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CPM Investing LLC - Research Publications

ETF Model Portfolios for High Return and Low Variability

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29. NOTICES AND COMMUNICATION - CPM Investing LLC may furnish you with notices, including those with regards to any changes to the TOS, including but not limited to email, regular mail, MMS or SMS, text messaging, postings on our website Services, or other reasonable means currently known or any which may be herein after developed. Any such notices may not be received if you violate any aspects of the TOS by accessing our Services in an unauthorized manner. Your acceptance of this TOS constitutes your agreement that you are deemed to have received any and all notices that would have been delivered had you accessed our Services in an authorized manner.

30. INTELLECTUAL PROPERTY - CPM Investing LLC will always respect the intellectual property of others, and we ask that all of our users do the same. With regards to appropriate circumstances and at its sole discretion,

CPM Investing LLC may disable and/or terminate the accounts of any user who violates our TOS and/or infringes the rights of others. If you feel that your work has been duplicated in such a way that would constitute copyright infringement, or if you believe your intellectual property rights have been otherwise violated, you should provide to us the following information:

- a) The electronic or the physical signature of the individual that is authorized on behalf of the owner of the copyright or other intellectual property interest;

- b) A description of the copyrighted work or other intellectual property that you believe has been infringed upon;

- c) A description of the location of the site which you allege has been infringing upon your work;

- d) Your physical address, telephone number, and email address;

- e) A statement, in which you state that the alleged and disputed use of your work is not authorized by the copyright owner, its agents or the law;

- f) And finally, a statement, made under penalty of perjury, that the aforementioned information in your notice is truthful and accurate, and that you are the copyright or intellectual property owner, representative or agent authorized to act on the copyright or intellectual property owner's behalf.

The CPM Investing LLC Agent for notice of claims of copyright or other intellectual property infringement can be contacted as follows:

CPM Investing LLC

Attn: Copyright Agent

PO Box 878

Summit, New Jersey 07902

Email: Contact@Focused15Investing.com

31. TRADEMARK & COPYRIGHT INFORMATION - You herein acknowledge, understand and agree that all of the CPM Investing LLC trademarks, copyright, trade name, service marks, and other CPM Investing LLC logos and any brand features, and/or product and service names are trademarks and as such, are and shall remain the property of CPM Investing LLC. You herein agree not to display and/or use in any manner the CPM Investing LLC logo or marks without obtaining CPM Investing LLC's prior written consent.

32. ENTIRE AGREEMENT - This TOS constitutes the entire agreement between you and CPM Investing LLC and shall govern the use of our Services, superseding any prior version of this TOS between you and us with respect to CPM Investing LLC Services. You may also be subject to additional terms and conditions that may apply when you use or purchase certain other CPM Investing LLC Services, affiliate Services, third-party content or third-party software.

33. CHOICE OF LAW AND FORUM - It is at the mutual agreement of both you and CPM Investing LLC with regard to the TOS that the relationship between the parties shall be governed by the laws of the state of New Jersey without regard to its conflict of law provisions and that any and all claims, causes of action and/or disputes, arising out of or relating to the TOS, or the relationship between you and CPM Investing LLC, shall be filed within the courts having jurisdiction within the County of Morris, New Jersey or the U.S. District Court located in said state. You and CPM Investing LLC agree to submit to the jurisdiction of the courts as previously mentioned, and agree to waive any and all objections to the exercise of jurisdiction over the parties by such courts and to venue in such courts.

34. WAIVER AND SEVERABILITY OF TERMS - At any time, should CPM Investing LLC fail to exercise or enforce any right or provision of the TOS, such failure shall not constitute a waiver of such right or provision. If any provision of this TOS is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties' intentions as reflected in the provision, and the other provisions of the TOS remain in full force and effect.

35. NO RIGHT OF SURVIVORSHIP NON-TRANSFERABILITY - You acknowledge, understand and agree that your account is non-transferable and any rights to your ID and/or contents within your account shall terminate upon your death. Upon receipt of a copy of a death certificate, your account may be terminated and all contents therein permanently deleted.

36. VIOLATIONS - Please report any and all violations of this TOS to CPM Investing LLC as follows:

CPM Investing LLC

PO Box 878

Summit, New Jersey 07902

Contact@Focused15Investing.com

38. CONTACT AND EFFECTIVE DATE - Email for all contact with CPM Investing LLC: Contact@Focused15Investing.com

Effective as of October 31, 2019

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1. OVERVIEW - CPM Investing LLC (CPM) values its users' privacy. This Privacy Policy ("Policy") will help you understand how we collect and use personal information from those who visit our website or make use of our online facilities and services, and what we will and will not do with the information we collect. Our Policy has been designed and created to ensure those affiliated with CPM Investing LLC of our commitment and realization of our obligation not only to meet, but to exceed, most existing privacy standards.

We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page. If at any point in time CPM Investing LLC decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, the user or users shall be promptly notified by email. Users at that time shall have the option as to whether to permit the use of their information in this separate manner. This Policy applies to CPM Investing LLC, and it governs any and all data collection and usage by us. Through the use of Focused15Investing.com and submitting information to CPM Investing through other means, you are therefore consenting to the data collection procedures expressed in this Policy.

Please note that this Policy does not govern the collection and use of information by companies that CPM Investing LLC does not control, nor by individuals not employed or managed by us. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information. It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent to better understand the way in which websites garner, make use of and share the information collected.

Specifically, this Policy will inform you of the following

- 1. What personally identifiable information is collected from you through our website;

- 2. Why we collect personally identifiable information and the legal basis for such collection;

- 3. How we use the collected information and with whom it may be shared;

- 4. What choices are available to you regarding the use of your data; and

- 5. The security procedures in place to protect the misuse of your information

2. Information We Collect - It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with products or services. This website collects various types of information, such as:

- Voluntarily provided information which may include your name, address, email address, billing and/or credit card information etc. which may be used when you purchase products and/or services and to deliver the services you have requested.

- Information automatically collected when visiting our website, which may include cookies, third party tracking technologies and server logs.

In addition, CPM Investing LLC may have the occasion to collect non-personal anonymous demographic information, such as age, gender, household income, political affiliation, race and religion, as well as the type of browser you are using, IP address, or type of operating system, which will assist us in providing and maintaining superior quality service. CPM Investing LLC may also deem it necessary, from time to time, to follow websites that our users may frequent to gleam what types of services and products may be the most popular to customers or the general public.

Please rest assured that this site will only collect personal information that you knowingly and willingly provide to us by way of surveys, completed membership forms, and emails. It is the intent of this site to use personal information only for the purpose for which it was requested, and any additional uses specifically provided for on this Policy.

3. Why We Collect Information and For How Long - We are collecting your data for several reasons:

- To better understand your needs and provide you with the services you have requested;

- To fulfill our legitimate interest in improving our services and products;

- To send you promotional emails containing information we think you may like when we have your consent to do so;

- To contact you to fill out surveys or participate in other types of market research, when we have your consent to do so;

- To customize our website according to your online behavior and personal preferences.

The data we collect from you will be stored for no longer than necessary. The length of time we retain said information will be determined based upon the following criteria: the length of time your personal information remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators, professional bodies or associations; the type of contract we have with you, the existence of your consent, and our legitimate interest in keeping such information as stated in this Policy.

4. Use of Information Collected - CPM Investing LLC does not now, nor will it in the future, sell, rent or lease any of its customer lists and/or names to any third parties. CPM Investing LLC may collect and may make use of personal information to assist in the operation of our website and to ensure delivery of the services you need and request. At times, we may find it necessary to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you from us. CPM Investing LLC may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future services that may be offered.

CPM Investing LLC uses various third-party social media features including but not limited to Google, FaceBook, Vimeo, and Godaddy and other interactive programs for supporting CPM Services and promotional activities and may use your information with these entities. These entities may also collect your IP address and require cookies to work properly. These services are governed by the privacy policies of the providers and are not within CPM Investing LLC's control.

5. Disclosure of Information - CPM Investing LLC may not use or disclose the information provided by you except under the following circumstances:

- as necessary to provide services or products you have ordered;

- in other ways described in this Policy or to which you have otherwise consented;

- in the aggregate with other information in such a way so that your identity cannot reasonably be determined;

- as required by law, or in response to a subpoena or search warrant;

- to outside auditors who have agreed to keep the information confidential;

- as necessary to enforce the Terms of Service;

- as necessary to maintain, safeguard and preserve all the rights and property of CPM Investing LLC.

6. Non-Marketing Purposes - CPM Investing LLC greatly respects your privacy. We do maintain and reserve the right to contact you if needed for non-marketing purposes, such as bug alerts, security breaches, account issues, and/or changes in CPM Investing LLC products and services. In certain circumstances, we may use our website, newspapers, or other public means to post a notice.

7. Children Under the Age of 13 - CPM Investing LLC's website is not directed to, and does not knowingly collect personal identifiable information from, children under the age of thirteen (13). If it is determined that such information has been inadvertently collected on anyone under the age of thirteen (13), we shall immediately take the necessary steps to ensure that such information is deleted from our system's database, or in the alternative, that verifiable parental consent is obtained for the use and storage of such information. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission to use this website.

8. Unsubscribe or Opt-Out - All users and visitors to our website have the option to discontinue receiving communications from us by way of email or newsletters.

To discontinue or unsubscribe from our website please send an email that you wish to unsubscribe to Contact@Focused15Investing.com.

If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific website to unsubscribe or opt-out. CPM Investing LLC will continue to adhere to this Policy with respect to any personal information previously collected.

9. Links to Other Websites - Our website does contain links to affiliate and other websites. CPM Investing LLC does not claim nor accept responsibility for any privacy policies, practices and/or procedures of other such websites. Therefore, we encourage all users and visitors to be aware when they leave our website and to read the privacy statements of every website that collects personally identifiable information. This Privacy Policy Agreement applies only and solely to the information collected by our website and provided directly to CPM Investing LLC.

10. Notice to European Union Users - CPM Investing LLC's operations are located primarily in the United States. If you provide information to us, the information will be transferred out of the European Union (EU) and sent to the United States. (The adequacy decision on the EU-US Privacy became operational on August 1, 2016. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the US under the Privacy Shield.) By providing personal information to us, you are consenting to its storage and use as described in this Policy.

11. Security - CPM Investing LLC takes precautions to protect your information. When you submit sensitive information via the website or directly to CPM Investing, your information is protected both online and offline. Wherever we collect sensitive information (e.g. credit card information), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment. This is all done to prevent any loss, misuse, unauthorized access, disclosure or modification of the user's personal information under our control.

The company also uses Secure Socket Layer (SSL) for authentication and private communications to build users' trust and confidence in the internet and website use by providing simple and secure access and communication of credit card and personal information.

12. Acceptance of Privacy Policy Terms - By using this website or submitting information directly to CPM Investing, you are hereby accepting the terms and conditions stipulated within the Privacy Policy Agreement. If you are not in agreement with our terms and conditions, then you should refrain from further use of our sites and submission of information directly to CPM Investing. In addition, your continued use of our website following the posting of any updates or changes to our terms and conditions shall mean that you agree and acceptance of such changes.

13. How to Contact Us - If you have any questions or concerns regarding the Privacy Policy Agreement, please feel free to contact us at the following email, telephone number or mailing address.

Email: Contact@Focused15Investing.com

Mailing Address:

CPM Investing LLC

PO Box 878

Summit, New Jersey

07902

Revised October 13, 2019

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