This privacy policy (“Privacy Policy”) for Neos Partners,LP (“Neos”, “we”, “us”, “our”)describes how we collect, use and disclose information about users of the Neos website (www.neospartners.com), and its services, tools, features and functionalities (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services. If we make changes to this Privacy Policy, if required by law, we will update the last revised date, and post the updated version on our website.

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Please read this Privacy Policy carefully. By using or accessing any of the Services, you agree to the use of your information it describes and to the other terms of this Privacy Policy. If you do not agree to this Privacy Policy, please do not access and use the Services.

1. HOW WE COLLECT AND USE INFORMATION ABOUT YOU      

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1.1 When you access oruse our Services, or otherwise engage with us, we may ask you to provide uswith the following information about you:

• (a.) Identification     Information: Name, phone number, and/or email. We collect this     information to communicate with you about our Services.
• (b.) Any other     information you choose to provide: This includes information that you     choose to include in communications with us through the Services, Survey     responses, and information provided to our support team. We use this     information to facilitate your engagement with the Services, including to     communicate with you about our Services (including to tell you about other     services that may be of interest to you).

1.2 In addition, ourwebsite, like most websites, uses third party tools, including cookies, pixelsand other tracking technologies (“Tracking Technologies”), including GoogleAnalytics, to provide and enhance the performance of our Services, facilitate andenhance user experience, monitor and analyze trends, usage and activities inconnection with the Services and conduct internal research and development. Forfurther information about Google Analytics, please click here. The information wecollect through Tracking Technologies includes:

• (a.) Details of the devices     used to access our website, such as unique device identifier, browser     type, device type, and operating system information.
• (b.) IP address.
• (c.) Date and time stamps, such     as the date and time you first accessed the Services.
• (d.) Log data.
• (e.) Other information     regarding your interaction with the Services, such as clickstream data,     referral activity, which emails you may have opened and ad impressions.

1.3 We may combinepersonal information that you provide to us with information that we collectfrom or about you from Tracking Technologies. This will include informationcollected in an online or offline context.

1.4 In addition to thespecific uses of information described above, we may use all of the aboveinformation to provide, improve and develop the Services and our productofferings, including as we describe in our Terms of Service, to comply with anyapplicable legal obligations, to enforce any applicable terms of service, toprotect or defend the Services, our rights, the rights of our users, or others,for the purpose of combatting fraud, or to otherwise operate the Neos business.

2. HOW WE SHARE INFORMATION ABOUT YOU

2.1 When you access oruse our Services, or otherwise engage with us, we may ask you to provide uswith the following information about you: We may share information about youwith third parties in the following circumstances:           

• (a.) With vendors and service providers, including cloud storage providers, email marketing service     providers, IT and security vendors, and data analytics vendors.
• (b.) With our affiliates, subsidiaries or otherwise within our corporate group.
• (c.) To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• (d.) In connection with an asset sale, merger, bankruptcy, or other business transaction.
• (e.) To enforce any applicable terms of service.
• (f.) To ensure the safety and security of Neos and our users.
• (g.) With professional advisors, such as auditors, law firms, or accounting firms.

2.2 To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for our business purposes, but will not disclose any personally identifiable information aboutyou to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to us, you consent to our use of such personally identifiable information for the purposes described in this Privacy Policy.    

3. COOKIES AND OTHER TRACKING TECHNOLOGIES

3.1 Do Not Track Signals

• (a.) Your browser settings may     allow you to transmit a “Do Not Track” signal when you visit various     websites. Like many websites, our website is not designed to respond to     “Do Not Track” signals received from browsers. To learn more about “Do Not     Track” signals, you can visit http://www.allaboutdnt.com/.

4. THIRD PARTY WEBSITES AND LINKS

4.1 We may provide linksto third-party websites or other online platforms operated by third parties. Ifyou follow links to sites not affiliated or controlled by us, you should reviewtheir privacy and security policies and other terms and conditions. We do notguarantee and are not responsible the privacy or security of these sites,including the accuracy, completeness, or reliability of their information.Information you provide on public or semi-public venues may also be viewable byother users of the Services and/or users of those third-party online platformswithout limitation as to its use by us or by a third party. Our inclusion ofsuch links does not, by itself, imply any endorsement of the content on suchplatforms or of their owners or operators except as disclosed on the Services.We expressly disclaim any and all liability for the actions of third parties,including but without limitation to actions relating to the use and/ordisclosure of personal information by third parties. Any information submittedby you directly to these third parties is subject to that third party’s privacypolicy.

5. DATA SECURITY

5.1 Any information yousend to us electronically, while using the Services or otherwise interactingwith us, may not be secure while in transit. No security measures are perfector impenetrable, and we cannot guarantee “perfect security.”

6. CALIFORNIA RESIDENTS

6.1 We do not share personal information as defined by California Civil Code Section 1798.83(“Shine The Light Law”) with third parties for their direct marketing purposes.

6.2 This section applies to you only if you are a Californiaresident (“resident” or “residents”). For purposes of this section, referencesto “personal information” shall have the same meaning as such term is definedunder the California Consumer Privacy Act (“CCPA”).

Processing of PersonalInformation

In the preceding 12months, we collected and (where indicated below) disclosed for a businesspurpose the following categories of personal information about residents:

The specific business or commercial purposes for which we collect your personal information and the categories of sources from which we collect your personal information are described in the section above, HOW WE COLLECT AND USE INFORMATION ABOUT YOU. We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Policy. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide,improve and develop the Services, to comply with any applicable legal obligations, to enforce any applicable terms of service, to protect or defend the Services, our rights, the rights of our users, or others, for the purpose of combatting fraud, or to otherwise operate our business.

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We disclosed personalinformation over the preceding 12 months for the following business orcommercial purposes:  

• to communicate with you, provide you with products and services, to market to you, etc.
• to provide you with services you have requested.

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Selling and/or Sharing of Personal Information

We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in thepreceding 12 months. Further, we do not have actual knowledge that we “sell” or“share” personal information of residents under 16 years of age.

Your California Privacy Rights

As a California resident, you may have the rights listed below in relation to personal information that we have collected about you. However,these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to Know. You have a right to request the following information about our collection, use and disclosure of your personal information:
   
  • categories of personal information we have collected, disclosed for a business purpose;      
   
  • categories of sources from which we collected personal information;
   
  • the business or commercial purposes for collecting personal information;
   
  • categories of third parties to whom the personal information was disclosed for a business purpose; and
   
  • specific pieces of personal information we have collected‍
• Right to Delete.     You have a right to request that we delete personal information we     maintain about you.
• Right to Correct.     You have a right to request that we correct inaccurate personal     information we maintain about you.

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

7. HOW TO CONTACT US

7.1 Should you have any questions about our privacy practices or this Privacy Policy, please email us atinfo@neospartners.comor contact us at (858) 727-9690.

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