the service. You may opt-out of location based services at any time by editing the setting of your browser.

## Forum

Our website offers publicly accessible community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our community forum, contact us at privacyquestions@formistry.com.  In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. Alternatively, if you used a third party application to post such information, you can remove it, by either logging into the said application and removing the information or by contacting the appropriate third party application.

## Testimonial

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacyquestions@formistry.com

## Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you or our Client by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

## Contact Information:

Greenclouds Education Solutions Pvt. Ltd 

6708 DLF City Phase IV 

Gurgaon Haryana 122002 India 

Email: privacyquestions@formistry.com

## Emails that you send to  us

Please note that any emails, text messages, or other communications that you send us or which we have been given legal access to may be copied, forwarded or distributed to our members within our sole discretion.