February 2020

This Privacy Policy is provided to you by Invest5 by Gotham Funds and describes how Invest5 collects, stores, uses and shares personal information that is provided on our Internet Website located at www.Invest5.com ("Website") from visitors to the \Website, including the information submission and registration features included on the Website. Unless otherwise indicated, this Privacy Policy only applies to personal information collected through Invest5.com. Please read the entire Privacy Policy carefully to understand how we use and protect your information. If you do not agree with these policies and practices, you may choose not to access the Website, however, by accessing the Website, you agree to all of the terms of this Privacy Policy and to our Terms of Use linked here This Privacy Policy may change from time to time (see "Changes to the Privacy Policy" below). This Privacy Policy applies to the information we collect about you in connection with your use of the Website. This Privacy Policy does not reflect the privacy practices of any third-party website which may be linked to or referenced on the Website and we are not responsible for the security, privacy practices, or content of these other websites.

USERS UNDER THE AGE OF 18

The Website is not intended for access or use by individuals under the age of 18 and we do not knowingly collect, solicit or use any personal information from individuals under the age of 18. If you are under the age of 18, do not access, use or provide any information to us via our Website, including completing any online registration, or provide us with any information about yourself, including your name, address, telephone number, email address or any screen or user name you may use. If you believe that we might have any information from or about an individual under the age of 18, please contact us at [email protected]

USERS OUTSIDE THE UNITED STATES

The Website is not intended for access or use by individuals located outside the United States and we do not knowingly collect, solicit or use any personal information from individuals residing outside the United States. If you reside outside the United States, do not access, use or provide any information to us via our Website, including completing any online registration, or provide us with any information about yourself, including your name, address, telephone number, email address or any screen or user name you may use.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about you in connection with your access and use of the Website, such as (i) personal information provided by you, including your name, postal address, date of birth, social security number, e-mail address, user name, password, domain name, telephone number or any other information input as part of our online registration process, (ii) financial information such as bank account numbers, including debit card numbers and your debit card transactions, (iii) information regarding your use of the Website, including browsing activity, and (iii) information about the computing environment you use to access the Website. We collect this information either directly from you when provide it to us as part of the online registration process or automatically through a variety of technical and navigational features as you access the Website (including usage details, IP addresses and other information obtained through tracking technologies).

We may also use a third party to collect personal information on our behalf and combine that with other information collected from or about you. The use of information collected through these third parties is limited to the services performed on our behalf.

INFORMATION YOU PROVIDE TO US

The information we collect from you includes (i) information that you provide when completing the online registration process, (ii) information contained in direct or indirect correspondence (including e-mail addresses) with us and (iii) information gathered when you interact with our personnel for any purpose, including reporting a problem with or difficulty using the Website.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you use the Website, we may automatically collect, through cookies, web beacons or other tracking technologies certain information about your computing environment, browsing activity and patterns, including (i) details of your use of the Website, including which portions of the Website you access, usage patterns related to your access of the Website, information regarding referring websites or search engines, traffic data, location data, logs and other communication data and the resources that you access through the Website, and (ii) information about your internet connection, including, among other things, your IP address, operating system, browser software, hardware and geographical location. We do not collect personal information through these automatic data collection technologies, but we may tie this information to personal information about you that we collect from other sources or that you provide to us.

A cookie is a text file that’s stored on your computer that allows websites to recognize devices (but not you personally) and store certain information, such as user preferences. Cookies are used to recognize you and distinguish you from other users of our online services. This helps to provide you with a more personal experience when you access our Website. A web beacon, also known as a pixel tag or clear GIF, is similar in function to a cookie in that it has a unique identifier that tracks online movements of our users and informs us of what Website content is effective.

If you wish to disable cookies on your computer or other device, you may do so by modifying your web browser settings. Please note that declining or disabling cookies may hinder our Website’s performance and may not allow you to access all of our Website’s features and services. Please also note that we do not respond to browser "do not track" requests.

THIRD PARTY SERVICES

Invest5 uses Plaid Inc. ("Plaid") to gather your data from financial Institutions. By opening an Invest5 account you give Invest5 and Plaid the right, power and authority to act on your behalf to access and transmit your personal and financial information from your financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy (https://plaid.com/legal/).

Gotham Funds are a series of FundVantage Trust, a registered, open-ended series fund company which supervises the management, activities and affairs of the Gotham Funds and has approved contracts with various organizations, including BNY Mellon Investment Servicing who provides accounting, administration and custodial services to the Trust.

Shareholder accounts invested directly through Invest5 by Gotham Funds are held at the transfer agent, BNY Mellon Investment Servicing ("BNY Mellon"). By opening an Invest5 account you give Invest5 and BNY Mellon the right, power and authority to act on your behalf to access and transmit your personal and financial information. You agree to your personal and financial information being transferred, stored, and processed by BNY Mellon in accordance with the BNY Melon privacy policy (https://www.bnymellon.com/us/en/privacy-policy.html).

HOW WE USE A CUSTOMER’S INFORMATION

We may use information that we collect about you or that you provide to us, including any personal information (i) to provide you with information or services that you may request from us, (ii) to fulfill any other purpose for which you provide that information, (iii) to provide you with notices related to your use of the Website and marketing materials related to products and services we or our affiliates may provide, (iv) to verify your compliance with the Website’s terms and conditions of use and any other agreements governing your use of the Website, (v) to carry out our obligations and enforce our rights under any other contracts entered into between you and us or our affiliates, and as required by applicable law, (vi) to improve the Website (vii) in any other way we may describe when you provide the information or (viii) for any other purpose with your consent.

DISCLOSURE OF CUSTOMER INFORMATION

We may disclose aggregated information about the Website’s users, including you, and information that does not identify any particular user, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy (i) to our subsidiaries, professional advisors and affiliates, (ii) to contractors, service providers and other third parties we use to support our business, (iii) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as an ongoing concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about the Website users is among the assets transferred, (iv) to fulfill the purpose for which you provide it, (v) to our affiliates to market to you, (vi) for any other purpose disclosed by us when you provide the information or (vii) for any other purpose with your consent. To opt out of receiving marketing materials from our affiliates, please email us at [email protected]

We may also disclose your personal information (i) to ensure compliance with our obligations under applicable law or legal process, including disclosure to government agencies, other regulatory bodies and law enforcement officials (ii) to enforce or apply the terms of any contracts entered into between you and us or our affiliates or (iii) if we believe disclosure is necessary or appropriate to protect our rights, property or safety or those of others with whom we have a relationship.

We do not share your information with non-affiliates for them to market to you and we do not authorize these non-affiliates to disclose the information except as necessary to perform services on our behalf or to comply with any legal requirement or entity.

DATA SECURITY

We have implemented physical, electronic and procedural safeguards designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the Internet is not completely secure. The security of this information depends in part on the security of the computer you use to communicate with us, the security you use to protect User IDs and passwords, and the security provided by your internet access services provider. Despite the above measures, we cannot guarantee the security of your personal information transmitted through the Website. Any transmission of personal information is at your own risk.

CHANGES TO THE PRIVACY POLICY

We reserve the right to update this Privacy Policy periodically and without prior notice. Please refer to the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting the revised Policy on the Website. By continuing to use our Website following such changes, you will be deemed to have agreed to such changes.

CONTACT INFORMATION

To the extent permitted by applicable laws and/or regulatory requirements, you may request that the personal information we maintain about you be corrected, amended or deleted. Please contact us at [email protected] or toll free at 888-705-0545 to update information we have about you or with any questions concerning this Privacy Policy and our privacy practices.