Privacy Policy

Quorus Inc. ("Quorus," "we," "us," "our") operates the website at https://www.quorus.io (the "Website"). This policy explains what information we collect from Website visitors, how we use it, who we share it with, and the choices and rights you have.

This policy covers our Website only. If you are a client of an investment adviser that uses Quorus for portfolio implementation, your relationship with that adviser is governed by the adviser's own privacy notice, and separate notices may apply to information we handle in our capacity as a sub-adviser. Contact us if you are unsure which applies to you.

Consent

We do not place analytics, measurement, or session recording technologies on your device, and we do not begin collecting information through them, until you consent through the cookie banner presented on your first visit. Until you make a choice, only strictly necessary cookies operate.

You can change or withdraw your consent at any time through the cookie preference center, available from the link in our footer. We honor Global Privacy Control signals sent by your browser.

Continuing to browse the Website does not by itself constitute consent to non-essential tracking.

Information We Collect

Information you give us

When you submit our meeting request form or otherwise contact us, we collect:

• Your work email address
• Your firm name
• The content of your inquiry, meaning whatever you choose to write in the free-text field describing what you would like us to review

We use this to respond to you and, if a business relationship develops, to communicate with you about it. We do not require you to provide any of it in order to browse the Website.

The free-text field is optional and unstructured. Please do not enter client names, account numbers, or other confidential information about third parties in it. If you need to share that kind of detail, we will arrange a secure method.

Information collected automatically

When you visit the Website, our servers and, with your consent, our analytics providers receive:

• Your IP address, and an approximate geographic region derived from it
• Your browser type and version, operating system, and device type
• The pages you view, the time and date of your visit, and how long you spend on each page
• The referring source that brought you to the Website
• With your consent, a reconstruction of your interaction with our pages. See Analytics and Session Recording below.

Information we do not collect

We do not use advertising, retargeting, or interest-based profiling technologies on this Website. We do not share online identifiers, hashed email addresses, or other data with advertising networks. We do not build marketing profiles about you across other websites.

We do not collect sensitive personal information through this Website for the purpose of inferring characteristics about you.

Cookies and Tracking Technologies

Cookies are small files placed on your device by a website. We also use related technologies, including web beacons (small transparent image files, sometimes called clear gifs or pixel tags) that let us count visits to a page or opens of an email.

Cookies are either session cookies, which are deleted when you close your browser, or persistent cookies, which remain on your device until they expire or you delete them.

We use the following categories.

Strictly necessary cookies Set without consent, because the Website cannot function without them. Administered by: Quorus Purpose: core Website functionality, security, and recording your cookie consent choice so we do not ask again on every page.

Functional cookies Set only with your consent. Administered by: Quorus Purpose: remember preferences you set, so you do not have to re-enter them.

Analytics and performance cookies Set only with your consent. Administered by: Google LLC and Microsoft Corporation Purpose: measure Website traffic and record visitor sessions so we can understand how the Website is used and improve it. See Analytics and Session Recording below.

Advertising cookies We do not use advertising cookies on this Website. This category appears in our consent banner so your preference is recorded if we introduce such technologies in future. No advertising cookies are currently set.

A current itemized list of the specific cookies in use, with their names, providers, durations, and purposes, is available in our Cookie Policy and in the cookie preference center accessible from any page.

Most browsers also let you refuse or delete cookies. Refusing strictly necessary cookies may prevent parts of the Website from working.

Analytics and Session Recording

With your consent, we use two third-party services to understand how visitors use the Website. Neither operates until you accept the analytics category in our cookie banner. If you decline, or take no action, neither collects information about your visit.

Google Analytics 4

Provided by Google LLC. Google Analytics gives us aggregate measurement of Website traffic, including pages viewed, time on page, approximate geographic region derived from IP address, device and browser type, and referring source.

We use Google Consent Mode, which means Google's tags read and respect your consent choice.

Google's privacy practices: https://policies.google.com/privacy Browser opt-out for all sites using Google Analytics: https://tools.google.com/dlpage/gaoptout

Microsoft Clarity

Provided by Microsoft Corporation. Clarity provides behavioral analytics including session recordings and heatmaps.

When enabled with your consent, Clarity records a reconstruction of your interaction with our pages. This may include mouse movement, clicks, scrolling, page navigation, and the sequence and timing of your interactions with elements on the page. These recordings are transmitted to and stored by Microsoft. We use them to identify usability problems and improve the Website.

We limit what recordings can capture in two ways:

• Our meeting request form is excluded from session recording entirely. Your interaction with that form is not recorded, and nothing you enter into it appears in any recording.
• Elsewhere on the Website, text you type into input fields is masked in recordings, so the characters you enter are not visible. Recordings may include text that is already displayed publicly on our pages.

We do not use session recordings to identify individual visitors, and we do not attempt to link recordings to your name, email address, or firm.

Microsoft's privacy practices: https://privacy.microsoft.com/privacystatement

How We Use Information

We use the information described above to:

• Operate, maintain, and secure the Website
• Respond to your inquiries and arrange meetings you request
• Communicate with you about our products and services, where you have asked us to or where you have an existing business relationship with us, subject to your right to opt out at any time
• Understand how the Website is used, identify usability problems, and improve it
• Comply with our legal and regulatory obligations, including recordkeeping obligations applicable to us as an SEC-registered investment adviser
• Establish, exercise, or defend legal claims
• Evaluate or complete a merger, financing, acquisition, or sale of assets, in which case information about Website visitors may be among the assets involved

How We Share Information

We share information only in the circumstances below.

Service providers and processors. We use third parties to provide the Website and our operations, including hosting, email, analytics, and consent management. They may process information only on our instructions and for the purposes we specify, and are prohibited from using it for their own purposes. Our analytics providers are named in Analytics and Session Recording above.

Legal and regulatory disclosure. We may disclose information where required by law, or in response to a valid request from a court, regulator, or other public authority. As an SEC-registered investment adviser, we may be required to produce records in connection with examination or enforcement.

Protection of rights. We may disclose information where we believe in good faith it is necessary to comply with a legal obligation, protect our rights or property, investigate possible wrongdoing in connection with the Website, protect the safety of any person, or protect against legal liability.

Corporate transactions. If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction. We will provide notice before information about you becomes subject to a different privacy policy.

With your consent. For any other purpose you agree to.

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising or targeted advertising. We have not done either in the preceding twelve months. We do not knowingly sell or share the personal information of anyone under 16 years of age.

Retention

We keep information only as long as we need it for the purposes described in this policy, or as long as we are required to keep it by law or by the recordkeeping obligations that apply to us as an SEC-registered investment adviser.

• Inquiry and meeting request form submissions: 6 years
• Analytics measurement data (Google Analytics): 14 months
• Session recordings (Microsoft Clarity): 30 days, or 9 months for sessions we specifically flag for further review
• Heatmap and aggregate interaction data (Microsoft Clarity): 9 months
• Cookie consent records: 5 years

We keep inquiry submissions and cookie consent records longer than analytics data because we are required to retain business records, and because consent records evidence the choices visitors have made.

Where a regulatory retention obligation requires us to keep information longer than the periods above, that obligation governs.

Your Choices

Cookie preferences. Review or change your consent choices at any time using the "Cookie Preferences" link in our footer. Withdrawing consent stops further collection by the affected technologies. Declining the analytics category stops both Google Analytics and Microsoft Clarity.

Global Privacy Control. We honor Global Privacy Control signals. If your browser or an extension sends a GPC signal, we treat it as a request to opt out of the sale or sharing of personal information and to decline non-essential tracking.

Browser controls. Most browsers let you block or delete cookies, and many offer a private browsing mode.

Google Analytics opt-out. Google offers a browser add-on that opts you out of Google Analytics across all websites: https://tools.google.com/dlpage/gaoptout

Email. Unsubscribe using the link in any message we send, or contact us and we will remove you.

State Privacy Rights

Notice at Collection

The categories of personal information we collect from Website visitors, and what we do with them:

Identifiers

• Examples: work email address, firm name
• Source: you, via our forms
• Purpose: respond to your inquiry; business communications
• Disclosed to: service providers

Commercial information

• Examples: the content of your inquiry
• Source: you, via our forms
• Purpose: evaluate and respond to your request
• Disclosed to: service providers

Internet or network activity

• Examples: pages viewed, session duration, referring source, interaction recordings
• Source: collected automatically, with your consent
• Purpose: Website measurement and improvement
• Disclosed to: Google LLC, Microsoft Corporation

Geolocation (imprecise)

• Examples: approximate region derived from IP address
• Source: collected automatically, with your consent
• Purpose: Website measurement
• Disclosed to: Google LLC, Microsoft Corporation

Retention periods are in the Retention section above. We do not sell or share any of these categories.

Your Rights

If you are a resident of California, Connecticut, or another state with a comprehensive consumer privacy law, you may have the right to:

• Know what personal information we have collected about you, and the categories of sources, purposes, and recipients
• Access a copy of your personal information in a portable format
• Correct inaccurate personal information we hold about you
• Delete personal information we have collected from you
• Opt out of the sale or sharing of personal information, and of targeted advertising
• Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects
• Not be discriminated against for exercising any of these rights

To exercise a right, email contact@quorus.io or write to us at the address below. We will verify your request using information already in our possession, and respond within the period required by applicable law.

You may designate an authorized agent to submit a request for you. We may require the agent to provide proof of authorization and may ask you to verify your identity directly.

Appeals

If we deny your request, you may appeal by replying to our response with the word "Appeal," or by emailing contact@quorus.io with "Appeal" in the subject line. We will respond within the period required by applicable law. If we deny your appeal, we will tell you how to contact your state Attorney General.

Security

We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, alteration, disclosure, and destruction. These include encryption of data in transit and at rest, access controls, logging, and monitoring, and are governed by our internal information security program.

No method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, and we do not claim to.

Where Information Is Processed

We operate in the United States, and information we collect is processed in the United States. Our service providers may process information in other locations. Where information is transferred outside the jurisdiction in which it was collected, we take steps intended to ensure it remains protected consistently with this policy.

If you are accessing the Website from outside the United States, be aware that data protection law in the United States may differ from the law where you are located.

Children

The Website is not directed to children, and we do not knowingly collect personal information from anyone under 13. If you are a parent or guardian and believe your child has given us personal information, contact us and we will delete it.

As stated above, we do not knowingly sell or share the personal information of anyone under 16.

Links to Other Websites

The Website contains links to sites we do not operate, including our regulatory filings on the SEC's Investment Adviser Public Disclosure system. We do not control those sites and are not responsible for their content or privacy practices. Review the privacy policy of any site you visit.

Changes to This Policy

We may update this policy. When we do, we will post the revised version on this page and update the "Last updated" date above. If the changes are material, we will provide more prominent notice, which may include email notification or a notice on the Website, before the changes take effect.

Review this page periodically. Changes take effect when posted, unless we state otherwise.

Contact Us

Questions about this policy, or about how we handle your information:

Email: contact@quorus.io

Mail: Quorus Inc. 500 Post Road East, 2nd Fl, Suite 303 Westport, CT 06824