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Privacy Policy

We respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy describes the types of information we may collect from you or that you may provide to us when you visit the website https://pamlicocapital.com/ (our “Website”), and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies to any information that we collect on and in connection with your use of the Website, including any information in any communications with us or messages submitted by you to us using the contact information provided on our Website. This Policy does not apply to any other information that we collect by any means.

Please Note: If you are an individual investor in one of our Executive Funds, we also provide a separate, supplemental Privacy Policy Notice that is posted conspicuously on our secure investor website with additional information about how we collect, share, and protect your information. Please see our secure investor website for additional details and to review this additional Privacy Policy Notice, or contact us at contactus@pamlicocapital.com if you have any questions regarding or difficulty accessing the additional Privacy Policy Notice.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose not to use our Website. By accessing or using our Website, you agree to this Policy. This Policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes.

Information We Collect about You and How We Collect It

We may collect several types of information from and about users of our Website. This may include information by which users may be personally identified or information about a user that is maintained in personally-identifiable form (collectively “Personal Information”).

When you visit our Website, we (or our third party service providers acting on our behalf) may automatically collect your IP address or mobile device ID as you navigate through or interact with our Website, as described below in the section titled “Traffic, Usage and Computer/Device Information.” We may also collect any Personal Information you choose to give us if you decide to use the contact information on our Website to communicate with us by e-mail or telephone.

Traffic, Usage and Computer/Device Information

Additionally, as you navigate through and interact with our Website, we may automatically collect certain traffic data, usage information, and information about your computer equipment or mobile device, such as your browser and operating system, your wireless carrier, configuration data, clickstream analytics and your actions and patterns when you use our Website (collectively, “Technical Information”). The technologies we use for this automatic data collection may include cookies that are stored on the browser of your computer or mobile device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code. We collect this information to manage our content and improve users’ use of our Website; count and review the number of users of our Website and their usage patterns; to track key performance indicators such as pages accessed, frequency of access and other statistical information related to our Website (for example, recording the popularity of certain content and verifying system and server integrity); to identify the portion of users who accesses our Website via different web browsers; to recognize if user is a return user of our Website; to store information about a user’s visits; to remember a user’s preferences; and for similar purposes in connection with monitoring, maintaining and improving our Website.

LP Log-In Hosted by InvestorVision

We have engaged a third party service provider, InvestorVision Systems, LLC (“InvestorVision”), to host and operate the LP Log-In section of our Website. In connection with this portion of the Website, InvestorVision may collect and process additional forms of personal information on our behalf. InvestorVision describes its practices for collecting, using, maintaining, protecting and disclosing that information through its privacy policy (https://www.ssctech.com/about-us/privacy), which we encourage you to review for additional details.

How We Use Your Information

Generally

We may use the information we collect about you or that you provide to us, including Personal Information, to:

  • Provide our Website and its contents to you.
  • Provide, through our third party service provider InvestorVision, the LP Log-In platform linked through our Website.
  • Provide you with information you request from us as well as informational content and marketing materials regarding the Website and our business.
  • Provide you with support and to respond to your inquiries and customer service and support requests, including to investigate and address your concerns and to monitor and improve our responses.
  • Update and maintain subscription or e-mail lists.
  • Help maintain the safety, security, and integrity of our Website, databases and other technology assets and our business.
  • With respect to automatically-collected traffic, usage and device information, fulfill the purposes described in the section above titled “Traffic, Usage and Computer/Device Information” and the section below titled “Use of Google Analytics.”
  • Notify you about changes to our Website or this Policy.
  • Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes or obligations.
  • Enforce any contracts between you and us, or for the establishment, exercise or defense of legal claims.
  • Evaluate or conduct 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 information (including Personal Information) held by us is among the assets transferred.
  • Fulfill any other purpose for which you provide the information.
  • Serve any other purpose that we describe when you provide the information and for any other purpose with your consent.

Third-Party Websites

Our Website may include links to blogs, social media and third-party websites. These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any personal information. If you follow a link on our Website to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy. You may be able to use social media widgets (e.g., the Facebook “Like” button) while using our Website. These widgets will collect your IP Address and identify which page you are visiting on the Website and make your preference information available to third parties. The information collected by such widgets is controlled by third-party privacy policies.

Use and Disclosure of Aggregated or De-Identified Data

We may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user. We may use and disclose to third parties any such de-identified or aggregated data (including traffic and usage data that does not identify you personally) for any lawful purpose.

Use of Google Analytics

We use Google Analytics to track and analyze certain traffic and usage statistics regarding the use of our Website, such as the number of visitors to our Website, how visitors are navigating to our Website, visitors’ general geographic region information, how long individuals are visiting our Website, and information about the equipment individuals are using to access our Website (e.g., browser version and operating system). We use this traffic and usage information to gauge, internally, the effectiveness of our advertising efforts and to make improvements to our Website and our marketing and promotional efforts.

For more information, please review the following:

•Information about Google’s use of cookies: https://policies.google.com/technologies/cookies?hl=en-US

•Information about Google’s use of information from sites or apps that use Google’s services: www.policies.google.com/technologies/partner-sites

You can opt out of our use of certain Google Analytics features by updating the “Ads Settings” in your browser (www.adssettings.google.com/authenticated) or mobile device (www.support.google.com/ads/answer/1660762#mob), by enabling the Google Analytics Opt-out Browser Add-on in your browser (https://tools.google.com/dlpage/gaoptout), or by visiting the Network Advertising Initiative’s Consumer Opt-Out page (www.optout.networkadvertising.org/). Because those opt-out and preference control pages are specific to the individual browser used to visit it, and because those pages are not operated by us, we are unable to perform the opt-outs on your behalf.

Tracking and “Do Not Track”

Tracking involves the use of cookies, web beacons, or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions. Tracking information can be used to enable companies to make interest-based (behavioral) advertising available to users on multiple sites that they visit.

We do not currently collect Personal Information about your online activities over time and across third-party sites for tracking purposes. Our Website does not respond to any “DO NOT TRACK” signals sent by your browser or mobile device, and if your browser or mobile device sends a “do not track” signal to our Website, our Website will not treat you differently from users who do not send such signals.

Disclosure of Your Information

Generally

We may share Technical Information and all forms of your Personal Information with third parties in the following circumstances:

●We may disclose Personal Information to any contractors, service providers and other third parties who need to know such information to provide services to us that support our hosting, maintenance, operation and promotion of our Website and our permitted uses of Personal Information under this Policy. For example, we may use a third party cloud-hosting infrastructure service provider (e.g., Amazon Web Services, Google Cloud or Microsoft Azure) to store certain of your Personal Information securely, and we use Google Analytics in connection with our Website as described above in the section titled “Use of Google Analytics.”

●Additionally, if you are a user of our LP Log-In platform, we may transmit certain of your Personal Information to InvestorVision, the service provider that hosts and operates this platform on our behalf, in order to provide you access to and use of that platform. InvestorVision may process your information in accordance with its privacy policy (https://www.InvestorVisionsystems.com/privacy-policy/privacy-policy-for-business-data/), which we encourage you to review for additional details.

●We may disclose Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction, and any due diligence review with respect to any such proposed transaction.

●We may disclose Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements and to respond to any government or regulatory request or audit.

●We may disclose Personal Information to enforce or apply any legal agreements between us and you (such as our Terms of Use), or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of our customers or others.

We may also disclose all forms of your Personal Information for any purpose disclosed when the information is provided, and for any other purpose with your consent.

No Sales of Personal Information

We do not sell, and in the past 12 months we have not sold, any Personal Information to third parties.

SMS/Phone Numbers

Any phone numbers collected for SMS consent will not be shared for marketing purposes. If phone numbers were collected to send SMS, this consent will not be shared or disclosed to another company.

Your Rights and Choices

Generally

You have certain choices regarding the Personal Information you provide to us. You can set your browser to refuse all or some browser cookies. If you choose not to accept cookies, you may be unable to access certain parts or pages of our Website, or certain parts, pages or features of our Website may not function properly. To learn more about cookies and how to disallow or manage them, go to: http://www.allaboutcookies.org/.

If you do not wish to have your Personal Information used by us to contact you with informational or promotional content or messages, you may send us an e-mail stating your request to contactus@pamlicocapital.com or you can opt-out by simply clicking on the “Unsubscribe” or “Updating your e-mail preferences” link in the most recent e-mail you received from us and follow the prompts that appear. This opt-out does not apply to notifications about changes to our Website or this Policy.

Please also refer to the section above titled “Use of Google Analytics” for more information regarding opting out of certain Google Analytics features used on our Website.

Accessing and Correcting Your Information

You may send us an e-mail at contactus@pamlicocapital.com to request access to any Personal Information that you have provided to us, or to correct or delete that Personal Information. For security reasons, we may need to request specific information from you to help us confirm your identity before we correct, update or delete any Personal Information you provide us. Except as specifically described below in the section titled “California Residents: Requests to Know and Requests to Delete”:

•We will evaluate such requests on a case-by-case basis.
•In certain cases we cannot delete your Personal Information.
•We also may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California Residents: Requests to Know and Requests to Delete

If you are a California resident, the following additional information in this Section (“California Residents: Requests to Know and Requests to Delete”) and the next Section (“No Differential Treatment”) applies to you:

You may request that we disclose to you certain information about (and, if requested, to receive a portable copy of) the Personal Information about you that we have collected and used in the past 12 months (a “Request to Know”). You may also request that we delete the Personal Information about you that we have collected or that we maintain (a “Request to Delete”). You may submit a Request to Know or a Request to Delete by calling us at (704) 414-7150 or by sending us an e-mail stating your request to contactus@pamlicocapital.com. Regardless of the method you use to contact us, please indicate in your communication that you are making a Request to Know or a Request to Delete under the California Consumer Privacy Act of 2018 (the “CCPA”).

Upon receipt of your Request to Know or Request to Delete, as part of our security measures and as required by law we will take steps to verify your identity in order to confirm that the person making the request is actually the person about whom we have collected Personal Information (i.e., that the “you” making the request is actually you). We will verify your identity and confirm your request by asking you to confirm and verify certain Personal Information we already have on file for you. We may, for example, verify your request by asking you to (1) send an e-mail to contactus@pamlicocapital.com using the e-mail address we have on file for you, and (2) in that e-mail verifying at least one other item of Personal Information we have on file for you (which we will specify at the time we provide an initial response to your Request to Know or Request to Delete). In certain cases we may have only limited information about you, and it is possible we may have insufficient information about you to be able to reasonably verify your request in accordance with applicable law.

We will use reasonable endeavors to accommodate verifiable Requests to Know and Requests to Delete submitted in the manner described above within a reasonable timeframe after receiving such requests. In any event, we will comply with your Request to Know and Request to Delete to the extent and in the manner required by applicable law, but we may deny a request, in whole or in part, to the extent an exception applies under (or as otherwise permitted by) applicable law, including the CCPA. For example, we cannot and will not comply with a Request to Know or a Request to Delete if we cannot reasonably verify your identity in connection with your request.

You may also designate an authorized agent to make a Request to Know or Request to Delete on your behalf. To designate an authorized agent to act on your behalf, you or your authorized agent must submit proof that either (1) such agent has actually been authorized in writing to act on your behalf, or (2) you have provided the authorized agent with power of attorney under the applicable laws in your jurisdiction. You may submit such proof by e-mailing us at contactus@pamlicocapital.com. If a duly-designated authorized agent makes a Request to Know or Request to Delete on your behalf, we will still require you to verify your own identity using the process described above, unless an exception applies under applicable law in your jurisdiction (for example, you have submitted verifiable proof to us that you have provided the authorized agent with power of attorney).

No Differential Treatment

If you are a California resident and you choose to exercise any of the rights described in the section titled “California Residents: Requests to Know and Requests to Delete,” you will not receive differential treatment by us as a result (e.g., different prices or quality of services), except to the extent permitted by applicable law (including if those differences are reasonably related to the value of your Personal Information).

California “Shine The Light” Disclosure

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an e-mail to contactus@pamlicocapital.com or otherwise contact us using the information set forth below. Please mention that you are making a “California Shine the Light” inquiry. Please note, however, that we do not currently disclose any Personal Information to third parties for their direct marketing purposes.
Nevada Residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statues Chapter 603A may submit a request by contacting us at contactus@pamlicocapital.com. Please note, however, that we do not currently sell any Personal Information to third parties within the meaning of this statute.

Users Outside of the United States

Our Website is hosted in the United States and is provided from the United States. It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms. If you are accessing the Website from the European Union, Asia or any other region with laws governing personal data collection, use, and disclosure that differ from United States laws, you are expressly and knowingly consenting to the transfer of your Personal Information from your home country to the United States and other jurisdictions as indicated above, and to our use of such Personal Information in accordance with this Policy.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age, and no one under age 16 may provide any information to this Website. We do not knowingly collect Personal Information from children under age 16. If you are under 16 years of age, do not use or provide any information on this Website, make any purchases through this Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 16 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under age 16, please contact us at contactus@pamlicocapital.com.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.

The safety and security of your information also depends on you. When we have given you (or when you have chosen) a password for access to certain parts of our Website, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information over the Internet is not completely secure. Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

We post any changes we make to our Policy on this page. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Policy to check for any changes.

Contact Information

“We” are Pamlico Capital Management, LP, a North Carolina limited partnership headquartered in Charlotte, North Carolina. To ask questions or comment about this Policy and our privacy practices, you may contact us via e-mail at contactus@pamlicocapital.com, reach us via telephone at (704) 414-7150, or write to us by mail at 150 North College Street, Suite 2400, Charlotte, NC 28202.

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