Privacy Policy

Overview

This privacy policy discloses the privacy practices for SmartETFs.com and Guinness Atkinson Asset Management, and applies solely to information collected by this website or as relevant to digital communications associated with this website, including email and social media.

Information We Obtain

Guinness Atkinson Asset Management and SmartETFs (“we”, “us”, or “our”) may obtain personal information from you through the site, including but not limited to information you provide when you:

• Download marketing or research collateral;

• Contact us with questions or requests for information

For purposes of this privacy policy, “personal information” includes information that can be used to identify you, such as your name, address, company affiliation, e-mail address, phone number, or investor type.

Collection of Information Using Cookies and Other Tools

We may use “cookies” or other electronic tools to collect information such as:

• IP address;

• Browser type;

• Operating system;

• Computer platform;

• Information about your mobile device;

• Geo-location data; and

• The state or country from which you accessed the site

We may also use cookies or other electronic tools to collect and compile statistical and other non-personal information about your use of the site and the services provided on the site, such as:

• The web pages you visit on the site;

• The date and time of your visit;

• The number of links you click within the site;

• The functions and features you use on the site;

• The searches you request on the site;

• The data you save on or download from the site; and

• The websites you visited immediately before and after visiting our site

A cookie is a small text file placed on your computer. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of the site, such as certain pages for which you need to log in, will not function properly.

How We Use Your Information

We use the information collected through the site for purposes such as:

• To enhance your experience with the site;

• To provide you with the services or information that you request;

• To communicate with you (g., to provide information about products or services in which you have indicated an interest);

• To combat fraud;

• To fulfill any other purpose for which you provided the information;

• To conduct research and analysis (anonymously and in the aggregate); and

• To provide information promotions to you regarding our products and services

To assist us with the uses described in this privacy policy, information we have collected from or about you through the site may be combined with or enhanced by other information about you that we have from other online or offline sources, including from our service providers.

How We Share Your Information

We may share your personal information with our affiliates and subsidiaries under narrow circumstances, including but not limited to:

• With our service providers that help us to operate our business (e.g., to deliver the information or services requested by you; to perform other activities related to such information or services; and to provide you with promotions from SmartETFs or Guinness Atkinson Asset Management);

• In connection with any proposed or actual sale or other transfer of some or all assets of SmartETFs, and/or any proposed or actual sale or merger of SmartETFs or Guinness Atkinson Asset Management (including in the event of a reorganization, dissolution or liquidation);

• As otherwise required or permitted by law; and/or

• Any other sharing to which you consent

We may also share your personal information with non-affiliated third parties, such as Google Analytics, that use technologies such as cookies to help us analyze how visitors use the site. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the site. To learn more about Google Analytics and how to opt out, please visit Google Analytics’s Privacy Page.

Security

We take precautions to protect your information. When you submit sensitive information via the site, your information is protected both online and offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information.

Email Communications

You can unsubscribe or choose not to receive promotional materials from SmartETFs by following the specific instructions in the e-mail or other communication you receive or by e-mailing us at [email protected]. Please note that it may take some time to process your request, consistent with applicable law.

Social Media

SmartETFs and select employees maintain profiles and/or pages on various social media sites, including Twitter, Facebook, YouTube, Instagram, and LinkedIn. If you choose to “Follow” SmartETFs on Twitter, Facebook, YouTube, Instagram, or LinkedIn or take any similar action on another social media site, you are providing your consent to receive informational updates, including solicitations, from SmartETFs. To stop receiving this information from SmartETFs on a social media site, you must follow the procedure established by the site. For example, on Twitter, you must click “Unfollow” on SmartETFs’ profile page.

The information contained in SmartETFs’ social media profiles and pages is current as of the date of publication (or such earlier date as referenced) and is subject to change without notice. SmartETFs has no obligation to update any or all of such information. Additionally, SmartETFs personnel other than the author(s) may provide oral or written market commentary or investment ideas to SmartETFs’ clients or prospects that differ from the views expressed.

All amounts, market value information, and estimates have been obtained from outside sources where indicated or represent the good faith judgment of SmartETFs. Where such information has been obtained from outside sources, we cannot guarantee its accuracy or completeness. Past performance is not a guarantee or reliable indicator of future results. Our social media profiles and pages are not intended to be an offer or solicitation with respect to the purchase or sale of any security or other financial instrument or any investment management services. They are provided for information purposes only, do not constitute investment advice, and should not be used as the basis for any investment decision. They also do not purport to provide any legal, tax, or accounting advice.

Twitter, Facebook, YouTube, Instagram, and LinkedIn are owned by third parties unaffiliated with us. We are not responsible for the terms of use or policies of any of the social media sites on which it maintains a profile or page or any third-party sites to which they are linked, and you use these sites at your own risk. We are not responsible for and do not endorse any content, advertising, products, advice, opinions, recommendations, terms of use or privacy policies, or other materials on or available from third parties.

While we may monitor postings by third parties on its profiles and pages, we are not able to review them before they are displayed, and any such postings are the views and responsibilities of the posters. We do reserve the right to edit or remove any post for any reason and to block followers to the extent permitted by the sites. If we do not remove a third-party post, it is not an endorsement of the content.

SmartETFs does not provide customer service, conduct financial transactions, or accept customer complaints through its social media profiles and/or pages. Never disclose account or other personal financial information on any of our social media profiles or pages.

Links to Third-party Websites

The site may include links to third-party websites. Since we do not control third-party websites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

Questions Regarding this Online Privacy Policy

If you have questions regarding this privacy policy, please contact us at [email protected]

Updates

Our privacy policy may change from time to time and all updates will be posted on this page. If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone at (866) 307-5990 or [email protected].

Carefully consider the funds’ investment objectives, risk factors, charges, and expenses before investing. This and additional information can be found in the funds’ summary or full prospectus, which may be obtained by calling (866) 307-5990 or by visiting SmartETFs.com. Please read the prospectus carefully before investing.

Social Media Site

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Social Media Site

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Social Media Site

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Contact Us

Do you have questions or require additional information? You can reach us by filling out this form or using the contact information below.

SmartETFs

Investors
(866) 307 – 5990
[email protected]

Media Inquiries
Victoria Odinotska, KANTER PR
(703) 685 – 9232

SmartETFs HQ
251 South Lake Avenue
Suite 800
Pasadena, CA 91101

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Note: Please do not send personal information via email. Direct any transaction requests or address changes to shareholder services at (866) 307 – 5990. By checking the box above you agree to subscribe to the SmartETFs email list. SmartETFs is committed to protecting your privacy. We use your registration information to customize and deliver additional resources via email and mail, including SmartETFs newsletters and product fact sheets. If you don’t want to receive mail or email from us, simply leave the box at the bottom of this page unchecked. To learn more about how we handle your personal information, read our Privacy Policy.

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* Items with an asterisk are required.

Note: Please do not send personal information via email. Direct any transaction requests or address changes to shareholder services at (866) 307 – 5990. By checking the box above you agree to subscribe to the SmartETFs email list. SmartETFs is committed to protecting your privacy. We use your registration information to customize and deliver additional resources via email and mail, including SmartETFs newsletters and product fact sheets. If you don’t want to receive mail or email from us, simply leave the box at the bottom of this page unchecked. To learn more about how we handle your personal information, read our Privacy Policy.

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Choose A Brokerage Firm

The [FUND NAME ETF] is available through many brokerage firms, including those below.

The inclusion of these links is not an endorsement from any of these firms and does not represent a recommendation or solicitation to purchase or sell any securities. Additionally, the inclusion of these links does not represent an endorsement by SmartETFs of any of these firms.