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Effective 1/23/2018

This Privacy Policy applies to our services available under the domain of (the “Site”).  We recognize that privacy is important to our users, so we design and operate our Site with the protection of your privacy in mind. This Privacy Policy outlines the types of information we may gather when you visit our Site or use our services, and some of the steps we take to safeguard it. Please read this Privacy Policy to learn more about how we protect, use and disclose your information. By visiting the Site, you agree to this Privacy Policy. If you do not agree, please do not use or access the Site.


We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about our investors from the following sources:

  • Information we receive on applications or other forms, including the information we collect on the Site, and

  • Information about investors’ transactions with us, our affiliates or others.


We do not disclose any non-public personal information about prospective, current or former investors to anyone, except as permitted by law. We may voluntarily disclose such non-public personal information to regulatory authorities in connection with our business or our affiliates (such as any of our funds).  We also share non-public personal information with certain service providers, to the extent permitted by law, and we require those service providers to keep the non-public information confidential.  For example, we may provide such information to prime brokers, attorneys, third-party marketing firms, fund administrators and auditors.

We restrict access to non-public personal information about our investors to employees and service providers who need to know that information to provide services to our clients and investors.

We maintain physical, electronic and procedural safeguards that comply with federal standards to guard investors’ personal information.

Collection of Information

In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our investors. This information may include the URL that you just came from, to which URL you go to next (in both cases, whether on the Site or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.

We also may use data collection devices such as “cookies” on certain pages of the Site to better understand how people interact with the Site. For example, they help analyze web page flow, measure effectiveness, and promote trust and safety. Cookies are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a cookie. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site.

Use and Disclosure of Information

We may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site’s content, layout and services. These uses improve the Site and better tailor it to meet your needs and provide you with a smooth, efficient, safe and customized experience while using the Site.

In providing our services, we may contract with third parties that are not our affiliates to perform services for us, and, if necessary, we may disclose information about you to them solely for the purpose of carrying out their assigned responsibilities. We require those third parties to treat your private information with the same degree of confidentiality that we do. 

We may also share information about you if we believe that disclosure is required by law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities. 

We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not described in this Privacy Policy. For example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Site. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.


Your information is stored on the servers used to host the Site located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access.

We do not guarantee, however, that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.


Persons under age 18 are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from those persons. 

Conditions Of Use

If you choose to visit the Site, your visit and any dispute over privacy are subject to this Privacy Policy, including limitations on damages and application of Oregon law. If you have any concerns about privacy, please send a thorough description to

Changes to this policy

We may amend this Privacy Policy any time by posting the amended terms on the Site. All amended terms are automatically effective 30 days after they are posted. Your continued use of the Site constitutes your agreement to this Privacy Policy and any changes to it. If we make any material changes that affect your information already stored in our database, we will post a prominent notice on the Site stating that this Privacy Policy has changed. If you do not agree with this Privacy Policy or any changes to it, please do not use or access the Site.

If you have any additional questions, please contact us any time at

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