Terms of Use

The web site located at www.sparkchange.io ("Web Site") developed, distributed or owned by Spark Change Group Inc., or one of its U.S. subsidiaries or investment specialists (collectively "SparkChange," "we," "our,", "us") are referred to herein collectively as the "Web Site." Please read these terms and conditions of use ("Terms") carefully before using the Web Site or any of the information or services provided by SparkChange in connection with the Web Site. By using the Web Site, you acknowledge that you have read and understood these Terms and accept and agree to be legally bound by them. If you do not accept and agree to these Terms, you are not an authorized user of the Web Site or any of the information or services provided by SparkChange in connection with the Web Site and should promptly terminate all use thereof. The term Web Site includes any other web site owned, operated, licensed, or controlled by SparkChange.  The terms "you" and "your" mean you and any entity you may represent in connection with the use of the Web Site. These Terms are in addition to any other agreements between you and SparkChange, including any customer or account agreements, and any other agreements that govern your use of information, content, tools, products and services available on and through the Web Site. You may use your browser to download or print a copy of these Terms for your records.

These Terms were last updated on September 16, 2021.

SparkChange reserves the right, in its sole discretion, to change, modify, add, or remove portions of these Terms at any time. We suggest that you check these Terms periodically for changes. The Terms can be accessed from a link at the bottom of the pages of the Web Site. Any changes, modifications, additions to, or deletions from these Terms shall be effective immediately upon posting on the Web Site. You acknowledge that, by using the Web Site after we post changes to these Terms, you accept and agree to be legally bound by these Terms as changed. SparkChange may also from time to time offer other services that are governed by different terms and conditions.

No Offer or Advice

The Web Site and its content are provided for informational and educational purposes only. Nothing on the Web Site constitutes a recommendation, solicitation or offer by SparkChange to sell or buy any security or investment product or service. The Web Site does not, and it is not intended to, provide any financial, investment, retirement planning, insurance, legal, accounting or tax advice. You are solely responsible for determining whether any investment, investment strategy, security or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. The Web Site should not be used or relied upon by you as a substitute for independent research or professional tax, financial or legal advice. You should seek such professional tax, financial or legal advice for your specific situation. You acknowledge that your requests for information in connection with the Web Site are unsolicited.

Before acquiring the shares of any investment fund by purchase or exchange, it is your responsibility to read the fund's prospectus or offering materials. For more information on any fund, contact your registered representative (financial professional) or download a prospectus or offering materials by clicking on the applicable link appearing throughout the Web Site. Prospectuses contain more complete information on advisory fees, distribution charges, and other expenses, and should be read carefully before investing or sending money. Past performance does not guarantee future results. Please remember that there is no assurance that the objective of any fund will be achieved. Please also note that investment return and principal value will fluctuate. All investments involve risks and may lose value. An investment in a fund or other investment product is not a bank deposit and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.

Jurisdiction

Unless otherwise specified, SparkChange controls, operates and services the Web Site from its offices within the United Kingdom. The services and products described and information provided through the Web Site are directed to and are intended to be made available only to qualified investors in the United States and are not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject SparkChange or any of its investment products or services to any registration requirement within such jurisdiction or country. Persons who access the Web Site do so on their own initiative, and are responsible for compliance with applicable local laws and regulations.

Access to Web Site/Mobile Apps and Content

SparkChange reserves the right, in its sole discretion, to withdraw access to or modify any of the information, tools, content or services provided in connection with the Web Site (the "Content") at any time without providing notice to you. All Content is presented as of the date published or indicated, and may become inaccurate as a result of subsequent market events or for other reasons. Although SparkChange makes every attempt to provide accurate and timely Content, SparkChange does not guarantee or ensure the accuracy, completeness, currency or authenticity of any Content or functionality, or transmission of any Content from the Web Site/Mobile Apps to you. Furthermore, you are solely responsible for making sure that you are receiving up-to-date Content from the Web Site, including, but not limited to, by appropriately setting cache settings on your web browser. SparkChange may withdraw access to or modify any of the investment products and services described on the Web Site at any time without providing notice to you.

Trademarks, Copyrights and other Intellectual Property

All Content is owned or licensed by SparkChange and its third-party information providers and is protected by applicable copyrights, trademarks, service marks and/or other intellectual property rights. All Content is solely for your personal, non-commercial use or that of your clients. Accordingly, you may not copy, reproduce, modify, sell, reuse, republish, post, frame, deep link, transmit, display, distribute or use for any commercial or unlawful purpose any Content, including, without limitation, any text, images, video, audio, code, user interface design or logos on the Web Site, without SparkChange's express prior written permission. If permitted by the Web Site, you may download Content for your personal use or that of your clients so long as you retain all copyright and other proprietary notices set forth in the Content. Please note that, notwithstanding the foregoing, if you have access to Content that is marked for use by financial professionals only, then you are not permitted to disclose such Content to your clients and your clients are not permitted to use such Content in any way. Any unauthorized use of Content violates the intellectual property rights of SparkChange and may violate copyright laws, trademark laws, the laws of privacy and publicity and communications regulations and statutes.

All trademarks, service marks, trade names, and logos ("Marks") displayed on the Web Site/Mobile Apps are proprietary to SparkChange and/or any respective third-party owners. Nothing contained on the Web Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any Mark displayed on the Web Site without the express prior written permission of SparkChange or such other third-party owner. Your use of the Marks displayed on the Web Site, except as provided herein, is strictly prohibited.

Prohibited Uses

Any use or attempted use of the Web Site (i) for any unlawful, unauthorized, fraudulent or malicious purpose, or (ii) that could damage, disable, overburden, or impair any server, or the network(s) connected to any server, or (iii) that could interfere with any other party's use and enjoyment of the Web Site, or (iv) to gain unauthorized access to any other accounts, computer systems or networks connected to any server or systems through hacking, password mining or any other means, or (v) to access systems, data or information not intended by SparkChange to be made accessible to a user by hacking or any other means, or (vi) to obtain or attempt to obtain any materials or information through any means not intentionally made available by SparkChange, or (vii) for any use other than the purpose for which it was intended, is prohibited.

In addition, users and visitors of the Web Site may not, without SparkChange's express prior written permission:

• copy, reproduce, republish, upload, post, transmit, or distribute in any way Content in any manner inconsistent with the purposes for which it is offered by SparkChange to its customers, prospective customers or members of the general public;
• copy, modify, or display SparkChange's name or logo, or any text, graphic images, or other Content;
• redeliver any of the pages, text, images, or other Content using "framing" technology;
• use devices (including software) that are designed to provide repeated automated access to the Web Site other than those made generally available by SparkChange;
• deep link or employ software or any automatic device, technology or algorithm, to "crawl," "scrape," search or monitor the Web Site, provided that generally available third-party web browsers may be used without SparkChange's authorization;
• include "SparkChange" or any other SparkChange trademark, the name of any SparkChange personnel, or any variation of any of the foregoing, as a metatag, hidden textual element, or any other indicator that may create a false or misleading impression of affiliation, sponsorship, or endorsement between any user and/or site and SparkChange;
• collect or store personal data about other users of the Web Site;
• upload, email or otherwise transmit to the Web Site any material that contains viruses or any other computer code, files or programs that might interrupt, limit or interfere with the functionality of any computer software or hardware of file communications equipment that is owned, leased or used by SparkChange;
• resell or provide commercial use of the Web Site or the Content, or create any derivative use of the Web Site or the content therein;
• make use of any data mining, robots, or similar data gathering and extraction tools; or
• reproduce, duplicate, copy, sell, resell, visit, or otherwise exploit for any commercial purpose the Web Site.

SparkChange reserves the right to take whatever lawful actions it may deem appropriate in response to actual or suspected violations of the foregoing, including, without limitation, the suspension or termination of the user's access and/or account. SparkChange may cooperate with legal authorities and/or third parties in the investigation of any suspected or alleged crime or civil wrong. Except as may be expressly limited by the SparkChange Privacy notice, SparkChange reserves the right at all times to disclose any information as SparkChange deems necessary to satisfy any applicable law, regulation, legal process or governmental request, or to edit, refuse to post or to remove any information or materials, in whole or in part, in SparkChange's sole discretion.

Copyright Agent

SparkChange respects the intellectual property rights of others, and we ask all those that access the Web Site to do the same. Pursuant to Section 512(c)(2) of the Copyright Revision Act, as enacted through the Digital Millennium Copyright Act, SparkChange designates an agent, as described below, to receive notifications of claimed infringement. If you reasonably believe that your work has been copied in a way that constitutes copyright infringement, please provide SparkChange's Copyright Agent the following information:

• an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright interest;
• a description of the copyrighted work that you claim has been infringed;
• a description of where the material that you claim is infringing is located on the Web Site;
• your address, telephone number, and email address;
• a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law;
• a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner's behalf.

SparkChange's Compliance Department is its Copyright Agent for notice of claims of copyright infringement on its site. SparkChange's Compliance Department address is: SparkChange, One Beacon Street, 14^th Floor Boston, MA 02108.

Connection Requirements; Passwords and Security

To ensure a high level of confidentiality and security, SparkChange maintains physical, electronic and procedural safeguards that meet or exceed federal standards. However, you are responsible for providing and maintaining, at your own risk, option and expense, any hardware, software and communication lines required to access and use the Web Site, and SparkChange reserves the right to change the access configuration of the Web Site at any time without prior notice. Please note that wireless networks and Wi-Fi network speeds vary by provider and geographic location. We are not responsible for limitations of such services used to access the Web Site.

To access password-protected content on the Web Site, you must complete the registration process by providing us with current, complete and accurate information as prompted by the applicable registration form, and choose a password and username. You are entirely responsible for maintaining the confidentiality of your login credentials and for any and all activities that occur while logged in or accessing personal account information through the third-party links provided on the Web Site. You will be logged out of certain secure portions of the Web Site after a period of inactivity, at which time you will be required to re-enter your credentials to access secure information. You agree to (a) immediately notify SparkChange of any unauthorized use of your account or any other breach of security of which you become aware, and (b) exit completely from your account at the end of each online session. SPARKCHANGE WILL NOT BE LIABLE FOR ANY LOSS THAT YOU MAY INCUR AS A RESULT OF SOMEONE ELSE USING YOUR PASSWORD OR ACCOUNT, EITHER WITH OR WITHOUT YOUR KNOWLEDGE. HOWEVER, YOU COULD BE HELD LIABLE FOR LOSSES INCURRED BY SPARKCHANGE OR ANOTHER PARTY DUE TO SOMEONE ELSE USING YOUR ACCOUNT OR PASSWORD. YOU MAY NOT USE ANYONE ELSE'S ACCOUNT AT ANY TIME.