Disclosures: Legal, Privacy, and Social Media

This communication is not an offer to sell, or solicitation of offers to buy, securities. Investments in a private fund can be made only pursuant to such fund’s subscription documents and private placement memorandum and after careful consideration of the risk factors set forth therein. Investments entail significant risks and are suitable only for certain investors as part of an overall diversified investment strategy and only for investors able to withstand a total loss of investment. Investment products offered by Partners for Growth are available only to investors who meet statutory qualifications as a “qualified client” under the SEC Rule 205-3 promulgated under the Investment Advisers Act of 1940. Past performance is not an indication of future results. In addition, there can be no assurance that current investments will be realized as projected. Actual realized returns will depend on, among other factors, future operating results, the value of assets and market conditions at the time of disposition, any related transaction costs, and the timing and manner of sale, all of which may differ from the assumptions on which the information contained herein is based. It should not be assumed that any investments described herein were or will be profitable. Forward-looking statements involve known and unknown risks, uncertainties and other factors, and accordingly, actual results may differ materially from those reflected or contemplated in such forward-looking statements. Prospective investors are cautioned not to place undue reliance on any forward-looking statements or examples and should bear in mind that past performance is not necessarily indicative of future results. None of Partners for Growth or any of its affiliates or principals nor any other individual or entity assumes any obligation to update any forward-looking statements as a result of new information, subsequent events or any other circumstances. All statements made herein speak only as of the date that they were originally made. Information included herein does not constitute investment advice and should not be viewed as a current or past recommendation buy or sell any securities or to adopt any investment strategy.

Social Media Disclosure

Partners for Growth Managers, LLC (“PFG” or the “Firm”) is a registered investment adviser. Investments in securities involve risk, including the potential loss of principal invested. Past performance is no guarantee of future results.

Information posted on any PFG social media site should not be construed as a recommendation by PFG or any of its affiliates as an offer to sell or solicitation to buy any securities or as personalized investment advice. Any activity taken by a PFG social media account shall not be construed as an endorsement of any services, products, individuals or views.

Any opinions expressed by PFG or its employees on the Firm’s social media accounts are as of the date of publication and are subject to change. Information that PFG posts on its social media sites is taken from sources that PFG believes to be reliable, but is not guaranteed by PFG as to accuracy or completeness.

PFG’s social media sites may contain links to articles or other information that are contained on a third party website. PFG does not endorse or accept responsibility for the content, or the use, of the web site. PFG assumes no liability for any inaccuracies, errors or omissions in or from any data or other information provided on the pages. PFG does not review content, advertisements, activities, or any other information posted on sites linked by third parties. Any opinions or statements posted by third parties are their own and may not be representative of the experience of others or indicative of future performance or success.

PFG maintains a presence on certain social media sites, currently LinkedIn and Twitter, but is not affiliated with these sites and has no control over how LinkedIn or Twitter or other third parties will use the information shared on the site. Please read and understand the privacy policies and terms of service for each social media site you participate in and understand how your information can be displayed and used throughout the site as well as other third-party sites that may be linked to by LinkedIn or Twitter.

Please ensure your activities are appropriate and relevant to the members of this community, and contribute positively to the content and conversation herein. PFG may remove any comments, photos, videos, discussion posts, wall posts and any other visitor or third party-posted content that contains confidential information, profanity, illegal material, spam or is otherwise deemed to be inappropriate. PFG reserves the right to ban from this site any commenters that violate these parameters.

Please avoid specific mention or discussions about investment advice, products, or specific securities. Visitors to this page must avoid posting positive reviews of their experiences with the adviser or its services as such testimonials are prohibited under state and federal securities laws and may not reflect the experience of all PFG clients and investors.

PRIVACY POLICY & GDPR COMPLIANCE

PFG respects your right to privacy. This Privacy policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Policy applies to all the personal information that we collect via our website (available at https://www.pfgrowth.com/), mobile applications, our services including our platforms, and our control solutions embedded in communication platforms and related support services (“Sites”). If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.

USE OF INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

To provide you with our information, products, or services that you request from us.
To provide you with notices about your account/subscription, including expiration and renewal notices (some of these notices may also go to your Administrator).
To carry out our obligations and enforce our rights arising from any contracts entered between you (or your company) and us, including for billing and collection.
To notify you about changes to the Sites we offer, or the services provide through the Site.
To allow you to participate in interactive features on our Sites.
To provide you with support services.
To estimate our audience size and usage patterns.
To store information about your preferences, allowing us to customize our Site according to your individual interests (e.g., to customize your personal trading workspace or specific trading functionality).
To improve your use of the Sites.
To recognize you when you return to our Sites.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

DATA SHARING

We do not share your personal information with unaffiliated third parties for their own direct marketing activities. We may share your personal information in the following circumstances:

To our subsidiaries and affiliates for business purposes.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
With brokers, futures commissions merchants, or other clearing firms with whom you grant permission to share information.
To fulfill the purpose for which you provide the data. For example, if you give us an e-mail address to use the “share via e-mail” feature of our Sites, we will transmit the contents of that e-mail and your e-mail address to the recipients.
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 a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
For any other purpose disclosed by us when you provide the information.
To enforce or apply our agreements with you, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, of our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
To any other person with your consent to the disclosure.

CONSENT AND LEGITIMATE USE

PFG will ensure the processing must relate to the legitimate interests of your business or a specified third party, providing that the interests or fundamental rights of the data subject do not override the business’ legitimate interest.

RIGHT TO ACCESS

Users can request confirmation as to whether personal information concerning them is being processed, where and for what purpose. Further, we shall provide a copy of the personal information, free of charge, in an electronic format.

RIGHT TO RECERTIFICATION

Users have the right to obtain and rectify inaccurate personal information.

RIGHT TO OBJECT

Users have the right to opt-out of marketing communications and processing of personal information at any time.

RIGHT TO BE FORGOTTEN

Users have the right to update or to delete the information we have collected. Whenever made possible, you can request deletion of your personal information directly within your account settings section.

DATA PORTABILITY

We allow you to receive the personal data concerning you, which we will provide in a ‘commonly used and machine-readable format’ and you have the right to transmit that data to another ‘controller’.

PRIVACY BY DESIGN

We implement appropriate technical and organizational measures, in an effective way, in order to meet the requirements of this policy and protect the rights of users. We hold and process only the data necessary for the completion of our duties (data minimization), as well as limiting the access to personal data to those needing to act out the processing.

INFORMATION WE OBTAIN FROM THIRD PARTIES

From time to time, we may receive personal information about you from third party sources (including your broker or futures commission merchant or an exchange), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

DISCLOSURE FOR LAW ENFORCEMENT

Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

RECORD OF PROCESSING

Your records of processing activities will be maintained to include purposes of the processing, categories involved and envisaged time limits. The records will be made available to a supervisory authority on request.

TRANSFER OF DATA

Your information, including personal information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer and process the data in the United States, including personal information.

Information. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

DATA ACCURACY

We will use best efforts to keep personal information collected or processed “accurate” and where necessary, kept up to date.

DATA SECURITY

The security and confidentiality of your personal information matters to us. We have implemented appropriate technical and organizational measures like encryption, access controls, intrusion detection systems, security event and an incident management platform designed to secure such information from loss or unauthorized access, use, alteration, and disclosure. We also review our security procedures periodically to consider appropriate new safeguards and updated solutions with reasonable efforts.

DATA RETENTION

PFG will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW TO CONTACT US

If you have any questions, a complaint, a request or wish to send us comments about this Privacy Policy, please contact us by using the form in the “Connect” portion of our website.