Introduction:

CORNERSTONE takes your privacy and the security of your personal information very seriously.  Please take a moment to read this Privacy Policy and learn about CORNERSTONE’S general privacy and information security principles.  This Policy applies to the website www.crefunds.com ("Website").  This Policy should be read in conjunction with the Terms of Use Agreement for CREFUNDS.COM web site

By using this Website and submitting your personal information to us, you agree to our using your personal information in accordance with this Policy.  Please do not send us any personal information if you do not want it to be treated in accordance with this Policy.

What is "Personal Information"?
Your personal information means information by which you, as an individual, can be identified.  It includes information such as your name, mailing address, telephone number, and e-mail address.  Your personal information may also include sensitive personal data, such as your age, marital status, tax identification number, investments in our funds, account information, assets, debts, income, net worth, employment history, financial information, beneficiary information, personal bank account information, credit history information, broker dealer, financial advisor, IRA custodian, account joint owners and other similar parties.

Information We Collect
CORNERSTONE does not currently collect personal information through this Website except for information that:

1.      your Internet service provider automatically provides to our web server, such as its web site address and possibly your e-mail address; 

2.      you send to us in an e-mail message using the e-mail facility that is part of this Website's functionality;

3.      you send us when you sign up on this Website for newsletters, events or the like;

4.      you send us via this Website in the course of an application for employment;

5.      you submit to us in a common gateway interface (CGI) form (for example, when you submit a search request on this Website).

How We Use Your Personal Information
CORNERSTONE may use personal information collected from this Website for the following purposes:

·        responding to and otherwise processing your requests and applications;

·        monitoring and improving the performance and content of this Website, analyzing Website usage and creating internal reports; and

·        contacting you and delivering information (including marketing material) to you that you have requested or that we believe may interest you, such as administrative notices, details of our products and services and communications relevant to your use of our Website. 

We will treat your personal information in accordance with this Policy and applicable law.

Disclosure to Third Parties
We may use third parties to provide data processing, hosting, storage, emergency recovery services, and similar services to us and it may be necessary for these third parties to have access to personal information you have provided on this Website.  These third parties will be required to enter into confidentiality agreements with CORNERSTONE that provide adequate protections for the safety and security of your personal information. If you provide personal information directly to any of our third party service providers, then their use of your personal information is subject to their privacy and security policies.

We will not otherwise disclose your personal information to third parties without your consent, unless required or permitted to do so by law, including the exercise or defense of our legal rights.  We have no obligation to monitor the use of this Website or to retain the content of any user session. However, we reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, regulation, legal process, or governmental request or to cooperate with law enforcement and other authorities in investigating a claim of illegal activity.

Cookies
In order to better enable us to provide you with customized services and a Website that is easier to use (for example, by allowing you to enter your user name and password less frequently), this Website will place a small data file, known as a "cookie," on your hard drive.  You can choose to not receive a cookie file by enabling your web browser to refuse cookies or to prompt you before you accept a cookie.  If you do that, the full functionality of this Website may not be available to you  and you may be required to enter your user name and password more frequently.

IP Addresses
We use IP addresses to analyze trends, administer the Website, track users' movements, and gather broad demographic information for aggregate use.  We do not link IP addresses to personal information.

Links to Other websites
For your convenience, this Website may provide links to other websites.  Please be aware that this Policy applies only to the website at www.crefunds.com operated by CORNERSTONE and not to any other site.  We recommend you review the privacy and security policies of each website you visit before providing any personal information.

Ownership of Materials
CORNERSTONE owns the information sent to us by means of this Website.  If you choose to send us an e-mail message (including submission of your résumé), we may retain the content of the e-mail, your e-mail address and our response.

Security
We use physical, electronic and procedural safeguards to protect your personal information. We employ encryption technologies, user authentication systems (e.g., passwords and personal identification numbers) and access control mechanisms to secure access to our computer systems and files. Please be aware that our information security software may cause some e-mail messages sent via this Website not to be received.

You should be aware that information sent to us using this Website may not be secure in transmission.  Please be aware of this when sending any communications.

Modification of Policy
We may modify this Policy at any time to ensure that it accurately reflects the regulatory environment in which we operate and our data collection and disclosure practices.  Your continuing use of this Website constitutes your acceptance of any modification to this Policy in effect at the time of your access. No modification or attempted modification of this Policy by you shall be binding on CORNERSTONE.

All changes to this Policy will be posted on this Website and we encourage you to check back from time to time to review any updates that have been made.

How to contact us
If you have any questions about this Policy or our use of your personal information, please email us at info@crefunds.com.