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PEARonline Privacy Policy

PEARonline LLC and its affiliates (collectively, "PEARonline" or "we") provide an online service through which a group that operates in the private equity or venture capital industry, agent, or such group's agent (each, a "GP User") may maintain its limited partner ("LP") data and control distribution of its own investment-related communications. Our website, pearonline.com, as well as related sites that PEARonline provides (collectively, the "Site") has both a public portion and a private portion.

On the public portion of the Site, Site visitors may browse general information about PEARonline and its products and services, as well as review newsletters, blogs, press releases, and related information feeds that pertain to PEARonline and the investment community. On the public portion of the site, registration is optional.

On the private portion of the Site, a GP User identifies which LPs are participating in a specific investment and controls the documents that such LPs will be able to review. Each LP needs only one user name and password to access all of the documents for all of such LP's investments. GP Users can monitor which LPs have downloaded each document, as well as when each document was downloaded.

Our Privacy Commitment

At PEARonline, our GP Users’ and LPs’ information is important to us, and we are committed to maintaining the confidentiality of the information we receive. This privacy policy (the "Privacy Policy") governs the information that Site visitors (including GP Users and LPs) (collectively, "Visitors" or "you") provide to PEARonline or that we learn from your use of the Site and any services that PEARonline provides. This Privacy Policy describes the types of information we collect, how we use it, and under what circumstances, if any, that we might disclose it. By accepting the Privacy Policy and using the Site, you expressly consent to the terms and conditions of this Privacy Policy, as well as PEARonline's use and disclosure of your personal information as described in this Privacy Policy.

For additional information, please visit PEARonline's Terms and Conditions, which establishes the use, disclaimers, and limitations of liability governing the use of the Site; and PEARonline’s Cookie Policy which describes the cookies used on the Site. The Terms and Conditions are located at www.pearonline.com/client/info/terms. The Cookie Policy is located at https://www.pearonline.com/privacy-and-cookies/.

Information Collection and Use

PEARonline collects information from Visitors when: (a) they register on the Site, (b) a GP User enrolls an LP to receive information from the private portion of the Site, (b) an LP confirms such enrollment, or (c) the Visitor requests access to the PEARonline information service or signs up to receive product demonstrations or training. PEARonline will not give, sell, share or rent this information to others, except as disclosed in this Privacy Policy.

We always strive to remain in compliance with the requirements of COPPA (Children's Online Privacy Protection Act); we do not knowingly collect any information from anyone under 13 years of age. Our Site, products and services are all directed to people who are at least 18 years old or older.

Profile Information

As an LP or other Visitor, you may be asked to provide personal profile information, which may include your name, email address, mailing address, telephone number, security questions and responses, and/or other personal identification information (collectively "Personal Information"). We use this Personal Information to develop, administer, and manage our relationship with you including:

Rendering our services to you and otherwise communicating with you;

Verifying the accuracy of personal information we receive;

Improving our Site (we continually strive to improve our Site content and offerings based on the information and feedback that we receive from you);

Improving customer service (your information helps us to respond more effectively to and address your customer service requests and support needs); and

Protecting our rights or interests or the rights or interests of others including you and other PEARonline clients or partners as described elsewhere in this Privacy Policy.

While PEARonline does not generally share Personal Information with others for their marketing purposes unless or except as described here, we may share aggregate information derived from Personal Information. The shared aggregated information is not personally identifiable.

An LP may be removed from receiving information from the private portion of the Site only by each applicable GP User. In such event, the LP will continue to receive investment information from all other GP Users in whose investments the LP participates, as well as PEARonline's notices regarding scheduled maintenance on the Site. In all other cases, if at any time you would like to unsubscribe from receiving communications through the Site or from PEARonline, either we will include detailed unsubscribe instructions at the bottom of an email, or you may contact us at the email address and/or mailing address provided at the bottom of this Privacy Policy.

Web Site Traffic Information

Because of the way that internet communication standards work, when you arrive at or leave the Site, we automatically receive the web address of the site from which you came or to which you are going. We also collect information on which pages of our Site you visit, the type of browser you use and the times you access our Site. We use this information only to try to understand your preferences better and to manage the speed and response time of our own Site pages (i.e. load on our servers), so as to improve our service and your experience with PEARonline. We also use analytical tools, such as Google Analytics, to determine the effectiveness of our marketing.

Internet Address Information

We only use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use. Any such data will be stored for a limited period.

Use of Cookies

Cookies are small files of data that are provided by a website or service provider and that are transferred to, and reside on, your computer and allow us to recognize you if you return to the Site using the same computer and browser. We use cookies to compile aggregate data about site traffic and site interaction, so that we can offer better site experiences and tools in the future. We may also send a "session cookie" or a one-hour cookie to your computer if and when you log in to your PEARonline account by entering your e-mail address and password. These cookies allow us to recognize if you visit multiple pages during the same session, reducing the need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We may also use longer-lasting cookies to display some of the information that you may need to complete various forms on the Site to reduce the need to retype the information each time you log in to your PEARonline account.

Please refer to the PEARonline cookie policy located at https://www.pearonline.com/privacy-and-cookies for more information regarding how PEARonline uses cookies.

Customer Service Correspondence

If you send us correspondence, including e-mails and faxes, we may retain such information in the records of your account. We may also retain customer service correspondence and other correspondence from PEARonline to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of these terms and to otherwise protect PEARonline's legal interests and the interests of others. We may, over time, delete these records if permitted by law.

Sharing

Because we value your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act and the European General Data Protection Regulation. Accordingly, PEARonline will not sell, trade, rent, or otherwise transfer your Personal Information to others for their marketing purposes, without your consent. PEARonline may validate Personal Information you provide, or request additional information from third parties, to assist us in establishing and authenticating your account, and verifying the accuracy of the information that you provide. Information obtained from third parties and linked with your Personal Information is safeguarded by confidentiality agreements and to the extent required by law.

PEARonline may share LPs’ Personal Information with GP Users for investment-related purposes, including but not limited to SEC and other regulatory compliance. For example, we may provide logs and issue reports to GP Users regarding an LP's use of the private portion of the Site, such as when an LP has downloaded information from the private portion of the Site or has been sent an email by PEARonline.

In addition to the foregoing, we may share your information with trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others' rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

When we partner with another party to provide specific services, and you sign up for those services, we share only the contact information that is necessary for the third party to provide such services. Third parties are not authorized to use Personal Information except for the purpose of providing those services. Otherwise, and except as stated above, PEARonline will not share or give your Personal Information to others unless in the rare case that PEARonline believes it is necessary to cooperate with regulators or law enforcement authorities or similar legal requests including the protection of our rights or the rights of others. If you object to your Personal Information being transferred or used as described in this Privacy Policy, please do not register on or use this Site.

Viewing and Changing Your Personal Data

As part of our compliance with the California Online Privacy Protection Act and the European General Data Protection Regulation, all users of our Site may make any changes to their information at any time by logging into PEARonline, clicking on the Settings Tab, changing the necessary information and clicking the Update button at the bottom of the page.

Links

This Privacy Policy applies solely to information collected by PEARonline through the Site. Occasionally, at our discretion, we may include or offer third-party products or services on our Site. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Data Access and Security

We implement a variety of security measures to maintain the safety of your Personal Information when you enter, submit, or access your Personal Information. All data access is based on a need-to- know basis. Secure protected areas of the Site may allow visitors, using a unique username and password, to access account information and authorized content, depending on their entitlements and account setup.

All information that PEARonline transmits on the private portion of the site is transmitted via Secure Socket Layer (SSL) technology and will be only accessed by those authorized with special access rights to our systems, and who are required to keep the information confidential. Our employees are regularly notified and/or reminded about the importance we place on privacy, and the steps they should take to protect Personal Information.

Your Personal Information will be kept on file in order to enable visitors who have initially registered on our Site to access updated content and other information on our site.

We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that Personal Information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. For information on reporting an unauthorized transaction or more detail on how we secure your Personal Information, please email us at privacy@pearonline.com.

If PEARonline learns of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. You agree that PEARonline may communicate with you electronically for this purpose. PEARonline may post a notice on this Site if a security breach occurs. If this happens, you will need a web browser enabling you to view the PEARonline Site. PEARonline may also send you an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us at info@pearonline.com.

International Use

Please note that your Personal Information will be stored and processed in the United States and the United Kingdom and Ireland and that by using the Site, you expressly consent to the transfer and processing of your Personal Information in the United States, United Kingdom, Ireland, and elsewhere as PEARonline deems reasonably necessary to make the Site available to you. The laws on holding Personal Information in the United States may be less stringent than the laws of your country, but PEARonline strives to maintain the confidentiality and security of Personal Information of individuals who may be outside the United States.

Merger or Sale of PEARonline

If PEARonline should ever file for bankruptcy or have its assets sold to or merged with another entity, information PEARonline receives through your use of the Site is a PEARonline asset and may be transferred except to the extent the law may prohibit such transfers.

Notification of Changes

We may occasionally update this Privacy Policy. When we do, we will post those changes on this page and/or send you an email notifying you of any changes and/or revise the date of this Privacy Policy. We encourage you periodically to review this Privacy Policy to stay informed about how we are protecting the Personal Information we collect. Your continued use of this Site constitutes your agreement to this Privacy Policy and any updates.

Contacting PEARonline

If you have a privacy concern regarding PEARonline or this policy and if you cannot satisfactorily resolve it through the use of this Site you should then write to: privacy@pearonline.com. In the event that you are still unable to resolve your concerns, PEARonline is committed to cooperating to achieve a proper resolution of your privacy concerns.

Copyright Notice and Terms of Use

Permission to use documents (such as product information, press releases, fact sheets and FAQs) from this server is granted, provided that (1) the PEARonline copyright notice appears in all copies, (2) use of such documents from this server is for informational and noncommercial or personal use only and will not be copied or posted on any network computer or broadcast in any media, and (3) no modifications of any documents are made.

Use for any other purpose is expressly prohibited by law, and may result in severe civil and criminal penalties. Violators will be prosecuted to the maximum extent possible.

All information on this Site is provided on an as-is basis. PEARonline makes no warranties, express or implied, as to the accuracy and correctness of the information. In no event shall PEARonline be liable for any damages whatsoever resulting from the use of this information. PEARonline is a registered trademark of PEARonline LLC All other products are trademarks and registered trademarks of their respective companies.

The practices described in this Privacy Policy statement are current personal data protection policies and related terms. PEARonline reserves the right to modify this Privacy Policy at any time. We will promptly reflect any such modifications in a manner described above.

If you have any questions regarding this Privacy Policy, you may contact us at: privacy@pearonline.com

or

PEARonline LLC
Attn: CEO
PO Box 1128
Los Gatos, CA 95030

Effective Date: May 25, 2018

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