Online Privacy Policy

The Firm’s policy is to respect the privacy of all information it receives from a user accessing the App and to protect the security and confidentiality of the nonpublic information we obtain during this process. Such information will be treated in accordance with the Firm’s Online Privacy Policy as set forth below:

Firm is committed to protecting the privacy of users of the App. We will use reasonable efforts to see that all information, identifying and otherwise, submitted to us by users, remains private and is used only for the purposes set forth herein. Furthermore, we believe that our online users have a right to know what information we collect when you visit our Website and App. This Online Privacy Policy outlines the types of information we gather about you, how we gather your information, how we use it, with whom we might share it, the means by which we keep it secure and the choices you have about the information you share with us.

What Information Do We Collect and How Do We Collect It?

In general, when you visit our Website or App, we do not collect personally identifiable information about you. When you request access to our App, you will be asked to supply information such as your name, e-mail address, phone number and certain information regarding your qualification status as an “accredited investor.”

How Do We Use the Information?

We may use your name, email address and phone number to send you information about funds and to determine your eligibility to access our password protected pages. The Firm does not share the collected information listed above with nonaffiliated third parties. In the event, however, that the Firm is sold, transferred or disposed of in accordance with legal proceedings, user information, including identifying information, may be transferred to such third party purchaser or transferee, and will be subject to such third party’s privacy policy.

Security

The Firm takes reasonable precautions to protect its clients’ personal information by hiring an internet hosting provider that maintains physical, electronic and procedural safeguards that either meet or exceed applicable law. Please note, however, that no transmission over the internet can be 100% secure. The Firm also works to protect user information offline. All of your information is housed in secure, access-restricted areas. Only employees who need the information to perform a specific function are granted access to personally identifiable information.

Use of Cookies

Cookies are small text files that are stored on a user’s hard drive after the user has visited and/or registered with an online website. This Website and App do not store long-term cookies, but rather uses session cookies which expire when the user closes the web browser.

Changes to the Online Privacy Policy

If we ever change the Online Privacy Policy, we will post that information here. If there is ever any material change to the information we gather and how it is used, we will notify you via the email address we have in your personal profile. We invite you to come back from time to time to review the policy.

REFERENCES TO PUBLICATIONS AND OTHER COMPANIES

References to any publication or any other company in the Website or App are for reference and informational purposes only and are not intended to suggest that any of such companies endorse, recommend or approve of the services, analysis or recommendations of the Firm or that the Firm endorses, recommends or approves the services or products of such companies. News stories reflect only the author's opinion and not necessarily that of the Firm.

LINKS TO THIRD PARTY WEBSITES

The Website and App may contain hyperlinks to websites operated by parties other than the Firm, which the Firm may not have been screened or reviewed and which may contain inaccurate, inappropriate or offensive material, products or services. The Firm does not control such websites, and the Firm assumes no responsibility or liability regarding the accuracy, reliability, legality or decency of such third-party websites, content, products or services. Such hyperlinks are provided for your convenience only. The Firm's inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.

MODIFICATION AND MONITORING OF WEBSITE AND APP

The Firm may, at its discretion, change, modify, add or remove portions of these Terms of Use at any time without notice to you. We suggest that you check these Terms of Use periodically for changes. If you use the Website or App after we post changes to these Terms of Use, you accept the changed Terms of Use. The Firm expressly reserves the right to monitor any and all use of the Website and App.

TERMINATION AND CANCELLATION

The Firm may modify or terminate the Website or App and terminate your access to either, without notice at any time and for any reason.

INDEMNITY

You agree, at your own expense, to indemnify, defend and hold harmless the Firm, its parents, subsidiaries and affiliates, and their officers, partners, managers, members, employees, agents, distributors and licensees, from and against any judgments, losses, deficiencies, damages, liabilities, costs, claims, demands, suits, and expenses (including, without limitation, reasonable attorneys' fees and expenses) incurred in, arising out of or in any way related to your breach of these Terms of Use or the Privacy Policy, your use of the Website, or any of your other acts or omissions.

JURISDICTIONAL ISSUES AND APPLICABLE LAW

These Terms of Use are governed by the laws of the State of Delaware, without regard to its choice of law provisions. You hereby consent to the exclusive and personal jurisdiction and venue of courts in Delaware in the United States which shall have exclusive jurisdiction over any and all disputes arising out of or relating to these Terms of Use, the use of the Website or App or any product or service related thereto. Use of the Website and App is unauthorized in any jurisdiction that does not give effect to all provisions of these terms and conditions, including without limitation this paragraph.

GENERAL

If any part of these Terms of Use is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision shall be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of these Terms of Use shall continue in effect.

By reviewing or using the information on the Website and App after accessing the Website and App, you represent and warrant that (a) you have the authority to enter into these Terms of Use and create a binding contractual obligation, (b) you understand and intend these Terms of Use to be the legal equivalent of a signed, written contract equally binding, and (c) you will use the information on the Website or App in a manner consistent with applicable laws and regulations in accordance with these Terms of Use, as the Firm may amend them online or otherwise from time to time. A printed version of these Terms of Use and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based on or relating to these Terms of Use to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

This Website and App may contain forward-looking statements on our current expectations and projections about future events. Statements that are predicative in nature, that depend upon or refer to future events or conditions or that include words such as “expects,” “anticipates,” “intends,” “plans,” “believes,” “estimates,” “thinks,” and similar expressions are forward-looking statements. These statements involve known and unknown risks, uncertainties and other factors that may cause our actual results and performance to be materially different from any future results or performance expressed or implied by these forward-looking statements. These factors include, among other things, those matters discussed as “Risk Factors,” in our materials, as well as (1) general economic and business conditions; (2) new governmental regulations and changes in, or the failure to comply with existing governmental regulation, (3) legislative proposals that impact our industry or the way we do business, (4) competition, and (5) our ability to attract and retain qualified personnel.

Although we believe that these statements are based upon reasonable assumptions, we can give no assurance that our goals will be achieved. Given these uncertainties, prospective clients are cautioned not to place undue reliance on these forward-looking statements. We assume no obligation to update or revise any forward-looking statements contained on this web site or provide reasons why actual results may differ.