Chandler Asset Management USER PRIVACY POLICY Last updated January 1, 2020 Thank you for choosing to be part of our community at Chandler Asset Management (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@chandlerasset.com. When you visit our website https://chandlerasset.com, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please contact us via UserPrivacy@ChandlerAsset.com. This privacy policy applies to all information collected through our website (such as http:// chandlerasset.com), and/or any related services, sales, or information exchange (we refer to them collectively in this privacy policy as the “Sites“). Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. TABLE OF CONTENTS WHAT INFORMATION DO WE COLLECT? HOW DO WE USE YOUR INFORMATION? WILL YOUR INFORMATION BE SHARED WITH ANYONE? DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? HOW LONG DO WE KEEP YOUR INFORMATION? HOW DO WE KEEP YOUR INFORMATION SAFE? DO WE COLLECT INFORMATION FROM MINORS? WHAT ARE YOUR PRIVACY RIGHTS? CONTROLS FOR DO-NOT-TRACK FEATURES CALIFORNIA RESIDENTS DO WE MAKE UPDATES TO THIS POLICY? HOW CAN YOU CONTACT US ABOUT THIS POLICY? 1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information. We collect personal information that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us. The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following: Name and Contact Data. We collect your ﬁrst and last name, email address, postal address, phone number, and other similar contact data. Credentials. We collect passwords, password hints, and similar security information used for authentication and account access. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. Information collected from other sources In Short: We may collect limited data from public databases, marketing partners, and other outside sources. We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media proﬁle information; marketing leads and search results and links, including paid listings (such as sponsored links). 2. HOW DO WE USE YOUR INFORMATION? In Short: We process your information for purposes based on legitimate business interests, the fulﬁllment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the speciﬁc processing grounds we rely on next to each purpose listed below. We use the information we collect or receive: – To facilitate account creation and logon process. If you choose to create and access your account on our online Client Portal, please send a request to clientservice@chandlerasset.com or call 800-317-4747. – To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the ” WHAT ARE YOUR PRIVACY RIGHTS ” below). – To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies. – Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its eﬀectiveness. – Request Feedback. We may use your information to request feedback and to contact you about your use of our Sites. – To protect our Sites. We may use your information as part of our eﬀorts to keep our Sites safe and secure (for example, for fraud monitoring and prevention). – To enforce our terms, conditions and policies. – To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. – For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the eﬀectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience. 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE? In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulﬁll business obligations. We may process or share data based on the following legal basis: – Consent: We may process your data if you have given us speciﬁc consent to use your personal information in a speciﬁc purpose. – Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. – Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulﬁll the terms of our contract. – Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). – Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More speciﬁcally, we may need to process your data or share your personal information in the following situations: – Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, ﬁnancing, or acquisition of all or a portion of our business to another company. 4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? In Short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Speciﬁc information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy. 5. HOW LONG DO WE KEEP YOUR INFORMATION? In Short: We keep your information for as long as necessary to fulﬁll the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 6. HOW DO WE KEEP YOUR INFORMATION SAFE? In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment. 7. DO WE COLLECT INFORMATION FROM MINORS? In Short: We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependentʼs use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at ndragoo@chandlerasset.com. 8. WHAT ARE YOUR PRIVACY RIGHTS? In Short: You may review, change, or terminate your account at any time. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can ﬁnd their contact details here: http://ec.europa.eu/ justice/dataprotection/bodies/authorities/index_en.htm Account Information Account Information If you would at any time like to review or change the information in your account or terminate your account, you can: ■ Log into your account settings and update your user account. Upon your request to terminate your online account with (see Section 2 above), we will facilitate the deactivation or deletion your account and information. However, some information may be retained in our ﬁles to prevent fraud, troubleshoot problems, assist with any investigations, enforce, or comply with legal requirements. For further information regarding to user account retention policies, please send a request to clientservice@chandlerasset.com or call 800-317-4747. Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could aﬀect certain features or services of our Sites. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list. To opt-out, please contact us via UserPrivacy@ChandlerAsset.com. 9. CONTROLS FOR DO-NOT-TRACK FEATURES Most web browsers and some mobile operating systems and mobile applications include a DoNot-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been ﬁnalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. 10. CALIFORNIA RESIDENTS In accordance with California Civil Code Section 1798.83, also known as the “Shine The Light” law as well as the California Consumer Privacy Act (CCPA), we do not collect any personal information to disclose or distribute to third parties for direct or indirect marketing purposes. For more information on CCPA please visit https://oag.ca.gov/privacy/ccpa. 11. DO WE MAKE UPDATES TO THIS POLICY? In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be eﬀective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notiﬁcation. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 12. HOW CAN YOU CONTACT US ABOUT THIS POLICY? If you have questions or comments about this policy, you may contact our Data Protection Oﬃcer (DPO), Nicole Dragoo, by email at ndragoo@chandlerasset.com, by phone at (800) 317-4747, or by post to: Chandler Asset Management Nicole Dragoo 6225 Lusk Blvd San Diego, CA 92121 United States 12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days. CHANDLER ASSET MANAGEMENT NEW INSIGHTS 11/19- Weekly Economic Highlights Nov 19, 2021 This week’s economic data was mostly favorable....... read more November 2021 – Bond Market Review Nov 09, 2021 Real US gross domestic product (GDP) growth...... read more CONTACT US 800-317-4747 info@chandlerasset.com CAREERS HOLIDAY SCHEDULE CONTACT FORM Copyright 2021 - CHANDLER ASSET MANAGEMENT. All Rights Reserved Form CRS Adv Part 2a Code Of Ethics Privacy Policy Disclosures Personal Data Requests