We appreciate your business, and we value your privacy and security. Brown Capital Group is therefore committed to safeguarding your privacy both online and off, and takes every step possible to ensure that your personal information is secure. Toward that end, we have developed the following comprehensive, global privacy policies.

We protect your privacy in every way we can think of.

• We collect personal information from you only when you choose to provide information to us, such as by purchasing our products.

• If at any time you wish to update or change any information you have provided to us, you may contact your Brown Capital Group representative or contact us directly at [email protected] as set forth under “Contact Information” below.

• We will only use the personal information you share with us to assist you in conducting business with us.

• We will not share any of your personal information with any third party other than partners under contract to us who help us serve you better in areas such as fraud prevention, technology services, and specialized customer service services. Our contracts dictate that our service partners only use your information in connection with the services they perform for us.

• We may also supplement or combine your personal information with data lawfully obtained from third parties such as banks and credit card processors that assist us in conducting business with you.

• We will never, under any circumstances whatsoever, sell or rent any of your personal information to any third parties for any purpose, as many other companies do.

• We may, from time to time, send you e-mails regarding our products. If you do not wish to receive such mailings, simply click on the “unsubscribe” link at the bottom of the email or contact us as set forth under “Contact Information” below.

• To assure the high level of personal service for which our company is known, if you choose to become a customer and are not already affiliated with a Brown Capital Group representative, we may assign you a representative and share basic contact information you provide –such as name, phone number, and email address – with them. This never includes your credit card information or other financial information.

• All Brown Capital Group representatives are also contractually obligated to abide by our privacy and security policies, which include the obligation not to share your personal information with anyone else, under any circumstances.

We take additional security measures online. Keeping your personal financial information private is vitally important to us. Since this can be a particular problem online, we take these additional security measures in that environment.

• If you purchase our products online, we need your name, address, and credit card or bank account information in order to fulfill your order. Any time we ask for a credit card or bank account number, however, we always transmit that payment information in an encrypted format, which keeps it from being understood by unauthorized people. We use state-of-the-art, industry-standard, SSL (secure socket layer) encryption to ensure that is the case.

• In fact, we take all possible organizational, technical and administrative measures to protect your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure, even by a company such as ours that goes to the lengths we do to ensure your privacy and security. In short, we cannot absolutely ensure or warrant the security of any information you transmit to us – no one can – and therefore ultimately you do so at your own risk, though we do everything humanly and technologically possible to minimize that risk.

Statement Updates

We may update this Privacy Statement from time to time to ensure that it reflects changes in the world around us. If we do update it, we will always make the updated statement available here for your continued review.

Contact Information

If you have any questions or concerns regarding our use of your information or about this Privacy Statement, please contact us at [email protected].

Special additional statement regarding the US-EU Safe Harbor Framework and US-Switzerland Safe Harbor Framework

Brown Capital Group complies with the US-EU Safe Harbor Framework and US-Switzerland Safe Harbor Framework, as set forth by the US Department of Commerce, regarding the collection, use, and retention of personal information in European Union member countries and Switzerland. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/.

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Brown Capital Group also commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss citizens with inquiries or complaints regarding this Privacy Statement should first contact us via email at [email protected].

We will make every effort to resolve any complaints to your satisfaction. In the unlikely event we are unable to do so, Brown Capital Group has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if you feel your complaint has not been satisfactorily addressed, please visit the BBB EU SAFE HARBOR website at www.bbb.org/us/safe-harbor-complaints for more information about how to file a complaint.

Updated and effective March 1, 2023.

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