MURPHREE INVESTMENT GROUP INC. PRIVACY POLICY

Last Updated: December 15, 2025

Welcome to Murphree Investment Group Inc. (“Company” or “us”, “our,” “we” and related terms), an Illinois corporation. Thank you for visiting our website located at murphreeinvestment.com.

We are committed to respecting the privacy rights of all individuals, wherever located and have adopted this privacy policy (“Privacy Policy”) to explain how we collect and process your Data (as defined below) through your use of and interaction with our Sites (as defined below) and Services (as defined below), how we share (or do not share) any of your Data, how we store and keep secure any of your Data, how you can update and control any of your Data, the rights you may have with regard to your Data, and other information relevant to your privacy.

Please review this Privacy Policy carefully, and please use the information herein to make informed choices. If you have any concerns or questions about our privacy practices, please feel free to contact us at service@murphreeinvestmentgroup.com. By accessing any of our Services or our Sites, and/or by registering for or using any of our Services, you are agreeing to all of the terms set forth in this Privacy Policy.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE ANY OF THE SITES OR SERVICES OR GIVE US ANY OF YOUR DATA. THE USE OF THE SITES AND THE SERVICES IS VOLUNTARY, AND BY ACCESSING AND/OR USING THE SERVICES AND/OR THE SITES YOU ACKNOWLEDGE THAT YOU HAVE READ, AGREE AND CONSENT TO THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF USE LOCATED AT [____] (“TERMS OF USE”); AND IF YOU ARE ACCESSING AND/OR USIN THE SERVICES AND/OR THE SITES ON BEHALF OF AN ENTITY (SUCH AS A COMPANY), THEN YOU AGREE THAT YOU HAVE THE AUTHORITY TO BIND THE ENTITY AND CONSENT ON BEHALF OF THE ENTITY TO THE TERMS OF THIS PRIVACY POLICY AND THE TERMS OF USE .

1. The Scope of this Policy

  1. Scope: This Privacy Policy applies to our website murphreeinvestment.com.; to our “backend” hosted applications that are a part of our service platform; and to all data and/or information that is collected via our websites, applications and mobile applications. For the purposes of this Privacy Policy, we refer to our websites, and applications collectively as our “Site,” “Website”, “Sites” or “Websites”. This Privacy Policy applies to all Site visitors (“Users”), as well as to all Site visitors that purchase, subscribe to or use our services or one of our products or otherwise interact with us (collectively, the “Services”) as a guest or as a registered customer (“Customers”). While certain portions of our Sites and certain of our Services can be viewed without registering, Site users will have to register (create an account) in order to access some of our secure proprietary applications and certain features of our Services. Customers are able to request user accounts for their employees/agents or third-party guest users (“Authorized Users”) to provide access secure areas of the Sites and certain features of the Services. Customers are responsible for managing the activity of all Authorized Users, and for how the Sites and Services are used by their Authorized Users.
  2. Changes: We may make changes to this Privacy Policy from time to time, and any material changes that we make will be posted (in the form of an updated Privacy Policy) on our Sites. Such policy updates will be effective when they are posted unless prohibited by law in which case, we will comply with applicable law prior to making changes to this Privacy Policy. Accordingly, please review the terms of this Privacy Policy on a regular basis to understand the current terms.
  3. Terms of Use: In addition to the terms of this Privacy Policy, your use of the Sites is subject to our Terms of Use.

2. The Types of Information That We Collect and How We Collect It

To provide our Services and access to our Sites, we collect data and information, which are not personally identifiable (“Anonymous Data”) and also data and information that, either alone or in conjunction with other data and information can be linked to, associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). The term Personal Information (as used in this Privacy Policy) also includes certain categories of "sensitive" or "special" Personal Information (“Sensitive Personal Information”) that may receive additional legal protection and/or are subject to additional restrictions under applicable laws.

This section describes the categories of Anonymous Data and Personal Information (together, “Data”) that we may collect, or that we may have collected in the prior 12 months, for the purposes described in this Privacy Policy.

  1. Account and Transaction Data: We collect Personal Information that is provided to us voluntarily either via direct communications (e.g., email) or through our Sites or use of our Services, such as when a User registers for our Services. We use Data that you provide to provide our Services to you; and we may also use Data to contact Customers and/or Users for limited marketing or product communication purposes (subject to the provisions herein). The Account and Transaction Data collected include common categories of contact information (e.g. name, email address, telephone number, billing and shipping addresses, username, password and zip code), and may also include certain account administration and registration information, payment information, marketing information, your purchase history, details relating to your subscriptions, information about items in your online shopping cart when you place an order with us online.
  2. Site Usage Data: We collect certain Site/Services utilization data through the use of tracking technologies (including cookies and other automated tracking technologies, as detailed below) and the Data collected can include both Anonymous Data (e.g., how a Site is used) and Personal Information. We use these Site Usage Data to understand how our Sites and Services are used, to improve our Sites and Services, and to protect the integrity and security of our Sites and Services. Site Usage Data include:
    1. Device data. Information about the computer or mobile device you use to access the Sites. This may include technical information transmitted by your device such as the browser used, the device model and operating system, language preference, device location, unique device identifiers, and the Internet Protocol (IP) address through which you accessed the Site.
    2. Site Use Activity. Information regarding your activity on the Sites and your activity in the use of the Services, such as the time and frequency of access, a referrer page domain, pages viewed, and interactions between the User and the Sites and/or the Services, other web pages you visit prior to coming to the Sites and web pages you view while on the Sites .

    If your device settings allow us, we may also collect information about your location or geolocation information when you use our Sites or Services and your IP Address. For more information about how you can control the collection of local information and to set your preferences, please see “Your Choices” below.

  3. Other Information you Choose to Provide: We collect information you choose to provide, such as your contact and marketing preferences, details about your order (for example, your shirt size), brand and merchandise interests, and communications and interactions (which may include email messages, chat sessions, text messages or phone calls with you) when you sign up for emails and marketing, participate in a survey, promotion or interactive area of a Site, or when you request technical or customer support or contact us.
  4. Information we Collect from Social Media Platforms: We may obtain information about you from social media platforms that you use in connection with our Sites or when using our Services, or that share or allow you to share information with us, such as LinkedIn, X and Instagram. For example, if you post content to feeds on third-party social media sites or use social media platforms in connection with the Sites or if you like us or follow us on social media platforms, we may collect the information that you share with us, or that those social media platforms share with us in accordance with their privacy policies and privacy settings. For more information about social media platform privacy practices, please review the privacy policies and settings of the social media platforms and networks that you use. You may update your privacy settings on each social media platform directly.
  5. Sensitive Personal Information. Of the information listed above, passwords and access credentials also may qualify as Sensitive Personal Information, and certain financial information may also qualify as Sensitive Personal Information. We use Sensitive Personal Information only as reasonably necessary to: (i) provide and secure the Services; (ii) prevent, detect, and investigate security incidents and fraud; (iii) comply with the law; and (iv) for internal operations compatible with the context in which the information was provided. Where an applicable law gives you a right to limit the use and disclosure of Sensitive Personal Information, we will honor that right. We do not collect or process Sensitive Personal Information for the purpose of inferring characteristics about individuals. The provision of Personal Information, including Sensitive Personal Information, is voluntary. In certain instances, you will not be able to fully access our Services without providing the requested Personal Information.
  6. From Our Third-Party Service Providers. We collect information from third parties that we have partnered with (e.g., cloud-based service providers providing application hosting services, marketing/messaging service partners) to provide necessary elements of our Services or the Sites and/or to provide specific services for Customers.
  7. Other Sources. We collect information from other sources including data analytics providers and/or publicly available sources.

If we combine Personal Information with Anonymous Data, the combined information will be treated by us as Personal Information for as long as it remains combined.

3. Limited Use of Artificial Intelligence Tools

We use AI-enabled tools (“AI Tools”) to improve internal workflows (for example, quality checks and drafting assistance). We do not use AI Tools to make decisions about individuals and we do not profile individuals. We do not use your Personal Information to train any third-party Ai or machine-learning models, and we contractually prohibit our service providers from using your Personal Information for model training or product improvement. Where an AI Tool is used to process Personal Information to provide the Services, we do so under agreements that(i) restrict processing to our documented instructions, (ii) ban training and redistribution, and (iii) require appropriate security and deletion. We will comply with applicable IA and privacy laws as they take effect and will update this policy accordingly.

4. Cookies and Other Automated Tracking Technologies

We may use cookies (small text files placed on your web browser or device) in connection with our Sites and Services; and we may analyze the information derived from these cookies for the same purposes as set forth elsewhere in this Privacy Policy. In addition, for information about the cookies used by our Website hosting platform, SquareSpace, please visit https://support.squarespace.com.

The information collected by these tracking technologies may include (a) your internet protocol (IP) address, unique device identifiers, location, browser type, and Internet service provider information; (b) information about when and how you access and use our Sites, such as the domains you visit, what features you used and for how long, the website that referred you to us, and date/time stamps associated with your usage; (c) information about the device you use to access the Sites or services, such as device type, device ID, and device/browser settings; and (d) location of the device used to access the Sites or services derived from GPS or WiFi use.

We may use the following types of cookies on the Sites:

  1. “Convenience” Cookies: These cookies can store ‘persistent’ information like registration information for use on later visits to the Sites. You may be able to configure your browser to block/delete these cookies; but if you do, you will have to input the account-related information every session.
    • You may have the option to opt out of convenience cookies (if applicable) when you visit our Sites.
    • If you do not opt out, and you would like to delete any account information we may store via convenience cookies, you can take the following actions: (1) you can delete your cookies (via your browser); and/or (2) you can reach out to us as specified in this Privacy Policy.
  2. “Analytics” Cookies: Cookies which help us to determine usage patterns of our web pages by collecting information about how visitors use our Sites, how many visitors we have to our Sites, how many times they visit us and how many times a User viewed specific pages within our Sites. Although analytics cookies allow us to gather specific information about the pages that Users visit and whether Users have visited our Sites multiple times, we cannot use them to find out details such as Users’ names or addresses. We may Google Analytics and other analytics cookies. For more information about Google Analytics, please refer to "How Google Uses Information From Sites or Apps that Use Our Services", which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. As you go through the checkout process, this Site may auto-complete your shipping and billing address by sharing your Personal Information with the Google Places API and returning suggestions to you to improve your checkout experience.

    More specifically, we may use a tool called Google Analytics for aggregated and anonymized website traffic analysis. In order to track your session usage, Google places a cookie with a randomly generated Client ID number in your browser. This ID number is anonymized and contains no identifiable information like email, phone number, name, etc. Google also has access to your IP address. In addition, Google may install additional cookies (e.g., Google fonts, Google tag manager). We may use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information can be important to us for improving the user experience and determining site effectiveness. For more information about Google Analytics, please refer to "How Google Uses Information From Sites or Apps that Use Our Services", which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.

    If you would like to understand or limit what Google Analytics-derived browsing information we may have and/or want to delete any Google Analytics data if we use Google Analytics, you can take the following actions: (1) you can delete your cookies (via your browser); (2) you can reach out to us as specified in this Privacy Policy, and/or (3) you can install the Google Analytics Opt-Out Browser Add-On (https://tools.google.com/dlpage/gaoptout). Although Google Analytics plants a permanent cookie on your web browser, which can identify you as a unique user the next time you visit the Site if we use Google Analytics, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this Site of we use Google Analytics by disabling cookies on your browser.

  3. “Essential and Functional” Cookies:These are cookies that the Sites need in order to function, and that enable you to move around and use the Sites and features. Without these essential cookies, the Sites will not perform as smoothly for you as we would like them to and we may not be able to provide the Sites or certain features you request. Examples of where these cookies are used include: to determine when you are signed in; to determine when your account has been inactive; and for other troubleshooting and security purposes.
  4. “Third-party” Cookies: These cookies are set by other online services that run content on the page you view on your browser. For example, if you click on a link on LinkedIn, the underlying code may store a cookie on your computer that can later be accessed by LinkedIn and may be able to track other sites that you visit.
  5. Web Beacons: We may also collect information using Web beacons, which are small images embedded into websites or emails that send information about your computer, mobile phone, or other device when you visit our Sites, use our mobile application, or open an email we send to you.

Please see “Your Choices” below to manage the use of these Cookies.

5. How We Use the Data that We Collect

We use Data in the manner described in this Privacy Policy. We use such Data for the following business purposes to:

  1. Provide Products Services to you: We use it to provide the Services to you, facilitate account creation and one-click orders, provide memberships and subscriptions, provide maintenance and support (including by sending you confirmations, related transactional, communications, security alerts, support and administrative messages), and to improve our Services and the Sites. We also us provide Data to our Website hosting platform so that they can provide Website services to us and track and respond to your submissions. We also use anonymized, de-identified and aggregated data generated by the Services to provide insights to our Customers.
  2. Further our Business Purposes: We use it to operate, improve upon and expand our business and lawful business activities; to maintain our programs, accounts, and records; for research; to detect and prevent fraud or misuse of our Services; and for any other business purpose that is permitted by law.
  3. Customize and Enhance your Experiences with Us. We use it to remember and categorize your interests and preferences; customize the products and services we share with you through direct marketing; communicate with you about the Sites, Services, products, offers, promotions, surveys, events and other news and information we think may be of interest to you and contact you for feedback. We also may also use Google to create a survey to collect data from Users.
  4. Respond to You. We use it to respond to you, such as when you place an order, call us, make a request or inquiry, complete a survey, or share a comment or concern.
  5. Use of Sensitive Personal Information. We only use Sensitive Personal Information to operate our Services, to provide Customers with the requested services, and to administer accounts.
  6. Miscellaneous. We use it for any of the following reasons:
    • To identify your preferences
    • To provide you information about our other Services that might be of interest to you
    • To comply with our internal record-keeping needs to legal compliance needs
    • To notify you about changes to our Services
    • To allow you the option to participate in interactive features of our Services
    • To detect, prevent, and address technical issues
    • To protect or otherwise investigate our Services regarding misuse, security breaches, prevention, detection, mitigation, or investigation of fraud, or other potentially prohibited or illegal activities and/or attempts to interfere with the Website or Services or to harm others
    • To facilitate and provide services to our Clients and authorized service users.
    • For everyday business purposes, such as account management, contract administration, Site management, corporate governance, and legal and regulatory reporting obligations.
    • To assist you and our Clients in using and accessing our services and Sites. This means that we may use your Personal Information to respond to your questions, operate the services and Sites, perform our obligations to Clients, and perform other actions based on consent.
    • To respond and address feedback you provide to us or if you contact us for support.
    • With respect to a transfer or sale, including a potential transfer or sale, of any of our assets and/or operations to another party or in the due diligence process in line with a potential transfer or sale
    • To determine your level of engagement
    • Monitor and improve the information security of our Sites and/or our Services
    • Comply with governmental regulations or to respond to a subpoena or other governmental, court, administrative, or other legal requirement or law enforcement requirement
    • Hire, train and/or manage our staff/employees
    • To send you marketing communications that promote our products, programs or services and/or those of our partners (with your consent, where required), and to determine the types of marketing communications to send. Please see below for additional details relating to your right to opt out of, or withdraw consent to receive, certain marketing communications.
    • To analyze your needs and help improve, develop, and evaluate the services, and to develop new products and services.
    • To comply with laws and regulations and legal processes.
    • To monitor compliance with our policies, procedures and applicable terms of service, for fraud prevention, to detect and address illegal activities and/or to protect us, and our employees, Users and property.
    • For customer relationship management and administration.
    • Where permitted, to create de-identified data sets. Such information is generally not considered Personal Information and can be used for various purposes, such as statistical and research analysis, in accordance with applicable law.
    • We may use Device Information to monitor the effectiveness and improve the functionality of the Sites, to help personalize your experience and to consider potential improvements to the Sites. This information may also be used for statistical and research purposes and administrative purposes including, without limitation, to troubleshoot and resolve problems with the Sites. We may rely on third-party partners to collect and analyze the Device Information. Device Information may also be collected through cookies or similar technologies. For more detailed information on cookies, please refer to the Cookies section above.
    • To enforce our Terms of Use, this Privacy Policy or other policies, and to monitor for violations of our policies or applicable laws
    • Combined with information we receive from other sources for the purposes set out in this Privacy Policy
    • Any other purpose communicated to you at the time of collecting the Personal Information and if required by law for which consent has been obtained
    • We may use non-personally identifiable information such as demographic data to analyze and develop our marketing strategy and maintain and further improve the Sites and our Services

Your Personal Information is not sold, rented or leased to other organizations for commercial/business purposes and has not been in the last 12 months immediately preceding the effective date of this Privacy Policy. We may send you our own marketing. We do not disclose your email address or other Personal Information to third parties for their independent marketing without your consent or as otherwise prohibited by law.

6. Disclosure of Personal Information to Third Parties

We work with third-party service providers that supply website and application development, hosting, maintenance, storage, virtual infrastructure, payment processing, research, advertising, marketing, analysis, and other services for us, which may require them to access or use of your Personal Information. However, in the event one of our third-party service providers needs to access your Personal Information to perform services on our behalf, they must also agree to comply with all portions of this Privacy Policy. We engage and share certain Personal Information with third party service providers/partners as follows:

  1. Engage with Service Partners: By necessity, we may share certain Data, including Personal Information, with third party service partners that are under contract with us and which perform Site-related functions on our behalf (“Service Partners”). Service Partners include certain cloud-based service providers that provide aspects of the Sites’ functionality (e.g., application hosting, database services, cloud-based storage) and other technology service providers and third parties and consultants, and vendors that furnish us with products and services and provide services to assist us to deliver our products and services to you, such as shipping, fulfillment, payment services providers and credit card payment processors, survey tools, Google Analytics, login partners and e-blast partners .We do not retain or record any payment processing information except that which is necessary to confirm payments and associate those payments with Customer accounts. All usage of the Sites will be subject to the privacy policies and terms of use maintained by the applicable Service Partners. If you object to the privacy practices of any Service Partners, please inform us, and please do not use the Sites or our Services.
  2. For Legal Purposes. We also reserve the right to disclose Data or any information submitted via Sites if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims or protect against legal liability;(v) prevent harm to our rights, property or safety (or the same interests of our Users or any third party); (vi) to notify you of any product recalls or other safety concerns; (vii) for billing and collection purposes; or (viii) for any other legal purpose.
  3. For Other Purposes. We may share Personal Information with third parties for other purposes. For example, we share Personal Information with:
    • Third parties who provide products and services that may be of interest to you, including third parties that provide us with products and services that enhance our products and services for you and that provide us with marketing, research and advertising services, including to: serve advertisements across the Internet; track and categorize your activity and interests over time on our Website and mobile application, and on third-party websites and mobile applications; and to identify the different device(s) you use to access websites and mobile applications.
    • As a convenience to our Users, some of our Sites may have features such as social media widgets or other tools made available by social media platforms and networks that may result in information being collected or disclosed between us and these platforms and networks. You use of these features is voluntary, and these third parties’ collection and use of your information is not governed by this Privacy Policy.
    • We may disclose Personal Information to companies, organizations or individuals outside of Murphree Investment, for purposes not specified elsewhere in this Privacy Policy, but only when we have your express written consent to do so.
  4. No Sale or Sharing: Except Data that we share out of necessity with our service partners, Data that may be generated by certain cookies (Section 4, above), and for the purposes listed in Section 5 above, we do not rent, sell, or share Data with third parties for third-party marketing or advertising purposes, but we may send out email blasts for our partners who want to let you know about services or products they offer, who will compensate us for doing so.

Please see Section 9, “Your Choices” for information about the choices you have about the sharing of your Data.

7. Legal Basis of Processing

We process information (including without limitation Personal Information) for the purposes described in this Privacy Policy, based on the following legal grounds:

  1. With Your Consent. In certain instances, whether you are an individual acting on your own behalf, or you are an individual acting on behalf of an entity, we ask for your consent to process Personal Information for specific purposes. Provision of consent is voluntary, and you have the right to withdraw your consent at any time. If you withdraw consent on behalf of an entity, we may not be able to provide Service to you and the applicable entity.
  2. When Pursuing Legitimate Interests. We process Personal Information for our legitimate interests and for the legitimate interests of third parties and Clients, while applying appropriate safeguards that protect individuals’ privacy, as further described in this Privacy Policy (and we use such data in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals).
  3. To Perform a Contract With You or a Customer. We will process Personal Information as necessary for the execution or performance of contracts with Customers
  4. When We Have Legal Obligations. We will process Personal Information when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable government request, including law enforcement.

In some cases, your provision of Personal Information may be required by a statutory or contractual obligation.

8. Third Party Features, Links and Privacy Policies

The Sites may include service features and augmentations operated by other companies that are not our service partners, but which provide features that we believe Users may appreciate, such as social media widgets, links to third-party websites, advertisements and other third-party content (“Third-Party Features”). Users who choose to access any Third Party Features, must understand the following: (1) we do not operate, control or monitor Third-Party Features, and these features are subject exclusively to the privacy policies of the companies that operate them; (2) this Privacy Policy does not apply to information collected by any third party, including through any Third Party Features; and (3) we are not responsible for the privacy practices, the placement of cookies on your computer by any third party, or any content you may encounter via Third Party Features. Users who decide to access any Third Party Features, should read the privacy policy of each linked website to understand the privacy practices that apply to those features.

9. Your Choices

Depending on where you live, you may have certain rights with respect to your Personal Information. Your rights will vary depending on where you are located. Specifically, you may have the following right.

  1. Targeted Advertising: If you do not want to receive the benefits of targeted advertising, you may be able to opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page at http://www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance (DAA) consumer choice page at www.aboutads.info/choices. Please note that even if you choose to remove your Data (opt out), you will still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page and the DAA consumer choice page provide mechanisms to opt out of receiving cookies from those companies. Please note that if you opt-out of targeted advertising, we may still track your visits to the Site(s) for our own analytics, operations and security purposes. We cannot guarantee that all of the third-party advertisers or web optimization service providers we work with will honor the selections you make. California residents and residents of other states may have additional Personal Information rights and choices.
  2. Browser-Based Opt-Out Preference Signals: We honor browser-based opt-out preference signals recognized by applicable law, such as Global Privacy Control (GPC), as a request to opt-out of sale/sharing and targeted advertising, and we process such signals in a frictionless manner where required.
  3. Google Analytics. If you would like to opt out of Google Analytics on a per browser basis, please see Section 4 - Cookies and Other Automated Tracking Technologies, above.
  4. Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies and web beacons. Managing cookie preferences is different on each browser so refer to your specific browser for further information. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites. If you set your browser to refuse all cookies, please contact us directly if you have trouble placing your order. We will store your cookie preferences until you clear your browsing cache. You may change your preferences at any time.
  5. Social Media: You should review your privacy settings and options directly with each of the social media platforms and networks that you access to determine your options and choices about sharing information from these sites with us.
  6. Email Communications: You may choose during the account registration process on the Sites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our products and services. You may opt out of receiving these promotional communications from us by following the instructions in those communications (such as by using an “unsubscribe” link in an email you receive) or by contacting us at the contact information provided above. Even if you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
  7. Promotional Mailings: If at any time you do not want to receive offers and/or circulars from us, you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line, along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  8. Phone/Text/SMS Information: With your consent, we may collect text/SMS information to communicate with you via phone, text and/or SMS. Electronic communication is the most effective and timely way to provide the users of the Sites and Services with any optional or required notifications and disclosures. In some circumstances, however, applicable laws may require us to send you disclosures or communications in paper format unless you have affirmatively consented to receiving electronic notifications only in advance of the notification. You may opt out of receiving these promotional communications from us by following the instructions in those communications (such as by texting “STOP” in response to a text message you receive) or by contacting us at the contact information provided above. Even if you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
  9. Electronic Notifications. Through this Privacy Policy, pursuant to 15 U.S.C. § 7001, you hereby affirmatively consent to receive electronic notifications and disclosures from us only (without requiring a paper copy) and you represent that, to date, you have not withdrawn such consent. You have the right to change your mind and withdraw your consent at any time. If you would like to withdraw your consent to receive electronic notifications and/or would like to request paper copies of any electronic notifications you receive, you may contact us at service@murphreeinvestmentgroup.com or via mail at 100 S. Sanders Road, Suite 150, Lake Forest, IL 60045. To receive electronic records, you will need access to a smart phone, tablet, laptop or computer with internet access and an email account. You may opt out of receiving these promotional communications from us by following the instructions in those communications (such as by texting “STOP” in response to a text message you receive) or by contacting us at the contact information provided above. Even if you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
  10. Location Information: We may collect information about your actual location when you use our mobile applications. You may stop the collection of this information at any time by changing the settings on your mobile device but note that some features of our mobile applications may no longer function if you do so.
  11. Account Information: You may update, correct or modify information about you at any time by logging into your online account or by contacting us at the contact information provided above. If you wish to deactivate your account, please email us at service@murphreeinvestmentgroup.com but note we may continue to store information about you as required by law or for legitimate business purposes.
  12. Push Notifications: We may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within
  13. Correction (Rectification): You may have the right to request that we correct or supplement any inaccurate or incomplete Personal Information we process about you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.
  14. Deletion (Right to be Forgotten): You may have the right to request that we delete your Personal Information. If required by law, we will grant your request to delete information. However, when we delete Personal Information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it. In addition, we may keep your Personal Information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
  15. Access: You may have the right to request access to the Personal Information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients to whom the Personal Information has been or will be disclosed, the sources of the Personal Information, retention, and transfers of Personal Information.
  16. Data Portability: In certain circumstances, you may have the right to request that we provide the Personal Information which you provided to us in a structured, commonly used and machine-readable format; and you have the right to transmit such Personal Information to another entity.
  17. Consent Withdrawal: Where our processing is based on your consent, you have the right to withdraw such consent at any time; however, you may not be able to use the Sites or feature for which you are withdrawing your consent. Withdrawing your consent will not affect the lawfulness of the processing we conducted prior to your withdrawal.
  18. Do Not Sell/Share; Right to Opt-Out of Targeted Advertising or the “Sale” or “Sharing” of Personal Information: Under applicable laws, you may have the right to opt out of the sale/sharing of your personal information to/with third parties for such third parties’ use for targeted advertising, marketing, data enrichment or any other commercial purpose that might benefit Murphree Investment Group Inc. or such third parties (collectively, “Commercial Purposes”). For the sake of clarity, as disclosed above, in order to provide our Services, Murphree Investment Group Inc. shares Personal Information and other data with certain third-party Service Providers which are only authorized to process such information as necessary to provide services to us pursuant to a written agreement. If you have questions or concerns about our sharing of data with our Service Partners, please contact us set forth in this Privacy Policy.
  19. Restriction of Processing: You may have the right to request that we restrict the processing of your Personal Information in certain cases. Where applicable, the respective Personal Information will be marked accordingly and may only be processed by us for certain purposes.
  20. Objection to Processing: In certain circumstances, you may have the right to object to our processing of your Personal Information.
  21. Automated Processing: You may have the right to object to a significant decision based solely on automated processing (i.e., a decision made without human intervention) unless that decision is required or authorized by law. We do not engage in automated decision-making.
  22. Right of Non-Discrimination/Non-Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.
  23. Right to Opt-Out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law): We do not currently use or disclose Sensitive Personal Information for purposes other than those which cannot be limited under applicable law.

Please note that many of the above rights are subject to exceptions and limitations, and that many of the above rights are defined in specific US or international laws. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable laws, we will respond within the time period prescribed by applicable law. In some cases, we may limit or deny your requests to access or delete your information. This may occur because the law permits or requires us to do so, or if we are unable to adequately verify your identity. If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. Under local law, you may be entitled to lodge a complaint with your local data-protection authority. Murphree Investment Group Inc. may require use of your Personal Information to provide access to the Sites. Therefore, when you exercise your deletion right, in particular, you may lose access to certain aspects of the Sites that require your Personal Information.

Depending on where you are located, a person authorized to act on your behalf may make a verifiable request related to your Personal Information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. After you make your request, we will use the information we have about you to verify your identity (and if applicable, your authorized agent’s identity). Our verification process may include a request for additional information to confirm your identity or your authorized agent’s identity (such as your name, email address and date of birth) or to obtain proof that you have given your authorized agent permission to act on your behalf. If our verification process is successful, we will respond to your request within the time and in the manner required by applicable law. If we cannot validate the identity of you and/or your authorized agent or obtain proof that you have given your authorized agent permission to act on your behalf, we will attempt to contact you to inform you.

If you designate an authorized agent to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a completed authorized agent designation form indicating that you have authorization to act on the individual’s behalf.

In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated to fulfill a request. In such a case, your request may not be fulfilled. However, to the extent permitted by applicable law, we may reject requests that are unreasonably repetitive, unduly burdensome, risk the privacy of others, or would be very impractical to honor. Depending on where you are located, you may have the right to lodge a complaint with the relevant supervisory authority.

Additional Rights by Region

EU/EEA, Switzerland, and UK: If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have certain rights under the GDPR or UK GDPR. If you reside in the EU/EEA, Switzerland, and the UK, you may have the right to:

  • Access, rectify, or erase your Personal Information.
  • Restrict or object to processing.
  • Receive your Personal Information in a portable format.
  • Withdraw consent at any time.
  • Lodge a complaint with your local data protection authority.

We process your Personal data only when we have a lawful basis to do so. Where we rely on legitimate interests, we balance those interests against your rights and freedoms.

Canada: You have rights under PIPEDA, including the right to challenge our compliance and to be informed of transfers outside Canada. You may withdraw consent at any time, subject to legal or contractual restrictions. You may also request written information about our policies and practices relating to the management of personal information by contacting us using the details in Section 12 Contact Us below.

Canadian Users Opt-Out

If you are a Canadian resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes by contacting us by phone at 312-257-3003, emailing us at service@murphreeinvestmentgroup.com, or writing to us at the address provided in Section 12 Contact Us below. Canadian residents may also opt-out of secondary marketing uses of personal information by us or our business partners by using these contact methods.

Certain U.S. States: Residents of California, Virginia, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia may have the following rights also, subject to exceptions:

  • Access/Know: The categories and specific pieces of Personal Information we collect, use, disclose, sell, or share.
  • Correction: Request correction of inaccurate Personal Information.
  • Deletion: Request deletion of Personal Information.
  • Opt-out: Opt-out of the sale or sharing of Personal Information.
  • Limit: If applicable, limit the use and disclosure of Sensitive Information. Note: We do not collect Sensitive Information as defined under California law.
  • Appeal: Appeal our decision if we decline your request (see Appeals).

We honor opt-out preference signals required by law, including Global Privacy Control (GPC) and other recognized Universal Opt-Out Mechanism.

We will not discriminate against you for exercising these rights.

How to Exercise Your Rights: You can exercise your privacy rights by emailing us at service@murphreeinvestmentgroup.com, or by mail to the address in Section 12. We will verify your identity before processing your request and respond within the timeframes required by applicable law.

For California-resident requests, we will confirm receipt within 10 business days of a request for access/know, to delete or to correct and provide information and cease selling/sharing within 15 business days of your opt-out and notify relevant third parties as required.

If you choose to have someone act on your behalf, please review the following requirements.

Authorized Agents: California residents may also exercise their rights through an authorized agent. To do so, the agent must provide proof of their authorization, such as a signed written permission from you or a valid power of attorney. We may also require you to verify your identity directly with us and confirm that you have authorized the agent to act on your behalf, as permitted by California law.

Nevada Residents: To opt out of the sale of your personal information, submit a verified request to our designated request address service@murphreeinvestmentgroup.com, subject line “Nevada Do Not Sell”.
Appeals: If we deny your request, you may appeal by emailing us at service@murphreeinvestmentgroup.com with the subject line “Appeal of Privacy Request.”

If you are in Colorado, Oregon, or New Jersey, we will decide your appeal within 45 days from our receipt of your request. If you are in Connecticut, Nebraska, New Hampshire, Maryland, Texas, or Virginia we will decide your appeal within 60 days from our receipt of your request.

For all responses, we will include reasons and how to contact your state Attorney General if you remain unsatisfied.

10. Measures Adopted by Murphree Investment Group Inc. to Protect Privacy Interests

  1. Data Inventory/Mapping: We have assessed our data practices and systems to ensure that we understand the Personal Information that may be collected via our Sites and how it may flow through our Services and technology platform. We prioritize privacy concerns in the design phase of all new features for our platform.
  2. Data Retention: We only collect and process Personal Information that we need to perform the Services or as otherwise described in this Privacy Policy. We have adopted policies that require us to delete or anonymize all data that are no longer required for the performance of the Services.
  3. Security of Data and Processing: We have implemented measures that are designed to limit access to Personal Information to authorized individuals and to prevent the loss or corruption of data. We have implemented commercially reasonable data security technologies designed to preserve the security of all Personal Information collected and/or processed on our platform, including encryption for all such Personal Information in transit and at rest when applicable except for metadata and photos which are publicly accessible and not encrypted at rest. We share your Personal Information with our website hosting provider so that they can provide Website services to us.

Please understand, however, that no security system is impenetrable or perfectly secure. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to or from us over the Internet. As a result, you use the Sites at your own risk.

When registering with us on the Sites, we encourage you to choose passwords of sufficient length and complexity, install the latest security updates and anti-virus software on your computer to help prevent malware and viruses, not share your password with others, and review your account information periodically. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, please contact us using the contact information provided above.

11. Other Terms

  1. Transfer of Assets: If another entity acquires us or acquires all (or substantially all) of our assets, the Data in our platform will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be sold or transferred to third parties.
  2. Minors and Privacy: The Sites are not directed toward individuals under age 18; and we do not knowingly collect information from anyone under the age of 18 (each, a “Minor”). Minors are not permitted to use the Sites, and we request that Minors not submit any Personal Information through the services. If you believe your Minor (child) has impermissibly submitted Personal Information to us, or if you believe that we have received Personal Information about a Minor in any way, please contact us to request that such information be removed from our Services. Once we are aware of information impermissibly entered by a Minor, we will exercise commercially reasonable efforts to remove such information from our systems.
  3. Third Party Sites and Links: We are not responsible for the privacy practices and/or security practices employed by any third-party websites or service, including but not limited to any such sites or services that may be linked to or referred to in any way on the Sites.
  4. Transfer of Information. Murphree Investment Group Inc. is based in the State of Illinois, USA. Please be aware that your Personal Information may be transferred to, and be processed in, countries other than (a) the country in which you are a resident, and/or (b) the country in which you are located when Personal Information is collected or processed. And please be aware that the country(ies) in which your Personal Information is processed via the Services may have data protection laws that are different to the laws in (a) and (b) above. Further, please understand that elements of our service platform (including servers) are located in the United States, and our third-party Service Partners (including cloud service providers) may operate around the world. This means that, when we collect Personal Information, we or our Clients may process it in foreign jurisdictions. If we do, we will follow all rules and requirements including, Standard Contractual Clauses, Binding Corporate Rules, or other allowed facilities based on the country of origin and destination. However, we will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is collected, stored or processed. By accessing and/or by using the Sites or the Service, you expressly agree and consent to the terms of this Section 11(D).
  5. Personal Information: If you are a user from a country outside the United States, and you choose to access the Sites, you are deemed to consent to the transfer of any Personal Information you disclose from the country from which you reside or from which you access the Sites to United States, as allowed by law.
  6. Do Not Track: Some web browsers may transmit “Do Not Track” signals to websites visited by the user that signal to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, we do not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
  7. Biometric ID Processing: We do not use any technologies (e.g. face recognition) that are designed to identify an individual based on data (e.g. photographs, videos) collected/processed by the system.
  8. Accessibility: We strive to assure that our Sites are accessible. If you experience any difficulty in accessing any part of the Sites or this Privacy Policy, please contact us immediately.
  9. California Residents: If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. California’s “Shine the Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information, if any we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to use using the contact information provided above. Please allow up to 45 days for a response.
  10. Security. We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.
  11. Retention of Personal Information. We will keep your Personal Information while you have an account with us or while we are providing products and/or Services to you. Thereafter, we will keep your Personal Information for as long as is necessary for achieving the purposes for which it was collected or processed, unless a different retention period is required by applicable law. We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Notice. Different retention periods apply for different types of Personal Information. Certain Personal Information in connection with financial transactions for subscriptions cannot be deleted. When it is no longer necessary to retain your Personal Information, we will delete or anonymize it.
  12. Severability and Enforceability. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
  13. Modifications to the Privacy Policy. From time to time, we may update and post revisions to this Privacy Policy. Any changes will be effective immediately upon the posting of the revised Privacy Policy. We encourage you to review this page periodically for the latest information on our privacy practices. This Privacy Policy was updated as of the effective date listed above.
  14. Liability. Our liability from or arising out of this Privacy Policy or breach thereof shall be, regardless of theory of liability or cause of action, limited to direct damages, and shall not exceed US$100.00 under any circumstance.

12. Contact Us

If you have any questions about this Privacy Policy, our Sites and/or Services, you can contact us at:

Murphree Investment Group Inc.
100 S. Sanders Road, Suite 150
Lake Forest, IL 60045
service@murphreeinvestmentgroup.com
312-257-3003