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Last updated: July 15, 2025

McElvaine Investment Management Ltd. (“McElvaine”, “we”, “our”, or “us”) is committed to protecting your privacy. This Website Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website [www.avaluefund.com](https://www.avaluefund.com).

1. Information We Collect

We may collect the following types of information when you use our website:

• - Personal Information you voluntarily provide, such as your name and email address (e.g., when subscribing to updates or contacting us).

• - Technical information, such as your IP address, browser type, device information, pages visited, and time spent on our site. This is collected through cookies and similar technologies to help us improve the site.

2. How We Use Your Information

We use your information to:

• - Respond to inquiries or requests you submit;

• - Send you updates or newsletters, if you’ve subscribed;

• - Analyze website usage and improve performance;

• - Meet legal or regulatory requirements.

We will not use your personal information for any other purpose without your consent.

3. Sharing Your Information

We do not sell your personal information.

We may share your personal information:

• - With trusted third-party service providers who help us operate the website (e.g., email providers);

• - If required by law or to comply with legal obligations;

• - To protect our rights or the rights of others.

Any third parties are required to maintain the confidentiality and security of your information.

4. Cookies

Our website uses cookies to improve your browsing experience. You can adjust your browser settings to refuse cookies or alert you when cookies are being sent.

5. Data Security

We use reasonable physical, organizational, and technological safeguards to protect your personal information from unauthorized access, disclosure, or misuse.

6. Your Rights

You have the right to:

• - Access the personal information we hold about you;

• - Correct or update your information;

• - Withdraw your consent (subject to legal or contractual restrictions).

To do so, contact our Chief Privacy Officer at info@avaluefund.com.

7. Changes to This Policy

We may update this policy from time to time. The “Last updated” date will reflect the most recent version. We encourage you to review this policy periodically.

8. Contact Us

If you have any questions or concerns about this privacy policy or how we handle your personal information, please contact:

Chief Privacy Officer
Tim McElvaine
info@avaluefund.com