Kohera's Privacy Policy

Kohera complies with SEC Regulation S-P, which requires
investment advisers to adopt policies and procedures to
protect the “nonpublic personal information” of natural person
consumers and customers and to disclose to such persons
policies and procedures for protecting that information.

Federal law requires the following:

• Kohera may only in limited instances disclose nonpublic
  information about a consumer to nonaffiliated third parties;
  
  
• Kohera must disclose to all consumers the privacy policies
  and practices with respect to information sharing with
  affiliated and nonaffiliated third parties; and
  
  
• Kohera must establish procedures to ensure the protection
  of consumer information.
  

To ensure that privacy disclosure laws are not violated, Kohera
has adopted the requirement and target objectives set forth in
these Privacy Policies and Procedures.

Any doubts about the confidentiality of client information must
be resolved in favor of confidentiality. Examples could include
basic information such as age and telephone number as well
as other identifying information.
 
Consumer – an individual or an individual’s legal representative
that obtains or has obtained a financial product or service to be
used primarily for personal, household or family purposes.
A person becomes a consumer even if a questionnaire or
application is withdrawn or denied or an advisory agreement
does not become effective.

Customer – a consumer that has an ongoing relationship
with Kohera, whereby Kohera is providing one or more
financial products or services to the consumer, e.g., an
advisory client or a shareholder of a Fund.

Nonpublic personal information –
All personally identifiable financial information.
Any list, description, or other grouping of consumers
(and publicly available information pertaining to them)
that is derived using any nonpublic personally identifiable
financial information that is not publicly available information.

Requirements

No confidential information, whatever the source, regarding
any Kohera customer, may be disclosed except as follows:

• To other Kohera employees in connection with
  Kohera’s business.
  
• To an affiliate, but the affiliate may disclose the
  information only to the same extent as Kohera.
  
• To nonaffiliated third parties with whom Kohera
  has a contractual agreement to jointly offer, endorse
  or sponsor a financial product or service; and to
  service and maintain customer accounts including
  effectuating a transaction.
  

Information Security and Online Privacy

User data and contact information obtained by Kohera will
not be shared for commercial purposes. If you have any questions
concerning Kohera’s Privacy Policy, please send an email to
privacy@kohera.net.

Kohera provides investment management services to institutions
and individuals worldwide. We are committed to providing the
highest quality of service to all of our customers. We also have
a responsibility to our customers and to the public to deliver
our services in a professional manner, with uncompromising
values and standards. Kohera must and will in all respects
comply with all relevant Federal and State laws, regulations
and requirements.

Kohera is committed to providing you with a clear explanation
of its Privacy Policy. This Privacy Policy covers privacy issues
as they relate to US, Canada, and UK online marketing
initiatives and http://www.kohera.net . 

General

Kohera collects contact information and other relevant data
from prospective clients so that we can provide them with
the information they've requested - either directly from Kohera
or through one of our marketing partners. Please note that this
information comes from people who specifically request
information through Kohera' website or from clearly labeled
advertising.

All personal information submitted to us will be held
confidential and will not be shared for commercial purposes.

Email

Kohera  may sponsor third party email content. In order to
receive third party email content, an individual needs to have
previously subscribed to a particular service or "opted-in";
to receive relevant promotional content from advertising partners.
If you have received Kohera' email content through a third party,
you must unsubscribe or "opt-out" through the respective publisher.
The only way to avoid receiving future promotional offers (from
Kohera or other companies) is by going directly to the respective
publisher and unsubscribing from their list.


Kohera does maintains a suppression file of email addresses
in compliance with the CAN SPAM Act of 2003 (S.877).
This list is updated daily and provided to publishers with
instructions to exclude the respective email addresses from
Kohera sponsored email campaigns. For instructions on
adding your name to Kohera's email suppression file,
see the section called "Removal from the Kohera Database."

Online Advertising

Kohera' online advertising is in full compliance with Internet,
advertising and finance industry standards and regulations.
Our advertising content is integrated and delivered with
online publisher's primary content in a variety of different
formats; some in graphical format (e.g. banner) and others
in text format.

The delivery of our online advertisements (and frequency
thereof) is ultimately controlled by the respective online publisher.
We are unable to suppress or restrict the delivery of our
online advertisements to individual users.

Kohera collects aggregate performance data on its online advertising.
This information is anonymous and not personally identifiable.
It does not contain your name, address, telephone number, or
email address. In addition, service providers and media owners
may track the behavior of users visiting their web sites, such as
domain type, IP address, and clickstream data. Please note that
this information is not individually identifiable.

Cookies

A cookie is a small data file containing information, such as
a link that a user clicked on, which is written to the user's
hard drive by a web server and is used to track the pages
visited. Cookie information is anonymous and not personally
identifiable. It does not contain information such as name,
address, telephone number, or email address. It also does
not contain user passwords. The individual information
gathered in this manner is used for internal purposes only,
such as looking at unique page views and customizing content.
We also use the information on an aggregate basis, to track
the usage of our website and to analyze traffic patterns.

Partners

Certain partner organizations have limited access to
online performance data in order to help Kohera get
a better understanding of the users visiting its website.
The data they maintain for Kohera helps us optimize
the use of our website.

Privacy Notice for Kohera's Clients

Kohera collects nonpublic information about users from the following sources:

• Information received on applications or other forms
  
  
• Information provided orally
  
  
• Information about transactions or online behavior with Kohera
  or other publishers
  

Kohera does not disclose any nonpublic personal information about its
clients without explicit authorization from the respective party, except
as permitted by law or in response to inquiries from governmental authorities.

Kohera restricts access to personal and account information to those
personnel who need to know that information. Kohera may also disclose
that information to unaffiliated third parties (such as to brokers or custodians)
only as permitted by law and only as needed for Kohera to provide
agreed services to clients. Kohera maintains physical, electronic and
procedural safeguards to guard nonpublic personal information.

Policy Updates

From time to time, Kohera may use data for new, unanticipated
uses not previously disclosed in our privacy notice. If its
information practices change at some time in the future Kohera
will post the policy changes to its website to notify users of
these changes. If users are concerned about how information
is used, they should check back to this location periodically.

Correcting Personal Information

Upon request, Kohera will provide site visitors with access
to respective contact information (e.g., name, address,
phone number) that is maintained about them. To access
this information, please email privacy@kohera.net.
Upon request, Kohera will also offer visitors the ability
to have inaccuracies corrected in the database.
Users can have this information corrected by sending
email to privacy@kohera.net.

 Removal from Kohera Database

If contact information is willingly provided to Kohera by
mail, phone, email, online, or otherwise, in response to
our marketing activities, individuals may receive subsequent
periodic information from Kohera on new products and
services or upcoming events. If individuals don't wish to
receive such information, please let Kohera know by
sending an email to privacy@kohera.net, or by writing
to the following address:


Kohera
Marketing Department
177 East 87th Street
New York, NY 10128


Please provide Kohera with the exact name and address
as it was originally provided. We will be happy to remove
your name from our database and will do everything possible
to honor your request for removal.

To unsubscribe from Kohera email communications,
send an email to optout@kohera.net. Please put
"UNSUBSCRIBE" in the subject field and include the
email address where you received the content, along
with any additional email addresses you would like
suppressed. We will do our best to prevent you from
receiving our email content in the future.

Security

Kohera has appropriate security measures in place
at its physical facilities to protect against the loss,
misuse or alteration of private information collected
from users. If users feel that this website is not following
its stated privacy policy, they are encouraged to
contact Kohera at privacy@kohera.net.