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Privacy Policy

OUR COMMITMENT TO PRIVACY

This is the Internet Privacy Policy for CNL Financial Group, Inc. (“CNL”). This Internet Privacy Policy addresses CNL's privacy practices with respect to information collected online via this Web site only. This Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us via this Web site and to assist you in making informed decisions when using our Web Site. This statement will be continuously assessed against new technologies, business practices and our customers' needs. By using our Web site or submitting information containing personal non-public information, you consent to our collection of your personal information as described in this Internet Privacy Policy as well as in CNL’s Privacy Policy. If we change our privacy policies and procedures, we will post those changes on our Web site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Where required to do so by law, we also will provide you with a notice by mail or email of any changes to this Internet Privacy Policy. Users who are not resident to the United States should not submit their personal information to our Web site or by submitting documents containing such information unless they agree that their personal information will be treated in accordance with United States laws and the terms of this Internet Privacy Policy. If you have any questions about the use of your personal information, please contact us at cfgprivacypolicy@cnl.com before submitting your personal information.

WHAT INFORMATION DO WE COLLECT?

You may provide us with two types of information: (1) personal information you knowingly choose to disclose to us through information submitted to CNL or its affiliates and over the Web site and (2) Web site-use information collected as you and others browse and use our Web site.

  1. Personal Information Submitted by You

    When you submit information to CNL or its affiliates, when you register on our Web site, and/or when you choose to request forms or information through our Web site, you may be asked to give personal information. For example, you may be asked to provide the following information:

    Name
    Postal or legal address
    E-mail address
    Home and business phone number
    Other personal information (i.e., mother's maiden name)

    When you request forms or information or otherwise complete online forms or submit information online, we may collect any information you provide in such documentation or communication.

  2. E-mail Information

    In addition to providing the foregoing information collected through your submission of information to CNL or its affiliates or your use of our Web site, if you choose to correspond further with us through e-mail, we may retain the content of your e-mail messages together with your e-mail address and our responses.
  3. Web Site Use Information and "Cookies"

    Similar to other commercial Web sites, our Web site utilizes a standard technology called "cookies" and Web server logs to collect information about how our Web site is used. Cookies are a feature of Web browser software that allows Web servers to recognize the computer used to access a Web site. They are small pieces of data that are stored by a user's Web browser on the user's hard drive. Cookies can remember what information a user accesses on one Web page to simplify subsequent interactions with that Web site by the same user or to use the information to streamline the user's transactions on related Web pages. This makes it easier for a user to move from Web page to Web page and to complete commercial transactions over the Internet. Cookies should make your online experience easier and more personalized. We use session ID cookies to make it easier for you to navigate our site during a particular visit. A session ID cookie expires when you close your browser. Information gathered through cookies and Web server logs may include the date and time of visits, the pages viewed, time spent at our Web site, and the Web sites visited just before and just after our Web site. This information is collected on an aggregate basis. None of this information is associated with you as an individual. If your browser is set to reject cookies, you may still use our site, but your ability to use or navigate some areas of our site will be impaired.

HOW DO WE USE THE INFORMATION THAT YOU PROVIDE TO US?

Broadly speaking, we use your personal information for purposes of administering our business activities, providing customer service and making other products and services available to you. Occasionally, we may also use the information we collect to notify you about important changes to our Web site, new services and special offers we think you will find valuable. You will be given the opportunity to notify us on the Web site of your desire not to receive these offers. We use Web site browser software tools such as cookies and Web server logs to gather information about our Web site users' browsing activities in order to constantly improve our Web site and better serve our customers. This information assists us to design and arrange our Web pages in the most user-friendly manner and to continually improve our Web site to better meet the needs of our customers and prospective customers.

SHARING INFORMATION WITH THIRD PARTIES

We may provide information collected on our Web site, Web site traffic patterns, related Web site information to our affiliates or reputable third parties, but this information will not include personally identifying data, except as otherwise provided in this Internet Privacy Policy and the CNL Privacy Policy. This Web site is administered by CNL. As such, any personal information submitted via this Web site will be provided to the service providers retained by CNL and/or its affiliates. However these affiliates are required and are committed to protecting your information as specified within this policy. We may enter into strategic marketing alliances or partnerships with third parties who may be given access to certain personal information including your name, address, telephone number and e-mail for the purpose of providing you information regarding products and services that we think will be of interest to you. In connection with strategic marketing alliances or partnerships, we will retain all ownership rights to the information, and we will not share information regarding your social security number or other non-public personal financial data. In the event that CNL or any of its affiliates and/or some of our assets are sold or transferred or used as security, the information collected on our Web sites may be transferred to third parties as part of that transaction. CNL may also provide such information or provide access to such information to our affiliates or to our business partners, vendors and/or service providers; however we will do so subject to appropriate confidentially agreements that obligate such partners, vendors and/or service partners to maintain and protect the confidentiality of such information. If CNL is requested by law enforcement officials or judicial authorities to provide information on individual users, we may, without your consent, provide such information. In matters involving claims of personal or public safety, CNL may provide your personal information to appropriate authorities without your consent or court process.

NOTICE OF NEW SERVICES AND CHANGES

Occasionally, we may also use the information we collect to notify you about important changes to our Web site, new services and special offers we think you will find valuable. You will be given the opportunity to notify us of your desire not to receive these offers by clicking on a response box when you receive such an offer or by sending us an e-mail request at cfgprivacypolicy@cnl.com.

HOW DO WE SECURE INFORMATION TRANSMISSIONS?

When you enter confidential personal information on our Web site, secure server software which we have licensed encrypts all information you input before it is submitted to us. The information is scrambled en route and decoded once it reaches our Web site. E-mail that you may send to us may not be secure unless we advise you that security measures will be in place prior to your transmitting the information. For that reason, we ask that you do not send confidential information such as Social Security or account numbers to us through an unsecured e-mail.

HOW DO WE PROTECT YOUR INFORMATION?

We know that security is a concern for our customers and we have developed and implemented administrative, technical and physical security practices and procedures designed to protect the confidentiality of your personal information and the security of our Web site. We will take measures which we believe are reasonable and appropriate to protect your information from unauthorized access or disclosure and accidental loss, alteration or destruction.

HOW CAN YOU ACCESS AND CORRECT YOUR INFORMATION?

You may request access to all your personally identifiable information that we collect online and maintain in our database by e-mailing cfgprivacypolicy@cnl.com. Such requests will likely take at least 4 to 6 weeks to process. We may retain in our files information you have requested be removed from our databases in some circumstances, such as to resolve disputes, troubleshoot problems, enforce the Terms of Use of our Web Site, or as required by applicable law, rule or regulation. Further, such information is never completely removed from our databases due to technical constraints and the fact that we back up our systems and are required to retain certain information by law or regulation. Therefore, you should not expect that all of your information will be completely removed from our databases in response to your requests.

WHAT ABOUT OTHER WEB SITES LINKED TO OUR WEB SITE?

We are not responsible for the practices employed by Web sites linked to or from our Web sites nor the information or content contained therein. Often links to other Web sites are provided solely as pointers to information on topics that may be useful to the users of our Web site. Please remember that when you use a link to go from our Web site to another Web site, our Internet Privacy Policy is no longer in effect. Your browsing and interaction on any other Web site, including Web sites which have a link to our Web site, is subject to that Web site's own rules and policies. Please read over those rules and policies before proceeding.

CONCLUSION

CNL restricts access to your personal and account information to those of its employees, affiliates and service providers who need to know that information to provide products or services to you. CNL maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information. We will continue to adhere to the privacy policies and practices as described in this notice, whether or not you become a investor in a CNL sponsored investment. If you have any questions concerning CNL privacy policies and procedures, please feel free to contact us.

Thank you.