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. The investment strategy includes the use of leverage which involves a substantial degree of risk and does not guarantee improved return. 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. Gross Internal rate of return (IRR) measures the annualized compounded return on for assets in PFG Fund Portfolios, taking into account timing of cashflows, and is not Net of Management Fees or Carried Interest due to the Manager.  The Net IRR for PFG Funds are presented for the Fund as a whole, net of applicable fees, expenses, carried interest, etc. An individual limited partner’s Net IRR may differ due to various reasons including timing of contributions and amount of management fees paid.  The variance in performance may be material. Limited partners should refer to their individual account statements for actual capital account balances and returns. The Net IRR shown was prepared by the Manager and has not been compiled, reviewed or audited by an independent accountant. The presented results are based on the Fund’s internal books and records and are subject to adjustment following the year-end audit. 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 website. 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, and refrain from posting reviews of your experiences with the adviser or its services.

PRIVACY POLICY & GDPR COMPLIANCE

 

Partners for Growth (“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. If you have any questions or concerns about our Privacy Policy, or our practices with regards to information we collect from or about you, please contact us at privacy@pfgrowth.com.

 

PFG collects and maintains certain non-public personal information from the following sources:

  • Information collected 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”). Your IP address, the type of browser and operating system you are using, the domain name of your internet service provider, and information collected via cookies. This includes information on the content you view on our website. We use cookies to understand usage of our website and improve our content. Cookies are bits of text that are placed on your computer’s hard drive.

     

    Generally, you can manage your cookie preferences through your web browser. Most web browsers will instruct you on how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please review the information made available through www.allaboutcookies.org.

  • PFG’s website uses Google Analytics to provide user interactions with the site, while IP addresses are used to provide and protect the security of the service, as well as share the user’s global location. Data is stored in an encoded format. For further detail please see Data privacy and security – Analytics Help (google.com) You may also visit Google’s opt-out options at htps://tools.google.com/dlpage/gaoptout. Please note that if you choose not to accept cookies, certain features on our website may not be available to you.
  • Information received in conversations over the telephone, in voicemails, through written correspondence, via email or in the subscription materials or other forms; and
  • Information relating to an investor’s transactions with the Fund or its affiliates.

 

If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Privacy Policy.

INFORMATION COLLECTED AND RECEIVED FROM OTHER SOURCES

We may collect and receive information about you from other sources. For example, you may engage with our content on social media networks like LinkedIn, or you may click on the LinkedIn icon on our website. As a result, we may collect or receive information about you.

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 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 (including, for example, to third party lenders under its credit facilities).
  • 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; and information related to trades entered by you, will be shared with the relevant exchanges.
  • 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.

NON-U.S. VISITORS

Any information we obtain about you in connection with your use on our website may be processed and stored in the United States or other countries.

LINKS TO THIRD PARTY WEBSITES

Our website contains links to third party sites and services whose privacy policies may be different than ours. We are not responsible for the privacy practices of third-party sites and services. You should consult with the third-party to better understand their privacy practices.

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 data.

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

DATA ACCURACY

We will keep personal data collected or processed “accurate” with best efforts, 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 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. Except as described above, PFG restricts access to non-public personal information about you to those of its affiliates, employees and agents who need to know the information to enable the Fund to provide services to its investors.

DATA RETENTION

PFG will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. PFG will apply the same policies that apply to current limited partners and clients to former limited partners or clients.

 

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 email, privacy@pfgrowth.com or call 415.912.5894.

This Privacy Policy was last updated on July 7, 2023.

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IDB Invest, a member of the IDB Group, is a multilateral development bank committed to promoting the economic development of its member countries in Latin America and the Caribbean through the private sector. IDB Invest finances sustainable companies and projects to achieve financial results and maximize economic, social, and environmental development in the region. With a portfolio of $16.3 billion in asset management and 347 clients in 25 countries, IDB Invest provides innovative financial solutions and advisory services that meet the needs of its clients in a variety of industries.

PFG leads a joint venture with IDB Invest that provides debt capital to emerging innovative tech companies across the region via our Latin America Growth Lending Fund. The initiative brings investment expertise into LAC from top notch global players in this field.

30+ Year Global Strategic Partner

SVB is a leading American bank providing products, services and strategic advice for businesses at every stage. They operate as a go-to commercial bank for start-ups and established corporations, offering venture funding, private banking & wealth advising. SVB is the largest lender to technology companies globally.

SVB has built its reputation as the financial partner of the innovation economy – helping individuals, investors and the world’s most innovative companies achieve extraordinary outcomes.
PFG and SVB have maintained an official strategic partnership since the late 1980’s. We have collaborated together as co-lenders and extended each other's ability to reach new markets and provide deeper capital to high-growth companies.

PFG and SVB have provided growth debt across the U.S. & Canada, Europe, Middle East, Asia, and Latin America, where we co-manage a Venture Debt Latin America Growth Lending Fund.

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IFC — a member of the World Bank Group — is the largest global development institution focused on the private sector in emerging markets. IFC works in more than 100 countries, using its capital, expertise, and influence to create markets and opportunities in developing countries, leveraging the power of the private sector to end extreme poverty and boost shared prosperity.

PFG and IFC are strategic partners where we extend IFC’s direct venture and VC funding, collaborating on fintech and tech lending across global growth markets.

10+ Year Global Strategic Partner

Aims to be the partner of choice for the private sector in Latin America and the Caribbean. They finance projects to advance clean energy, modernize agriculture, strengthen transportation systems and expand access to financing.