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.


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. Personal information (also referred to as ‘personal data’) is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you.


This Privacy Policy is intended for:

  • Users of 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”); and
  • Prospective, current and former investors. 


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

  • Information collected via our Sites;
  • Information received in communications with you, such as conversations over the telephone, in voicemails, through written correspondence, via email or in the subscription materials or other forms; and
  • Information we collect relating to services we provide to you (“Services”), such as about your transactions with the Fund or its affiliates.


In some cases, it is mandatory for us to collect certain personal information in order to provide services to you or fulfill our contractual obligations to you. If you fail to provide such mandatory information, we may not be able to provide those services to you or perform the contract we have entered into with you.


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.


We use information that we collect about you or that you provide to us, including any personal information based on the following legal bases, where applicable, and for the following purposes:

Legal basis for processing Purpose
  • For any other purpose in accordance with applicable law.
Legitimate Interests
  • To notify you about changes to our Sites and Services based on our legitimate interests to notify you of our Services.
  • To allow you to participate in interactive features on our Sites based on our legitimate interests in your participation.
  • To provide you with support services.
  • To estimate our audience size and usage patterns based on our legitimate interests to know our audience base.
  • To store information about your preferences, allowing us to customize our Site according to your individual interests based on our legitimate interests, to improve the quality of the services we offer to you.
  • To improve your use of the Sites.
  • To recognize you when you return to our Sites.
  • To provide information collected via our website (https://www.pfgrowth.com/), mobile applications, platforms, and communication solutions.
  • PFG website uses Google Analytics. Collected data includes your IP address, browser and operating system details, internet service provider domain, global location, and cookie-based information, including content reviewed on our site. You may also visit Google’s opt-out options at https://tools.google.com/dlpage/gaoptout.
  • Cookies are employed to analyze website usage and enhance content, with cookies being small text files stored on your computer. You can typically control cookie settings through your web browser. For more information on managing preferences, visit www.allaboutcookies.org. Please note that if you choose not to accept cookies, certain features on our website may not be available to you.
Performance of a contract
  • To provide you with our information, 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.
Legal Obligations
  • To respond to law enforcement and other regulatory or government inquiries.

Where PFG relies on legitimate interests as the lawful basis of processing your personal information, we will only engage in such processing to the extent that our legitimate interest is not overridden by your interests or fundamental rights or freedoms.


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 email 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 clients 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, in accordance with applicable law.


In accordance with applicable data protection law, users may have the following rights with respect to their personal information:

  • 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 rectification: Users have the right to obtain and rectify inaccurate personal information.
  • Right to object: Users have the right to object to the processing of personal information.
  • Right to restrict: Users have the right to restrict the processing of personal information in some cases.
  • Right to be forgotten: Users have the right to update or request that we delete the information we have collected.
  • Right to data portability: You may request to receive the personal information we have collected about you, which we will provide in a ‘commonly used and machine-readable format’ and you have the right to transmit that data to another entity.
  • Right to withdraw consent: Where processing is based on consent, users have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Accordingly, users may opt-out of marketing communications and related processing of personal information at any time.
  • Right to lodge a complaint with a supervisory authority: If you believe that PFG has not complied with the requirements of applicable data protection law with regard to your personal information, you may have the right to lodge a complaint with the data protection authority in your country of residence or work.


We implement appropriate data protection technical and organizational measures, such as data minimization measures and access controls, in order to meet the requirements of applicable law and protect the rights of users.


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.


Under certain circumstances, we may be required to disclose your personal information to third parties such as law enforcement or government regulators by law or in response to valid requests by public authorities (e.g., a court or a government agency).


We will maintain records of personal information processing activities, including purposes of the processing, categories of personal information processed, and envisaged time frames for processing. Categories of personal information may include name, contact information, transaction history and/or account balances. The records will be made available to the relevant supervisory authority upon request in accordance with applicable law.


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 from those in 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.


We comply with legal requirements for cross-border data protection, for instance by entering into appropriate safeguards for the transfer of data (such as the appropriate standard contractual clauses) and, where needed, supplementary safeguards to ensure your data is protected. For more information on the safeguards relating to personal information transfers outside of the EEA and/or UK, where applicable, please contact us using the contact details provided at the bottom of this Privacy Policy.


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


The security and confidentiality of your personal information matters to us. We have implemented appropriate technical and organizational measures, such as encryption, access controls, intrusion detection systems, and a security event and incident management platform, designed to secure personal 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.


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 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.


Partners for Growth Managers, LLC is the controller of your personal information. If you have any questions, a complaint, a request, or wish to send us comments about this Privacy Policy, please contact us at:


1751 Tiburon Blvd
Tiburon, California 94920

This Privacy Policy is intended to serve as a statement of the Fund’s privacy practices as required by law and is not meant to contradict or circumvent any of the provisions of the agreement of limited partnership of the Fund, which provisions shall be controlling as to the matters described therein. The Fund and its affiliates reserve the right to change the Fund’s privacy practices, including this Privacy Policy, at any time.

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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.

IFC logo

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.

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.