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Terms of Use

Please read this page carefully before using this Site and the materials accessible through this Site. By using this Site, you are agreeing to be legally bound by the following terms. We reserve the right to amend these terms. Your continued use of this Site constitutes your agreement to such changes.

LIMITED LICENSE

Oleet & Company, LLC, and all its related entities, (“Oleet & Co.”) provides this website, www.oleet.com (together with its contents and all sub-websites, the “Site”) for your informational purposes only.

Subject to these terms, Oleet & Co. grants you a non-exclusive, non-transferable, limited right to display this Site and download the material displayed on this site (the “Materials”) solely to view general information regarding Oleet & Co.’s businesses.

You agree to treat the information you obtain from the Site that requires a password or similar identification procedure as confidential. This does not include the right to reproduce, modify, make collections or compilations of, distribute, or publicly display the Site or the Materials. You must not transfer the Materials to any other person or entity. You must retain, on all copies of the Materials downloaded, all copyright and other proprietary notices contained in the Materials. You agree to abide by all additional restrictions displayed on the Site from time to time. Any unauthorized use of the Site, misuse of passwords and or any other information listed on the Site is prohibited. Except as expressly provided herein, Oleet & Co. does not grant you any express or implied license or permission under any patents, trademarks, copyrights or trade secret information.

You agree to access the Materials and this Site manually, by request, and not automatically, through the use of a “bot” or similar program, or by other means. You agree not to take any action, alone or with others, that would interfere with the operation of this Site, to alter this Site in any way, or to impede others’ access to and freedom to enjoy and use this Site as made available by Oleet & Co.

NON SOLICITATION OR RECOMMENDATION

The contents of this Site are prepared by Oleet & Co. for general information purposes only and should not be construed as an offer or solicitation or advice or recommendation for purchase or sale of any of the schemes or products made available through the Site. Nothing contained on this Site shall be construed to be advice, invitation, inducement, offer, recommendation or solicitation for investment or disinvestment in any financial instrument.

Oleet & Co. has not considered the investment objectives, financial situation or particular needs of the user. It is the responsibility of the user to evaluate all such matters.

OWNERSHIP AND TRADEMARKS

This authorization is not a transfer of title in the Site, or the Materials or copyrights therein. All content included on this Site, such as graphics, logos, articles and other materials, is the property of Oleet & Co. or others and is protected by copyright and other laws.

All trademarks and logos displayed on this Site are the property of their respective owners, who may or may not be affiliated with our organization.

NO WARRANTY OR RELIANCE

The materials may contain inaccuracies and errors. Oleet & Co. does not warrant the accuracy or completeness of the materials or the reliability of any advice, opinion, statement or other information displayed or distributed through this site. Oleet & Co. disclaims any duty to update this site.

This site, the information and materials on this site, and, to the extent applicable, any software made available on this site, are provided “as is” without any representation or warranty, express or implied, of any kind, including, but not limited to, warranties of merchantability, noninfringement, or fitness for any particular purpose. Some jurisdictions do not allow for the exclusion of implied warranties, so the above exclusions may not apply to you.

This Site, and access to the Site, may not be available at all times and may be impeded by a range of factors including technology failures or lack of capacity. You are responsible for obtaining and maintaining your own information and communications technology in order to access the Site.

Nothing contained on this Site constitutes financial, legal, tax or other advice, nor is any information or material on this Site to be deemed a recommendation to buy or sell any securities or is to be relied upon for the purpose of making or communicating investment or other decisions. Any transactions listed on this Site are included only as representative transactions.

FORWARD LOOKING STATEMENTS

Past performance is no guarantee of future results. Certain of the information contained herein may be based upon forward-looking statements. Forward-looking statements are inherently uncertain and factors affecting the markets in general or industries or issuers in particular may cause events or results to vary from those described herein. Accordingly, you should not rely on or draw conclusions from forward looking statements.

THIRD-PARTY SITES

As a convenience to you, Oleet & Co. may provide, on this Site, links to websites operated by other persons or entities. If you use these sites, you will leave this site. Oleet & Co. makes no warranty or representation regarding, and does not endorse, any linked websites or the information appearing thereon or any of the opinions, ideas, products or services described thereon. Links do not imply that any linked website is authorized to use any of Oleet & Co.’s trademarks, trade names, logos or copyright symbols. In addition, these websites may be governed by a different privacy policy or security practices from this Site so it is important that you read the policies of those sites before sharing your personal information. Users shall comply with request(s) of Oleet & Co. or any of the third party providers to protect their respective rights in the information and services available on the Site.

EXTERNAL LINKS TO THIS SITE

Oleet & Co. shall have no liability for third party content or websites linking to or framing this Site. All links to this Site must be approved in writing by Oleet & Co., except that Oleet & Co. consents to links in which: (i) the link is a text-only link containing only the name “Oleet & Co.”; (ii) the link “points” only to www.oleet.com and not to deeper pages; (iii) when activated by a user, the link displays that page full-screen in a fully operable and navigable browser window and not within a “frame” on the linked website; and (iv) the appearance, position, and other aspects of the link neither creates the false appearance that an entity or its activities or products are associated with or sponsored by Oleet & Co. nor damages or dilutes the goodwill associated with Oleet & Co.’s name or trademarks.

Oleet & Co. reserves the right to revoke this consent to link at any time.

INFORMATION PROVIDED BY YOU

Do not send any confidential or proprietary information to Oleet & Co. via the Site. No information or materials that you provide to Oleet & Co. via this Site will be considered or treated as confidential or proprietary. By providing any such information or materials to Oleet & Co., you grant to Oleet & Co. an unrestricted, irrevocable, worldwide, royalty-free, non-exclusive license to use, reproduce, modify, publicly display, publicly perform, transmit and distribute such information and materials, and you further agree that Oleet & Co. is free to use any ideas, concepts or know-how that you or individuals acting on your behalf provide to Oleet & Co. You agree not to use the Site to distribute, email or post any advertising, promotion or solicitation without our prior approval. You agree not to use the Site to upload, display or distribute any materials that are defamatory, threatening, obscene, harassing, or otherwise unlawful, or that incorporate the copyrighted, confidential or proprietary material of any other person or entity.

LIMITATIONS OF DAMAGES

None of Oleet & Co. or any of its directors, partners, members, employees, agents, affiliates or subsidiaries are liable for any direct, indirect, special, consequential loss, liability, cost, claim, expense or damages of any kind (including, without limitation, any lost profits, business interruption, loss of information or programs or other data on your information handling system) whether in contract or in tort, (including negligence) that are related to the accuracy, inaccuracy, use of, or the inability to use, the content, materials and functions, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, of this site or any linked website, even if Oleet & Co. is expressly advised of the possibility of such damages.

NO WARRANTIES FOR CONTENT

The user acknowledges and agrees that information provided through the Site is provided on an “as is” and “as available” basis. Oleet & Co. disclaims, to the fullest extent of the law, all implied or express warranties, including but not limited to, implied warranties of merchantability and fitness for a particular purpose, nor does it guarantee the timeliness, reliability, quality, completeness, or usefulness or continued availability of any of the contents available on the Site. Subject to compliance with requirements of applicable laws, neither Oleet & Co. nor any of its third party service providers shall have any responsibility to update or maintain the data and services made available on this site or to supply any corrections, updates, or releases in connection therewith. The material available on this Site is based upon information that Oleet & Co. considers reliable and endeavors to keep current. The information contained on this Site has been obtained from various sources and may not have been updated since the original date of posting on the Site and may not reflect the current views of Oleet & Co. Neither Oleet & Co. nor any of its partners, employees, agents, advisors or any expert used by it for providing the content for this Site or any information made available on the Site shall in any circumstance be liable for any loss or damage caused by a user’s reliance on such information. Oleet & Co. may discontinue or alter any of the services / products / facilities offered through the Site, without providing any prior notification to the user.

CHANGES

Oleet & Co. reserves the right, at its sole discretion, to grant or revoke authority to use this Site or to change, add, suspend or remove the information, products or services described in the Site or the Materials at any time without prior notice to you and without any liability to you.

Oleet & Co. may also impose limits on certain features and services or restrict your access to parts or all of this Site without notice or liability. Oleet & Co. may terminate the authorization, rights and license given above and, upon such termination, you shall immediately cease using and destroy all Materials.

INTERNATIONAL USERS AND CHOICE OF LAW

This Site is not intended for use by any person or entity who is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation or which would subject Oleet & Co. or its affiliates to any registration requirement within such jurisdiction.

Oleet & Co. makes no representation that the information available on this Site is appropriate or available for use in any jurisdiction. Prior to accessing the Site, users are required to ensure themselves whether the information available on this Site can be accessed and utilized in their respective jurisdictions and observe any relevant restrictions thereto. The user shall be solely responsible for compliance with all applicable laws and shall satisfy that they are not subject to any regulatory requirements which restrict or prohibit them from accessing or using the site.

The products, services or facilities have not been registered under any securities law of any foreign jurisdiction and are only for the information of any person in any jurisdiction where it may be lawful to offer such products, services and facilities. Oleet & Co. will not undertake any requisite registration within any prohibited jurisdiction.

This Site is governed by the laws of the State of Delaware, without giving effect to its conflict of laws provisions.

This page constitutes the entire agreement between Oleet & Co. and you with respect to your use of this Site. Any cause of action you may have with respect to your use of this Site must be commenced within one (1) year after the claim or cause of action arises. If for any reason a court of competent jurisdiction finds any provision of this page or portion thereof, to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to affect the intent of the provision, and the remainder of this page shall continue in full force and effect.

ANTI-CORRUPTION

Oleet & Co. is committed to providing the highest quality services to its clients. To achieve this, anyone working for or on behalf of Oleet & Co. (including staff members, vendors, agents, suppliers or service providers) is expected to maintain the highest ethical standards, to conduct themselves with integrity and in a manner that excludes consideration of personal advantage and the interests of other clients. We do not tolerate bribery or corruption in any form.Please read this page carefully before using this Site and the materials accessible through this Site. By using this Site, you are agreeing to be legally bound by the following terms. We reserve the right to amend these terms. Your continued use of this Site constitutes your agreement to such changes.

Privacy Policy

In the ordinary course of business, Oleet & Co. collects, uses, and shares personal information pertaining to its partners, employees, clients, and others. Obtaining this information is important to our ability to conduct our operations and to deliver the highest level of service, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information that a relevant Oleet & Co. entity may collect about you in compliance with applicable legal and regulatory requirements, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. The following privacy policy is intended to apply only to personally identifiable information you provide to Oleet & Co. from time to time via this Site.

HOW WE COLLECT INFORMATION ABOUT YOU

When you visit our Site, our web servers collect the details of your operating system, browser version, domain name and IP address and the details of the web site you linked from to the Site. Our web servers may seek to place a “cookie” (a small data file) on your computer’s hard drive, which allows the server to recognize your computer when you visit again. If you prefer not to accept cookies, you can set your browser to reject them or to alert you before one is placed.

There are parts of this Site where we may need to collect personal information from you for a specific purpose, such as to provide you with certain information you request. If you voluntarily submit information to our website (for example, in a request for general information or through the submission of a business proposal), we may record and use any personally identifiable information, such as your name, phone number, fax number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request and marketing and business communications. If you do not provide all the information we need, we may not be able to give you the information you request.

Please also note we have certain responsibilities under various regulations to verify the identity of clients and may need to make certain inquiries and obtain certain information from you for that purpose. You confirm that all information you supply will be accurate and that we may disclose such information as we consider necessary to comply with any reporting or legal and regulatory requirements.

USES OF COLLECTED INFORMATION

The principal purposes for which we process and store your personal information are, or may in the future be:

DISCLOSURES OF YOUR PERSONAL INFORMATION WITHIN OLEET & CO.

In order to provide efficient and reliable services and to improve service options available to you, we may share your personal information with our subsidiaries or affiliates. For this purpose, we may transfer the information you provide outside your country to an Oleet & Co. entity in another country that does not have similar data protection legislation and may provide a lower level of protection for your information. By submitting any information you consent to these transfers. We have taken certain measures outlined below to try to ensure the security of your information.

Business Continuity Plan

Oleet & Company, LLC (“Oleet & Co.”) is committed to protecting the interests of our clients in the event of Significant Business Disruption (“SBD”). The Business Continuity Plan summary below details how we will respond to events that significantly disrupt our business.

Our Firm will respond as immediately as practicable to an SBD by:

In the unlikely event that we determine that we are unable to continue our business, we will notify our clients to that effect and make available to each of them any records and other documents we maintain related to the continuation of their business.

In the event of an SBD, we will authorize employees to remain at each person’s respective home. Each individual has home telephone and/or cellular phone contact information. Actual physical office space is not necessary to the continuity of our operations during a dire emergency and for short periods of time. In the event of a long-term SBD, we will consider moving our staff from affected offices to the closest of our unaffected office locations.

Oleet & Co. has a comprehensive architecture for the electronic back-up and recovery of its data. Besides for localized primary data facilities at its main office, Oleet & Co. manages a global repository of all company data that is built upon the secure Box cloud platform. Characteristics of this platform include:

We communicate with our clients using telephone, e-mail, our website, fax, US mail, delivery services, and in-person visits at our Firm or at our clients’ locations. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by e-mail but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the US mail or rapid delivery service.

Registered staff of Oleet & Company, LLC is affiliated with Ecoban Securities Corporation, a broker-dealer registered under the Securities Exchange Act of 1934, and a member firm of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). A summary of the Business Continuity Plan for Ecoban Securities Corporation is located on its website. If you have questions regarding our Business Continuity Plan, you may contact us at compliance@oleet.com. Oleet & Co. will review this Business Continuity Plan at least annually to modify it for any changes in our operations, structure, business or location.

Regulation

CHINA

Oleet Investment Management (Shanghai) Company, Limited, company number MA1K37ET9, is a company incorporated in the People’s Republic of China to engage in investment management (excluding capital investment services), investment consulting, investment management consulting, business information consulting, and enterprise management consulting and related activities. It is not registered with the China Securities Regulatory Commission or other regulatory authorities in the People’s Republic of China to conduct any regulated activities. The contents of this website have not been reviewed by any regulatory authority in the People’s Republic of China. You are advised to exercise caution in relation to the information contained in this website. If you are in any doubt about any of the contents of this website, you should obtain independent professional advice.

The material on this website is provided for information only and is not intended to be, or construed as being, investment advice or services, nor is anything contained in it a recommendation of any particular security or investment. Nothing on this website is, or should be construed as, an offer to, or a solicitation of, any person in the People’s Republic of China, to sell or buy any security or investment.

HONG KONG

Oleet & Company Asia (Hong Kong) Limited, company number 1591679, is incorporated as a limited company in Hong Kong under the Companies Ordinance (Chapter 32). It is not registered with the Securities and Futures Commission in Hong Kong to conduct any regulated activities.

The contents of this website have not been reviewed by any regulatory authority in Hong Kong. You are advised to exercise caution in relation to the information contained in this website. If you are in any doubt about any of the contents of this website, you should obtain independent professional advice.

The material on this website is provided for information only and is not intended to be, or construed as being, investment advice or services, nor is anything contained in it a recommendation of any particular security or investment. Nothing on this website is, or should be construed as, an offer to, or a solicitation of, any person in Hong Kong, to sell or buy any security or investment. You should obtain independent professional advice if you intend to buy or sell any security or investment.

UNITED STATES

Registered staff of Oleet & Company, LLC is affiliated with Ecoban Securities Corporation, a broker-dealer registered under the Securities Exchange Act of 1934, and a member firm of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC).