PRIVACY POLICY

This Privacy Policy governs the manner in which Sora Investors, LLC (“Sora,” “we”, “our”) collects, uses, maintains and discloses information collected from users (each, a “User”) of our websites including www.sorainvestors.com (collectively, the “Sites”).

PERSONAL AND NON-PERSONAL IDENTIFICATION INFORMATION

We may collect personally identifiable information from Users in limited ways, including, but not limited to, when Users visit our Site and fill out a form in connection with the activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, their name and email address. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

NON-PERSONAL IDENTIFICATION INFORMATION

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

WEB BROWSER COOKIES

Our site may use “cookies,” which are small data files your web browser places on your hard drive for record-keeping purposes to help tailor the site to you each time you initiate a session on our site. This information may be retrieved when you access our site to help give you a more personalized browsing experience. The information stored does not directly identify you. You can set many browsers to notify you when a cookie is being placed on your computer and also erase cookies that may have been knowingly or unknowingly set on your computer. You may delete cookie files from your own hard drive at any time; however, cookies may be necessary to provide access to much of the content and many of the features of the site.

Sora may also use third-party cookies and other technologies, such as Google Analytics, to support our Sites or provide information regarding User activity on our Sites. Some of these third parties may use technology such as cookies to collect information such as your device type, operating system, browser information or software version. The use of this information by those third parties will be governed by their own privacy policies including, for example, Google’s Analytics Privacy Policy.

PROTECTING YOUR INFORMATION

The security and confidentiality of your information is extremely important to us. We have implemented data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and do not guarantee that personally identifiable information transmitted via the Internet or stored in the firm’s systems or is otherwise under Sora’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the internet.

USING AND SHARING YOUR PERSONAL INFORMATION

Sora may use your personal information and/or passively collected information to improve the Site, customize the Site to your preferences, communicate information to you (if you have requested it), and for the purposes specified in this Privacy Policy. We do not sell, trade, or otherwise transfer to outside parties your personal identification information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may share aggregated non-personally identifiable visitor information with other parties in any way.

To the extent permitted by law, Sora may also disclose personally identifiable information to comply with applicable law; respond to judicial process or regulatory authorities; protect against fraud; enforce our Terms of Use; or protect the safety and security of the Site, Users, records, databases, third parties and any tangible or intangible property that belongs to us or to third parties.

LINKS TO OTHER WEBSITES

The Site may contain links or references to other websites which may be integrated into and appear to be part of the Site. Please be aware that Sora does not control other websites and that this Privacy Policy does not apply to those websites. Sora encourages you to read the privacy policies of every website you visit, including websites you link to from this Site, and disclaims any responsibility for the privacy policies and procedures of any third-party website.

AMENDMENTS TO THIS PRIVACY POLICY

Sora reserves the right to amend this Privacy Policy at any time and from time to time. We encourage Users to check this page and the terms of use for any changes each time you use the Site. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Site following the posting of amendments to this Privacy Policy will be deemed your acceptance of those amendments.

YOUR ACCEPTANCE OF THESE TERMS

The Site is governed solely by applicable federal and state laws and governmental regulations in the United States. Use of the Site constitutes your consent to application of such laws and regulations and acceptance this Privacy Policy.