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GDPR Privacy Policy

EFFECTIVE MAY 25, 2019 as amended AUGUST 11, 2021

This Privacy Policy describes how your personal information is collected, used, and shared when you visit, contact an employee from New Age Alpha LLC (or any of its affiliated entities), or sign up for communications from New Age Alpha from www.newagealphaetfs.com (the “Site”) or the New Age Alpha mobile applications, including the H-Factor System (“apps”).

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Personal Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Personal and Device Information that we collect through the site. Additionally, we use this Information to:

Communicate with you;

Screen for potential risk or fraud; and

When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.

You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

BEHAVIORAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at
http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

FACEBOOK – https://www.facebook.com/settings/?tab=ads

GOOGLE – https://www.google.com/settings/ads/anonymous

BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

DATA RETENTION

When you interact through the Site, we will maintain your Device and Personal Information for our records unless and until you ask us to delete this information.

MINORS

The Site is not intended for individuals under the age of 21.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at privacy@newagealpha.com or by mail using the details provided below:

New Age Alpha Advisors, LLC
555 Theodore Fremd Ave.
Suite A-101
Rye, New York 10580
United States
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Overview Team
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United States

New Age Alpha LLC

555 Theodore Fremd Avenue, Suite A101 Rye, New York 10580

212.922.2699
212.922.2698

South Africa

New Age Alpha SA (Pty) Ltd

18th Floor Metalbox, 25 Owl Street,
Auckland Park, Johannesburg 2092

+27.11.486.2500
+27.11.486.2915

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Legal Notices

Fill out the form below and a Portfolio Specialist will be in touch within 24 hours to help answer any questions and provide additional information about our investment solutions and indexes.

© 2022 New Age Alpha LLC. All Rights Reserved.
New Age Alpha, Human FactorTM, H-Factor, No Alpha No Fee, Avoid the Losers are all trademarks of New Age Alpha LLC.

All New Age Alpha trademarks are owned by New Age Alpha LLC. S&P is a registered trademark of Standard & Poor's Financial Services LLC (SPFS). All other company or product names mentioned therein, including S&P and Thomson Reuters or Refinitiv, are the property of their respective owners and should not be deemed to be an endorsement of any New Age Alpha product, strategy or fund.

The New Age Alpha U.S. Large-Cap Leading 50 Index is part of the index family offered by New Age Alpha, LLC. The New Age Alpha U.S. Large-Cap Leading 50 Index consists of 50 U.S. stocks in the S&P 500 as ranked by the combination of Human Factor score (“HF”), and other rules-based criteria as defined by the index methodology.

The New Age Alpha U.S. Large-Cap ESG Index is part of the index family offered by New Age Alpha, LLC. The New Age Alpha U.S. Large-Cap ESG Index consists of 50 U.S. stocks in the Refinitiv U.S. Total Return Index as ranked by the combination of ESG score, Human Factor score (“HF”), and other rules-based criteria as defined by the Index methodology.

ESG - Is designed to be a socially responsible investment benchmark. The Environmental, Social & Governance matters (ESG) in this context is designed to measure the performance of a company's business operations and governance as it relates to financially material ESG factors. All ESG data is sourced, provided and calculated by Thomson Reuters/Refinitiv. Nothing contained herein shall be interpreted to serve as an endorsement of any New Age Alpha product, strategy or portfolio by Thomson Reuters or Refinitiv. Events such as the recent Ukraine and Russia conflict are factors in the ESG methodology. More information about the ESG methodology used herein is available upon request. The New Age Alpha ESG Indexes are designed to be socially responsible investment strategies. The New Age Alpha ESG policies could cause it to make or avoid investments that could result in the portfolio underperforming, similar indexes, portfolios or funds that do not have an ESG Policy.

The New Age Alpha Developed World Ex-US Leading Index is part of the index family offered by New Age Alpha, LLC. The New Age Alpha Developed World Ex-U.S. Leading Index employs a rule-based, index of indexes methodology in allocating weights among the New Age Alpha Japan Leading 50 Index, New Age Alpha United Kingdom Leading 50 Index and the New Age Alpha Europe Ex-UK Leading 75 Index.

The S&P 500 Index is a market-capitalization-weighted index of 500 of the largest publicly traded companies in the U.S.. It is not an exact list of the top 500 U.S. companies by market capitalization because there are other criteria to be included in the index. The index is widely regarded as the best gauge of large-cap U.S. equities. A total return index represents the total return earned in a portfolio that tracks the underlying price index and reinvests dividend income in the overall index, not in the specific stock paying the dividend.

The S&P 500 ESG TR Index is a broad-based, market-cap-weighted index that is designed to measure the performance of securities meeting sustainability criteria, while maintaining similar overall industry group weights as the S&P 500. In a total return index, changes in the index level reflect both movements in stock prices and the reinvestment of dividend income. A total return index represents the total return earned in a portfolio that tracks the underlying price index and reinvests dividend income in the overall index, not in the specific stock paying the dividend

Part of the S&P Global BMI TR Index series, the S&P Developed Ex-U.S. BMI is a comprehensive benchmark including stocks from developed markets excluding the United States. A total return index represents the total return earned in a portfolio that tracks the underlying price index and reinvests dividend income in the overall index, not in the specific stock paying the dividend.

Alpha - The extra return due to nonmarket factors. This risk-adjusted factor takes into account both performance of the market as a whole and the volatility of the manager’s performance. A positive Alpha indicates that a manager has produced returns above the expected amount at that risk level, and vice versa for a negative.

Batting Average - A measure of a manager's ability to consistently beat the market. It is calculated by dividing the number of months in which the manager beat or matched an index by the total number of months in the period.

Beta - A measure of the volatility of an index or investment relative to a benchmark. A reading of 1.00 indicates that the investment has moved in lockstep with the benchmark; a reading of -1.00 indicates that the investment has moved in the exact opposite direction of the benchmark.

Downside Capture – A measure of an investment manager's overall performance in down-markets. The downside capture ratio is used to evaluate how well or poorly an investment manager performed relative to an index during periods when that index has dropped.

Information Ratio - A measurement of portfolio returns beyond the returns of a benchmark, usually an index, compared to the volatility of those returns.

R-Squared - A measure that represents the percentage of a fund’s or security's movements that are explained by movements in a benchmark index. For fixed-income securities the benchmark is the T-bill, and for equities the benchmark is the S&P 500.

Tracking Error - A measure of the volatility of excess returns relative to a benchmark.

Sharpe Ratio - A measure of risk-adjusted return. Higher values indicate greater return per unit of risk, specifically standard deviation, which is viewed as being desirable.

Standard Deviation - A measure of how widely an investment or investment strategy’s returns move relative to its average returns for an observed period. A higher value implies more “risk”, in that there is more of a chance the actual return observed is farther away from the average return.

Upside Capture - A measure of an investment manager's overall performance in up-markets. The upside capture ratio is used to evaluate how well an investment manager performed relative to an index during periods when that index has risen.

Prospectus Offering Investors should carefully consider the investment objectives, risks, charges and expenses of the New Age Alpha Funds. This and other important information about the Funds is contained in the prospectus, which can be obtained at www.newagealphaetfs.com or by calling 888-559-7146. The prospectus should be read carefully before investing. The New Age Alpha Funds are distributed by Northern Lights Distributors, LLC, member FINRA/SIPC. Northern Lights Distributors, LLC is not affiliated with New Age Alpha Advisors, LLC.

Performance Disclosure Language The performance data quoted here represents past performance. Current performance may be lower or higher than the performance data quoted above. Investment return and principal value will fluctuate, so that shares, when redeemed, may be worth more or less than their original cost. Past performance is no guarantee of future results. For performance information current to the most recent month‐end, please call toll‐free 888-559-7146 or visit our website, www.newagealphaetfs.com.

Important Risk Information Risk Disclosure The New Age Alpha Funds involve risks including the possible loss of principal and may not be suitable for all investors. There is no assurance that the fund will achieve its investment objectives. There is no assurance that the Advisor or index methodology will successfully identify and quantify the H‐Factor methodology risk or which stocks have low or high H‐Factor Scores.

Errors and additional rebalances carried out by the Advisor with respect to the Index may increase the costs and market exposure risk of the Fund. The Fund is not ‘actively’ managed and maintaining investments regardless of market condition could lower Fund performance. Markets and equity securities can decline in value sharply and unpredictably, and in times of severe disruptions you could lose your entire investment.

The Funds have a limited number of intermediaries that act as authorized participants, and none of these authorized participants are or will be obligated to engage in creation or redemption transactions. Cash equivalents are not guaranteed as to principal or interest, and the Fund could lose money through these investments. The Fund may effect creations and redemptions in cash or partially in cash, which may be less tax‐efficient than an investment in an ETF that distributes portfolio securities entirely in‐kind. In following its methodology, the Index may be concentrated in securities of issuers operating in a single industry and the Fund will concentrate its investments to approximately the same extent. Investments in fixed‐income instruments are subject to the possibility that interest rates could rise sharply, causing the value of the Fund’s holdings and share price to decline.

The Funds are subject to the risk that large‐ and mid-capitalization securities may underperform other segments of the equity market or the equity market as a whole. The Funds returns may be uncorrelated and not match the return of the benchmark index. The AVDR US LargeCap ESG ETF is non‐diversified, which means it invests a high percentage of its assets in a limited number of securities. The AVDR International Leading ETF contains international securities that may provide the opportunity for greater return but also have special risks associated with foreign investing including fluctuations in currency, government regulation, differences in accounting standards and liquidity.

The Funds seek to track quantitative strategy indexes and the Funds invest in securities comprising indexes created by proprietary models. The success of the Funds principal investment strategies depend on the effectiveness of the models. The value of a REIT can depend on the structure of and cash flow generated by the REIT. The Funds investment return on repurchase agreements will depend on the counterparty’s willingness and ability to perform its obligations. U.S. government securities are subject to the risks associated with fixed‐income and debt securities, particularly interest rate risk and credit risk.

ETF Trading Disclosure ETF shares are not redeemable with the issuing fund other than in large creation unit aggregations. Instead, investors must buy or sell ETF Shares in the secondary market. The NAV of the Funds shares are calculated each day the national securities exchanges are open for trading, normally 4:00 p.m. Eastern time. Shares are bought and sold at market price not NAV. Market Price returns are based upon the official closing price on the listing exchange at 4:00 p.m. ET when NAV is normally determined for most Funds, and do not represent the returns you would receive if you traded shares at other times.

An active secondary market for the Fund’s shares may not exist. Although the Fund’s shares will be listed on an exchange, it is possible that an active trading market may not develop or be maintained. There is no guarantee that distributions will be paid.

7362-NLD-11022021 | CC: NAA10143G | SKU: 10020

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You will leave newagealphaetfs.com when clicking any link below. The website you are accessing is created and maintained by another entity. We make no representation or warranty with respect to the information contained on the site or that it is appropriate in all jurisdictions or countries, or for use by all investors or counterparties. The products and services discussed at this site may not be appropriate for sale or use by all investors or counterparties. By providing this link, we are not providing you with investment advice or offering securities for sale to you. All persons and entities that access this site do so on their own initiative and are responsible for compliance with applicable local laws and regulations.

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