Privacy Policy

Welcome to the website/mobile application of the SP Funds. We understand that our customers and website/mobile application visitors are concerned about the privacy of information. We have established policies and procedures concerning the collection, use and security of your information that will help protect your privacy. Our privacy policies are designed to help us serve our customers while maintaining strict privacy and security standards. At SP Funds, we recognize the importance of keeping the information we collect about you confidential. Changes to our privacy policies may be made occasionally. We recommend that visitors to our site and mobile application users review our privacy policies from time to time to learn of new privacy practices and changes to our policies.

We collect the following non-public personal information about you:

1. Information we receive from you in applications or other forms, correspondence, or conversations, including, but not limited to, your name, address, phone number, social security number, assets, income, and date of birth; and

2. Information about your transactions with us, our affiliates, or others, including, but not limited to, your account number and balance, payments history, parties to transactions, cost basis information, and other financial information.

3. Information we receive from you through internet technology, including website and mobile application technology.

We do not disclose any non-public personal information about our current or former shareholders to non-affiliated third parties, except as permitted by law. For example, we are permitted by law to disclose all of the information we collect, as described above, to our transfer agent to process your transactions. Furthermore, we restrict access to your non-public personal information to those persons who require such information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information.

If you hold shares of the Funds through a financial intermediary, including, but not limited to, a broker-dealer, bank, or trust company, the privacy policy of your financial intermediary governs how your non-public personal information is shared with non-affiliated third parties.

Security Standards and measures

We adopt reasonable security practices and procedures and will protect your Personal Information by reasonable security safeguards appropriate to the sensitivity of the Personal Information, consistent with generally accepted standards of commercial business practice, which includes, technical, operational, managerial and physical security controls in order to protect your Personal Information from unauthorized access, or disclosure while it is under our control. You may download materials, data, etc. displayed on the website for non-commercial and/or personal use only. You may not, however, distribute, modify, transmit, reuse, report, or use the contents of the website for public or commercial purposes, including the text, images, audio and video without the SP Fund’s written permission. You shall not delete, modify and/or otherwise interfere with copyright or other intellectual property rights displayed on the website.

Online Information Collection

For each visitor to our website/mobile application, our Web server automatically recognizes the visitor's Internet service provider. Additionally, we collect information about the sites visitors connect from, and the browsers visitors use. We use this information to assemble aggregate information about the visitors to our website/mobile application, and assist with our systems administration and problem resolution activities. We collect personally identifiable information in order to identify and register a Fund investor. The information we collect will vary depending upon the function you select. For example you may be required to provide information such as:

Personal Information
PAN Number
Phone number

If you supply us with your e-mail address on-line you may receive periodic messages from us with information on new products and services or upcoming events. If you supply us with your postal address on-line you may receive periodic mailings from us with information on new products and services or upcoming events. If you supply us with your telephone number on-line you may receive telephone contact from us with information regarding products or services you have or asked about on-line. You also may receive telephone contact from us with information regarding new products and services or upcoming events. SP Funds makes no representations of any kind whatsoever about the content of any such web site that you may access through this website. You are advised to read the terms and conditions/disclaimers of such website that may be accessed by you. The SP Funds also advises you to confirm the accuracy of any such information before seeking to rely on such information. SP Funds disclaims all liability that you may incur as a result of relying on any such reports/information and/or accessing any other website and/or any third party content that may be accessed from the website.

Visitor Data Collected on this Website/mobile application

The information for the accounts you have with the SP Funds website/mobile application is kept secure and confidential through multiple security features and procedures. . Information you submit through our website/mobile application, as well as the information we send back to you while you are visiting our website/mobile application, is protected while passing through the Internet using strong encryption ("scrambling" to make it incomprehensible) when necessary. Our secure server software encrypts information, ensuring that Internet communications through our website/mobile application stay private and protected. To enable our customers to process transactions at our website/mobile application, we

use cookies. Your information is not permanently stored on our Web server. The information only resides on our Web server while you are viewing the information. Our corporate network systems, which store your account information, use proven security controls. We have data security staff whose sole responsibilities are to ensure the security of the information we process and store. SP Funds has policies and procedures in place to limit access to your information to only those who have a business need to view it.

Use of Cookies

The website, like many web sites, uses "cookies" (information stored on your computer by your browser at our request). Cookies enable the site to "remember" who you are so that you can get around it easier and more efficiently. Cookies allow you to access secured information, conduct secured transactions, and take advantage of promotional opportunities. Different web sites store the information in cookies differently. We do not record personal or sensitive information in our cookies. Any such information is stored in our protected systems and not in the cookie or on the Internet. This policy describes how we will handle information we learn about you from your visit to our Web site / mobile application. If you visit our site / mobile application to read or download information, we may collect and/or store the following information about you:

The name of the domain from which you access the Internet ;
The date and time you accessed our site/ mobile application;
The Internet address of the Web site / mobile application from which you linked directly to our site;
The page locations where you visited, and other miscellaneous site references.

Some pages on this Web site employ "cookies." A cookie is a small file that a Web site transfers to your computer’s hard disk to allow the server to "remember" specific information about your session while you are connected. Fund may find it necessary to use the "cookies" system to collect data when you visit our web pages / mobile application. This will help us find out which sections of our pages you are interested in. Requests to send cookies are not designed to collect information about you, but only about your "browser session." The cookies make it easier for you to use the dynamic features of our Web site / mobile application. The cookies and the information about your session are automatically destroyed shortly after you close your browser. The information is not permanently stored on your computer. No personal information about you is collected except as described above. The primary reason for doing this is to enable Fund to appreciate, better, your centres of interest and send you information specific to your requirements. Such data will not be held for more than one year. This website / mobile application does not collect any personal information that identifies a visitor to this site/ mobile application individually unless specified otherwise. Your visit to this site / mobile application will record only the Domain Name Server part of your e-mail address and of the pages visited within this website / mobile application. The information we receive depends upon what you do when visiting our site. This information is used for management and enhancement of our Web site / mobile application and also to prepare aggregate information about the visitors to the site and statistics on usage patterns. If you identify yourself by

sending an e-mail or ordering forms/brochures, we will only use this information to respond to your request and improve our Customer Services. Names and addresses are kept in our Customer Services system for 3 months in order to follow up on orders if necessary. They are then deleted from the system. While every care has been taken in preparing the information and materials contained in this site, such information and materials are provided to you "as is" without warranty of any kind either express or implied. The Fund does not warranty the adequacy of the information made available. In particular, no warranty regarding non-infringement, security, accuracy, fitness for a particular purpose or freedom from computer virus is given in conjunction with such information and materials.


"Cookies" will also save you from having to supply information that you have previously given, every time you connect. It will be possible for you to detect these "cookies" and, if you wish, delete them. To do this, we would remind you that your web browser software contains the option of blocking "cookies" on your computer:

Other web connections: hypertext links

Our web pages / mobile application also offer links to other sites for which we are not responsible either for their standards of public order and decency, or for their personal data protection policy or the use that could be made of such data. When you access another website through a hypertext link, you are accepting that this access is at your own risk. Consequently, Fund cannot accept responsibility for any direct or indirect damages that may result from your access to another site connected by a hypertext link. We would also draw your attention to the use of public forums where you may be asked to give your identity or e-mail address. This information then enters the public domain and may be used by a third party using the service.

Breach of Internet Security

Despite our best efforts, if unauthorized persons breach our security control measures resulting in the Site being hacked or presenting inaccurate information etc., Fund, SP Funds Inc, Tidal Trust, Toroso, their directors, officers, employees or affiliates’ will not be responsible. Unless otherwise stated, we own the intellectual property rights in the website / mobile application and material on the website / mobile application. You may view, download for caching purposes only, and print pages from the website / mobile application for your own personal use, subject to the restrictions set out in these terms and conditions of use.