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7:45 AM Eastern Time
Registration & Breakfast
8:15 AM Eastern Time
Pre-Conference Workshop: Analyzing the Economics of Full Term Deals - Traded Vs. Non-Traded Products – Separating Fact from Fiction
After the success of this pre-conference workshop at our June NYC symposium, we are pleased to offer this enhanced version which delves even deeper into some of the key issues at hand. There has been much debate over the years on the merits and drawbacks of Traded vs. Non-Traded investment products for both sponsors and retail investors. Particular focus has been given to front end fees and whether this puts Non-Traded product retail investors at a disadvantage from the start that cannot be regained. Recent studies have examined the relative performance of Traded vs. Non-Traded products. The findings in the studies have confirmed or dispelled some commonly held assumptions and has paved a path for further debate. In this opening session we revisit the issue by analyzing the economics of Traded and Non-Traded products over the course of their lifecycles. We compare and contrast costs, fees and performance and attempt to break down the Non-Traded model for both sponsors and retail investors.

• Front end fees / both acquisition and capital raising
• Annual costs including asset management fees and general and administrative costs
• Sponsor, director and officer promotes and incentive fees
• Dividend rates, IRRs and total returns
• Performance metrics-MFFO, FFO, AFFO, Core FFO
• Advised vs. internal management-pros/cons

Peter Fass

Partner
Proskauer Rose, LLP

Dana Woodbury

President
Buttonwood Investment Services

Phil Owens

Senior Vice President, Advisory & Consulting
Green Street Advisors

Kevin Gannon

Managing Director
Robert A. Stanger & Co.
9:05 AM Eastern Time
Pre-Symposium Workshop Concludes
9:10 AM Eastern Time
Welcome from IMN and Chairpersons’ Opening Remarks

Rosemarie Thurston

Partner
Alston & Bird LLP

Peter Fass

Partner
Proskauer Rose, LLP
9:20 AM Eastern Time
Non-Traded REIT & Non-Traded BDC Year End Market Update
* Capital raising: How does 2015 compare to recent years? Who are the top $ raisers by product type in the alternatives market? Are any alternatives likely to threaten the dominance of Non-Traded REITs? Are current capital raising trends amongst products likely to be permanent or an anomaly? What can we expect for capital raising market-wide in 2016? What will be the impact of FRN 15-02 on Non-Traded REIT/BDC/other DPP sales? Quantifying the impact of the change in definition of an accredited investor under FRN 15-02 * Non-Traded REIT/BDC performance: Who were the winners of 2015? What factors will likely impact performance/returns in 2016? * What was the rate of new product registration this year? Was this up or down on recent years? Will there be a significant increase in 2016? Who are the prime candidates for new product launches today? Will these industries continue to be dominated by a few big players? * What further product structure innovation can we expect within this market sector? Will new structures open up new distribution channels? * Liquidity events: Why wasn’t 2015 as active as anticipated? What activity can we expect in 2016? * M&As: Will consolidation between sponsors and/or IBDs continue at the same pace? * How are the dynamics of the Non-Traded REIT and BDC industries changing? What will these industries look like in 2-5 years’ time? What will this mean for product sponsors? Retail investors? *

Kevin Gannon

Managing Director
Robert A. Stanger & Co.
10:00 AM Eastern Time
Non-Traded REIT CEO/President Panel
* FINRA RN 15-02: With just 4 months to go, how have you responded? Have/will you reduce/eliminate front end fees? Have you/will you develop multi-class deals? What should Non-Traded REIT product structures look like in this evolving regulatory climate? * How are you viewing competition for retail investor $ from the growing number of retail alternative product launches? Are brand names such as Apollo, Blackstone and KKR entering the market a good or bad thing? * What is your take on the current health of the Non-Traded REIT market? Can Non-Traded REITs deliver in today’s investment environment? Where do you see the greatest investment opportunity in the near-term? Long-term? Where will growth of the retail investment product sector come from? How are you positioning to take advantage? What do you anticipate the Non-Traded REIT market will look like this time next year? Will traditional investors come back after the dust of 15-02 has settled? * What is your take on CRE investment and capital raising opportunities within Europe? Other overseas markets? Are they worth the extra hurdles? * Are you anticipating further product launches? Into new product types? What product types would you launch? Why? Will another product rise to the same prominence as Non-Traded REITs? If so, what will it look like? * Where will retail investors be concentrating their money in the next 2-5 years? *

Rosemarie Thurston

Partner
Alston & Bird LLP

William Miller

President & CEO
Cole Capital

Suneet Singal

Founding Principal/Chairman
First Capital Real Estate Investments

Mark Earley

CEO & President
Hines Securities, Inc.

Alan Feldman

Chief Executive Officer
Resource
10:45 AM Eastern Time
Morning Networking Break Courtesy of:
11:15 AM Eastern Time
DOL, FINRA, SEC, NASAA: A Practical Understanding of What the Latest Regulatory Developments Mean for Product Sponsors & Broker/Dealers
In this panel discussion we take a practical look at how key regulation/legislation will directly and indirectly impact product sponsors and independent retail broker/dealers (IBDs) and RIAs.
• The Department of Labor (DOL) Proposed Fiduciary Rule
• FINRA 15-02 • SEC updates
• NASAA: What is on the horizon?

Alice Connaughton

Partner
Morrison & Foerster LLP

Mark Quinn

Director of Regulatory Affairs
Cetera Financial Group

Kirk Montgomery

Partner
Kirk Montgomery Law, LLC

Robert Bergdolt

Partner
DLA Piper LLP (US)

Drew Dornbusch

Director of Product Development
NorthStar Asset Management Group

Michael Komenda

SVP, Head of Product Development
Cole Capital
12:15 PM Eastern Time
Best in Class? Comparing & Contrasting New Product Structures that Meet New Regulatory Requirements
In response to an evolving regulatory environment, new product structures are being introduced to the retail alternative investment industry. In this panel we compare and contrast some of these offerings and sponsor representatives weigh in on what will be the ‘best in class’ retail alternative investment product of the future. Among the discussion points are:

* Briefly outline your product structure: What is the rationale behind it? What investor/regulator ‘wants’ does it fulfil? * What is your investor base profile and what has been the investor uptake? * What are performance/return expectations? * What were the timing considerations in your launch? Costs? Fees? What would you have done differently with hindsight? * What are the sales & marketing considerations? How are you educating broker/dealers on your new product? What feedback are you getting? Is there a risk that too many dissimilar products could fracture the industry? * Compliance & due diligence issues * Exit strategies *

Michael Choate

Partner
Proskauer

Robert Hoffman

Executive Director, Fund Strategy
Franklin Square Capital Partners

Howard Hirsch

Chief Legal Officer
Griffin Capital Essential Asset REIT

Jason Plucinak

Sr VP of Business Development
GWG Holdings, Inc

Tim Toole

President and CEO
NorthStar Securities, LLC
1:00 PM Eastern Time
Lunch
Concurrent Sessions: Choose 'A' or 'B'
2:00 PM Track A
Assessing the Investment Potential of New & Existing Alternative Asset Types in 2016
2016 is another pivotal year. In this session we address the investment potential of new and existing asset types for retail alternative products against the backdrop of a strengthening economy and a presidential election year. Among the discussion points are:

* Some analysts predicted that 2015 would be the best year of economic recovery since the 2007 crash: Where are fundamentals at year-end? What is the 2016 macro-economic outlook and what is the impact of it being a presidential election year? The prospect of rising interest rates? Where are we in the real estate cycle? Are CRE pricing bubbles forming? Are there still opportunities to capture upside in either fundamentals or prices? In what markets? In what property types? Are current asset classes popular amongst alternative product sponsors over-subscribed? Is now a prime time for Non-Traded REIT sponsors to consider new asset types? Infrastructure, farmland, student housing, cell towers, correctional facilities, something else? What new asset types are attracting interest amongst Non-Traded REIT sponsors? What are the due diligence considerations? * What can Non-Traded REIT sponsors learn from the successes of Traded REITs and private equity funds in the investment of ‘alternative’ CRE assets? * What does the macro-economic outlook mean for the investment potential of oil and gas offerings – where are prices going? BDC offerings – how strong are the credit markets? *

John Harrison

Executive Director
ADISA

Brendan Connaughton

Chief Investment Officer
ClearPath Capital Partners

Mark Petersen

Head of Capital Markets
GWG

Daniel Oschin

Chief Strategy Officer
Shopoff Realty Investments, L.P.

Bruce Batkin

President & CEO
Terra Capital Partners, LLC
2:00 PM Track B
Navigating the Burgeoning Non-Traded BDC Market: Key Take-Aways for Prospective Sponsors & Retail Investors
There are now around 14 Non-Traded BDCs from 11 sponsors and more sponsors are expected to enter the market shortly. What are the factors driving growth in this market? Are they set to continue? How many products can the market sustain?

* Understanding the key differentiators between Non-Traded BDC products – Debt/equity and industry specializations * How do Non-Traded BDCs compare to traditional closed end credit funds and Traded BDCs for prospective sponsors? For retail investors? * What is the outlook for the credit markets? What will this mean for BDCs in 2016? * How do BDCs compare to other sources of finance for borrowers? * Where to be in the capital stack? * Originations vs. syndication: How important is it for a Non-Traded BDC to have an origination platform? * Master-feeder BDCs and multi-share class BDCs: Are they the future? How flexible is the BDC as a “wrapper” for an investment product? What opportunities and limitations does it pose for an issuer considering offering a BDC? What new product structures can we expect in the lead up to FRN 15-02? * How to evaluate a BDC? What are the key due diligence components? Valuation considerations? * How does the liquidity strategy for BDCs differ from REITs? Are BDCs better able to “self-liquidate” by letting the loans mature and simply distributing the proceeds to investors? Or is listing the ideal liquidity event for a BDC? What is the outlook for liquidity events next year? *

Jonathan Talcott

Partner and Co-Chair of Securities Practice Group
Nelson Mullins Riley & Scarborough LLP

Robert Hoffman

Executive Director, Fund Strategy
Franklin Square Capital Partners

Bill Lehew

Director of Strategic Accounts
Hines Securities, Inc.

Owen Pinkerton

Partner
Morris, Manning & Martin, LLP
2:45 PM Track A
Liquidity Events to Maximize Shareholder Value: The Need to Know for Sponsors, RIAs & Broker/Dealers
In this session we examine the key factors for consideration by both product sponsors and broker/dealers and RIAs when it comes to liquidity events and the maximizing of shareholder value. We explore the different liquidity options – M&As, listings, portfolio sales -and the subsequent decision and action points. Among the issues under discussion are:
• Assessing the pros/cons of the different liquidity event options:
       o For product sponsors 
       o For retail investors
• How do liquidity events impact the economics of the product?
• Key issues/considerations for the Board of Directors/Executive Management
• Corporate governance structures to avoid possible conflicts of interest
• Key considerations for broker/dealers & RIAs in representing client interests/maximizing shareholder value during the liquidity event
• Broker/dealers & RIAs: Considerations and decision points for reinvesting client capital
• To what degree do sponsors influence share price upon a listing?
• Sponsor-broker/dealer – RIA communications for a smooth liquidity process
• Tax planning, structuring and ongoing compliance
• Learning from recent liquidity event successes and failures

Peter Fass

Partner
Proskauer Rose, LLP

Gregory Paul

CEO
Central Trade & Transfer, LLC

William Miller

President & CEO
Cole Capital

Larry Steinberg

Chief Investment Officer
Financial Architects

Tyson Walter

Private Placement and Investment Banking Principal
Multiple Financial Services

Neil Greene

SVP & Due Diligence
Newbridge Securities
2:45 PM Track B
Dissecting ‘40 Act Interval & Closed End Funds & Assessing Their Place in a Retail Investor’s Portfolio Today
Should ‘40 Act interval funds be treated like an alternative or a mutual fund? Who makes a suitable retail investor? How do interval and closed end funds differ? How are they structured and what do they invest in? What are the nuances between the different products on the market? What are the risk/rewards? Due diligence and compliance considerations? How are such funds performing? These are just some of the questions that we answer as we dissect ‘40 Act interval and closed end funds and their place and value in retail investors’ portfolios as we head into 2016.

Janis Kerns

Of Counsel
Nelson Mullins Riley & Scarborough LLP

Michael De Luz

President
Financial West Group

Justin Milberg

Portfolio Manager, Diversified Income Fund
Resource

Rosemarie Leong

Due Diligence Manager
Silverhawk Private Wealth

Jon Kuczmarski

Portfolio Manager
WhaleRock Point Partners, LLC
3:30 PM Eastern Time
Afternoon Networking Break Courtesy of:
Attendees Reconvene for Closing General Sessions
4:00 PM Eastern Time
Assessing The Regulation D/Private Placement Market: The Good, The Bad & The In-Between
* Where does this market currently stand? Will 2016 finally be the year of new issuances? Why hasn’t there been a rush to market to-date? Do Regulation D offerings/private placements have an image to overcome? * Regulation D as a way to seed a portfolio * Regulation D offerings vs Non-Traded REITs: How do they compare in terms of what product sponsors can/can’t do? * Why sponsor a private placement over other alternative products? What are the risk-rewards? Costs? Timeframes and barriers to market entry? Valuation issues? * What are common product structures? * What makes a private placement attractive to retail investors vs. other alternative products? What are the risks for end-investors? What types of investor are private placements targeting and how? What has uptake been? What is their place in investors’ portfolios? Are they only for sophisticated investors? How to verify if investors are accredited? * What are the key issuer regulatory, due diligence and compliance hot buttons? Liabilities at the state and federal level? * How are Broker/Dealers viewing private placements? What are their key due diligence and compliance hot buttons? Liabilities? *

Daniel Oschin

Chief Strategy Officer
Shopoff Realty Investments, L.P.

Michael De Luz

President
Financial West Group

Robert Hoffman

Executive Director, Fund Strategy
Franklin Square Capital Partners

Rosemarie Leong

Due Diligence Manager
Silverhawk Private Wealth
4:45 PM Eastern Time
Multiple Share Classes? Daily NAV Products? Product Structure Consistency? What Sponsors Need to Do - & Not Do - to Meet Retail Investors’ Needs: Broker/Dealer & RIA Perspectives
We are pleased to introduce this highly popular session from our June NYC symposium……….The retail alternative investment industry has seen significant innovation in product structure in recent years. Such structures have been sponsors’ attempts to address concerns over perceived failings in legacy products, as well as to meet retail investor demand for greater returns and so further penetrate retail distribution channels. Such structures have had a varied reception from the IBD/RIA community. Following on from the earlier session on ‘best in class’ product structures addressed from the sponsor perspective, this session focuses on the IBD/RIA viewpoint. Is there a disconnect between what product sponsors are offering and what Broker/Dealers and RIAs actually want for their retail investor clients? What are the key issues that Broker/Dealers and RIAs face in selling these new products? In this session we invite representatives from the IBD/RIA community to discuss what they see as the pros and cons of recent product innovation and what they would like to see from the sponsor community to further make products ‘client friendly’.

Jason Goode

Partner
Alston & Bird LLP

Darren Whissen

President
Atomi Financial Group

Chad LaFauci

Director, Real Assets
Commonwealth Financial Network

Dan Breen

Partner
CFX Investing

Joseph Zarlenga

President
Ameriprise Financial
5:30 PM Eastern Time
Networking Reception Courtesy of:
 
6:30 PM Eastern Time
Close of Day One
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Event Contacts for The 11th Annual Western Non-Traded REIT & Retail Alternative Investment Symposium

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We will process your data for the following lawful purposes: with your consent; to fulfil our obligations to you; and where there is a legitimate interest to do so.

When possible, we rely on your consent to use your data for the purposes described in this Privacy Notice. We also process personal data to fulfil our contractual obligations to you, for example, when you register for any of our services, subscribe to a publication, sign-up for an event or purchase a product from us, we will need to process some of your personal data. This will also include details of the person/people responsible for payment (if different).

We may determine that processing your personal data serves both of our legitimate interests. This is the case in relation to many of our research, customer survey, sales, marketing and advertising activities described in this Privacy Notice. These activities allow us to better understand your requirements, which in turn enables us to provide you with a better service. We review the bases for our processing decisions carefully and you can object to these activities at any time (see the “Your Rights” section of this Privacy Notice).

What Personal Data We Collect & Why

Our primary goal in collecting personal data from you is to give you a relevant customised experience of our products and services.

  • Registration, Free Trials & Subscriptions

    When you register with our website and/or sign up for a free trial of our products or services, we may ask you to provide your name, address, email address and telephone number, and details relevant to your occupation or employer.

    If you subscribe to one of our products or services, we will also ask for payment details. Credit/debit card payments are processed using a third party supplier and we do not retain the credit card data (see the Third Party Sites of this Privacy Notice). Address details may be shared with third party service providers engaged by us for order fulfilment, delivery and payment collection. This personal data is used by us to complete subscription requests.

  • Events & Conferences

    If you have registered for an event through a group website we may collect personal data including: name, job title, company, address, telephone number and email.

    This information is necessary so that we can complete your registration for the event and provide you with relevant event materials.

    We may also provide delegate details (e.g. name, email) to event sponsors who, subject to your consent, may contact you for their own advertising and marketing purposes.

  • Advertising & Marketing

    We use the personal data you provide us and which we collect from you to inform you about similar products and services which we provide. We may send you marketing communications that are sponsored by our partners and which are targeted to your interests based on information you have provided us such as job title, employer and/or industry. If you have consented to receive information from other Euromoney group companies, we may share your personal data with these companies so that they can fulfil your request to receive marketing materials in accordance with your preferences. We will not share your personal data with any third parties for their own marketing purposes unless you have provided your consent.

    Each of the Euromoney group companies that may contact you is a data controller in relation to the personal data that you have agreed to share with them. If you have any questions or concerns, you may contact the individual company, or us – using the contact details set out in the “Who We Are” section.

    You can opt out from receiving such materials at any time.

    The personal data we may use for advertising and marketing purposes includes your name, email address, job title, phone number, company name/employer, geo location, postal address and data collected using cookies and other similar technology (Please read our separate Cookies Policy to find out more about which cookies we use, how they work and how you can control your cookie options).

    Marketing materials are sent electronically, by post and we may occasionally call you.

  • Online Targeted Advertising

    We use targeted advertising on our websites to display advertisements that are relevant to what we believe are your interests. In order to deliver relevant advertisements, we use third parties to deliver cookies that collect information about your IP address and how you interact with our sites (e.g. browsing information, which articles you have read etc.). This data is used by the third parties to determine which advertisements may be of interest to you.

    We may also share your personal data with third parties to deliver targeted advertising to you on other websites (e.g. Twitter Tailored Audiences or Facebook Custom Audiences). This could include your email address, cookie data, and information obtained from third parties. Third party cookies may also be used to enable us to target advertisements to you on other websites that you visit.

  • Lead Generation and Scoring

    We occasionally use the services of trusted third parties in order to ensure that the personal data we use for advertising and marketing purposes is accurate and up-to-date. To do this, we transfer personal data of individual leads (such as name, email, job title, location and phone number) to these third parties who conduct research to verify the data – primarily against public information.

    We also use algorithmic software technology to help us improve the quality and relevance of marketing activities. The personal data analysed by the software includes email address, phone number, job title, address, purchase history and account information. This allows us to provide meaningful offers that are relevant to your specific profile.

  • Surveys, Market Research & Customer Feedback

    We want to understand the needs of our readers and customers. We may therefore use the information you provide us – including your name and contact details – to contact you to request your feedback, or to participate in our customer and market research.

  • Public forums, message boards and blogs

    Some of the pages on our group websites may include message boards, blogs or other facilities for generating content from users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to post any personal data. User generated content is also subject to our site Terms & Conditions.

  • Business or Asset Sale

    If we sell a business or assets we may need to disclose your personal data to the prospective buyer of such business or assets.

    If Euromoney, or any of our group companies is sold or sells our assets or is acquired by a third party, then personal data about our customers will be acquired by that third party. A transfer of your personal data in these circumstances would be necessary so that the services you have contracted for can still be delivered, or so that you can continue to enjoy the benefits of our free products and services. You will receive notice if a new controller assumes responsibility for your personal data.

  • Additional Third Party Disclosures

    We may disclose your personal data to other third parties in the following situations:

    • To third party partners who help us by providing services such as technology, marketing, advisory or other services. These third parties only receive encrypted data and may only process personal data to provide those services to us.
    • Where we are required by law or regulation to do so. In each case we will seek, where practicable, to minimise the amount of data that is disclosed.
    • If required to protect the rights and interests of other users and/or Euromoney and its affiliates (including our employees, agents and contractors), or as otherwise set out in our Terms & Conditions. This may include exchanging information with other companies and organisations for the purposes of fraud protection.
  • Email Tracking

    We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected. You can opt out of receiving our direct marketing emails either by following the instructions in each email, or by contacting us (see the “Who We Are” section of this Privacy Notice).

International Transfers

Some of the Euromoney group companies are based outside the European Economic Area (EEA). If you have consented to being contacted by our group companies, then the transfer of your personal data will be made according to the terms of an international data sharing agreement that contains obligations approved by European data protection regulators. Any of our group companies that receive your personal data will be co-controllers of that data, which means they may determine how they process your personal data – although they may only use it for the purposes for which it was shared, unless you are informed of new or additional processing activities.

We may also transfer personal data to third party service providers as described in this Privacy Notice which are located outside the EEA. Where we conduct these transfers, we take all steps necessary to ensure that your data is treated securely and in accordance with applicable privacy legislation, either by only sending your personal data to jurisdictions that provide an adequate degree of legal protection for your data or by imposing approved contractual terms on these third parties.

Retention Periods

We have a data retention policy that ensures we don’t use or store your personal data for longer than necessary. We consider the following issues to determine retention periods:

  • Guidance from the UK Information Commissioner or other regulatory agency, or industry best practice recommendations;
  • The business rationale for collection and expiry of the purpose for which personal data was collected;
  • Our ongoing ability to ensure the accuracy of the data; and
  • Legal and regulatory requirements.

We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of an applicable retention period will be carried out in a manner that respects the rights and interests of all persons concerned.

How You Can Set Your Data & Privacy Preferences

You can use our Preference Centre to select the topics that are of interest to you so that we can send you publications and information about our products and services that are especially relevant to you. You can also choose the channels we use to contact you (email, phone, post, etc.) and can also opt-out of receiving marketing communications.

Your Rights

You have certain rights in relation to your personal data which include the following:

  • Access & Portability

    You may request access to any personal data of yours for which Euromoney is responsible as controller. Unless there are legal or regulatory reasons for not doing so, we will confirm whether we process any of your personal data and if we do, we will provide you with the following information: the purposes of the processing, the categories of personal data, any recipients of your personal data, the applicable retention period and the data source. Copies of your personal data will be made available to you in a structured, machine-readable format.

    You may also request that we transfer the personal data that you have submitted to us, to another controller, where it is technically feasible for us to do so.

    If you have consented to our processing of your personal data, or if we are processing your personal data in order to fulfil our contractual obligations to you, then you can submit a request that we transfer your personal data to another data controller.

  • Rectification, Restriction, Objection

    You have the right to request that Euromoney rectify any errors in the personal data that we process. In some circumstances, you may also be able to ask for the erasure of personal data, and/or request that the processing of your personal data be restricted. You may also object to the processing of your personal data for sales or marketing purposes.

  • How to Exercise Your Rights

    To exercise any of these rights, please contact us by post or email at the following addresses:

    Euromoney Institutional Investor PLC
    8 Bouverie Street
    London, EC4Y 8AX
    United Kingdom

    Email: dataprotectionofficer@euromoneyplc.com

    Web form: Complete Subject Data Request Form

    We may need to check your identity prior to processing a request.

    Euromoney will do our best to respond to any questions and address any of your concerns. You are also able to register any complaints regarding the processing of your personal data directly with the UK Information Commissioner.

Protecting Your Data

Euromoney is committed to keeping your personal data secure and we will take appropriate technical and organisational measures to protect your personal data from loss, unauthorised use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk. We have therefore implemented information security policies and rules, staff training on information security, and technical measures to ensure the integrity of data that we have under our control.

All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.

Third Party Sites

Our site may contain links to other websites – including, for example, providers of payment processing services. Euromoney is not responsible for the privacy and data collection practices of third party sites and we therefore recommend that you review the privacy policies and terms of service of each site you visit.

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