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Privacy Policy

Last Updated: October 3, 2022

Gridline Holdings, LLC and its affiliates (collectively, “Gridline,” “we”, “us” or “our”) know that privacy is very important to you. We have created this privacy policy (the “Privacy Policy”) to describe what kinds of personal information we may obtain through:

Our website located at www.https://gridline.co (the “Site”);
Any other website, mobile application, or digital property that links to this Privacy Policy; and
When you interact with us in any other way.

By accessing or using the Site or any other website, web application, or digital property that links to this Privacy Policy (collectively, the “Digital Properties”), you may (i) access our proprietary interactive platform (the “Platform”); (ii) register with Gridline as a customer (“Customer”), open an account (“Customer Account”), and invest in Gridline alternative investment funds (“Gridline Funds”); or (iii) register with Gridline as an investment advisor (“RIA”), open an account (“RIA Account”), onboard your clients and investors (“RIA Clients”), and select and manage your RIA Clients’ investments in Gridline Funds (collectively, the “Services”). If you are under the age of 18, you may not use our Services.

Gridline provides investment advisory services to the Gridline Funds, with an investment strategy focused on private market alternative investments. If you invest (or have taken steps to invest) in Gridline Funds as our Customer, or through your RIA, please also review our Gramm-Leach Bliley Act (“GLBA”) Privacy Notice for a description of our processing and disclosure activities regarding the non-public personal information that we (i) collect from you as our Customer, or (ii) receive about you from your RIA, in our capacity as a financial institution subject to the GLBA.

By accepting this Privacy Policy, visiting our Digital Properties, or accessing or using any of the Services, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying Terms of Use, which together make up the Agreement. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use the Services. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

This Privacy Policy will help you understand the following:

I. The Information We Collect

We may collect or receive the following types of information from or about you, which may include personal information.We collect contact information through our Services, which may include your name, email address, phone number, business contact data (e.g., title, company name, office phone number and company email address), and any information you provide in messages to us (“Contact Information”). We use Contact Information for purposes such as starting an application to obtain a Customer Account or an RIA Account, providing you with information about the Services, responding to your inquiries, sending you email alerts (including marketing emails), or providing you with the Services. Customer Accounts: Our Customers include a variety of individuals and institutions that invest in Gridline Funds by registering for one or more Customer Accounts. Depending on the type of account (personal or institutional), we may require that you provide certain information in addition to Contact Information such as your date and country of birth, nationality, passport numbers (or numbers associated with other government issued identification), Social Security Number or Tax ID, education, gender, interests, photo, employment status, occupation, employer name and address, marital status, financial information such as bank account and payment card details, suitability information, income, revenue, and other sources of funds, net worth, trusted contact information, account balance, credit scores, tax information and other information about financial situation and risk preferences. We reserve the right to accept or decline any application(s) for Customer Accounts in our sole and absolute discretion.

Customer – Investment Agreements: If you decide to invest in a Gridline Fund, additional or updated information may be required, and you will be required to acknowledge certain disclosures and enter into various agreements with the Gridline Funds which may include, but are not limited to, operating agreements and subscription agreement(s) (collectively, “Investor Agreements”). Investor Agreements will be furnished to Customers for signature by Gridline. Gridline shall retain the executed Investor Agreement(s).

RIA Accounts: SEC registered investment advisors may register for an RIA Account. We may require that you provide information in addition to your Contact Information such as confirmation of your SEC registration, identity verification data, and other information. We reserve the right to accept or decline any application(s) for an RIA Account in our sole and absolute discretion. If your application is approved, you will be required to enter into certain agreements with Gridline.

RIA Client(s): RIAs are required to input Contact Information into their RIA Account regarding each RIA Client. Depending on the type of RIA Client (personal or institutional), RIAs will be required to provide certain additional information such as date and country of birth, nationality, passport numbers (or numbers associated with other government issued identification), Social Security Number or Tax ID, education, gender, interests, photo, employment status, occupation, employer name and address, marital status, financial information such as bank account and payment card details, suitability information, income, revenue, and other sources of funds, net worth, trusted contact information, account balance, credit scores, tax information and other information about financial situation and risk preferences.

RIA Client – Investment Agreements: RIAs may select one or more Gridline Funds for investment by an RIA Client, and use app.gridline.co to submit their investment interest (e.g., a completed and signed sub-agreement). Gridline may request additional or updated information regarding the RIA Client, and reserves the right to accept or decline any request to invest in any Gridline Funds. When an RIA Client is approved for investment, Gridline will prepare and provide to the RIA required Investor Agreement(s) for the selected Gridline Funds. Upon RIA’s approval, the Investor Agreement(s) will be furnished to RIA Clients for signature by Gridline. Gridline shall retain the executed Investor Agreement(s).

Investor Agreements and Fees: Investor Agreements are strictly between the Gridline Fund(s) and the Customer and/or RIA Client, as applicable. Gridline is not a party to any Investor Agreements and assumes no obligations, duties, or liabilities related to or arising from any Investor Agreement. Gridline may request that Customers and/or RIA Clients, as applicable, provide ACH transfer information or wiring instructions in connection with their investment. Applicable fees and payment terms are described, as applicable, in the Investor Agreements or the RIA Services Agreement.
When you access or use any of our Services, we use browser cookies, pixels, web server logs, web beacons, and similar technologies (collectively, “Tracking Technologies”) to automatically collect or receive certain standard technical information and other data (such as traffic data, location data, logs and other communications data) sent to us by your computer, mobile device, tablet, or any other device over time on our Digital Properties, and your online activity across third party websites, apps, and devices. We may also evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services.

When you access or use any of the Services, advertising companies, analytics networks and providers, and other third parties may also use Tracking Technologies to collect information about your online activities over time on our Digital Properties and across different websites, apps, online services, digital properties and devices.

The data we or third parties collect automatically may include personal information and/or statistical data that may not identify you personally; however, we or third parties may maintain, combine, or associate it with personal information collected in other ways or received from third parties. We and/or third parties use this information to (i) enhance the performance and functionality of our Services; (ii) personalize your experience with the Services, understand how you use the Services, maintain a persistent session, and improve and further develop our Services; and (iii) serve targeted and other advertising, and provide custom experiences, across other sites, apps, online services, digital properties and devices, measure how the ads perform, and for analytics purposes.

The Tracking Technologies used on the Services include the following, among others:

Cookies: Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. In addition to collecting information, we use cookies to help us authenticate users, provide content of interest to you, analyze which features you use most frequently, and measure and optimize advertising and promotional effectiveness. To do this, we may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. For information regarding your choices regarding Cookies, please see Section III of this Privacy Policy.

Local Storage Technologies: We may use local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

Web Beacons: We use Web beacons, also known as pixel tags or clear GIFs, to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

Third Party Sites: When access to the Services is made available to you through third-party sites, such as social media, please be aware that these other sites maintain their own policies regarding Tracking Technologies and the collection and use of information. You are responsible for reviewing those policies.To provide access to the Services while you are using an electronic device, we automatically collect geolocation information from your mobile device, your wireless carrier, or certain third-party service providers (“Geolocation Information”). Collection of such Geolocation Information occurs only when the Services are running on your mobile device. You may control the collection of Geolocation Information through the user settings on your device. You may decline to allow us to collect such Geolocation Information, in which case we may not be able to provide access to the Digital Properties or certain Services to you. Please be sure to manage your mobile device and privacy preferences on the Platform on an ongoing basis.
Service Providers: We may collect or receive your personal information from third party service providers such as credit bureaus and service providers (e.g., providers of Anti-Money Laundering (“AML”) or Know Your Customer (“KYC”) services).

Social Media/Third Party Websites: We may collect or receive your personal information when you visit, use, or access the Services from third-party websites. We will do so in accordance with the Terms of Use and privacy policies of the third-party websites and applicable law. This includes any social media pages we may have on third-party services such as Twitter and LinkedIn. For example, we may collect the information you shared on our social media pages through an application or form, which will have a hyperlink to this Privacy Policy. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about their visitors’ use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. This Privacy Policy does not cover personal information collected by such third-party sites. For more information on their privacy and security practices please review the privacy policies and Terms of Use on their respective websites.

Government and Public Sources: As permitted by applicable law, we may also collect or receive your personal information from publicly available government records, directories, and sources such as courts, tax authorities, government agencies, regulatory authorities, and law enforcement.

Inferences: We may collect or receive inferences, which are assumptions or extrapolations that have been drawn from your information to create a profile which may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Text Messaging Program: This information includes your name, mobile phone number, and texting preferences (opt-ins and opt-outs). We use this information to send you text messages and manage our text messaging program. Please note that your mobile phone carrier may collect data about your wireless device usage, and that its practices are governed by the provider’s own policies.

Data Providers: We may license or otherwise acquire demographic and other information from third party information services, data licensors, and data brokers.

Marketing and Advertising Partners: We may receive information from our marketing and advertising partners, such as joint marketing partners and event co-sponsors.We use third-party analytics services (such as Google Analytics) to evaluate your access and use of the Digital Properties and the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to device and internet usage. These third party analytics services use cookies and other Tracking Technologies to help analyze and provide us the data. By accessing or using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. The information used by such analytics services is generally at the aggregate level. Google and other services may associate such data with visitation information collected from our Digital Properties.

We may change these third-party analytics services from time to time. For more information on our analytics services, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services. If you have any questions, or to request a current list of our third-party analytics services, please contact us as set forth in Section XI.

II. Information Use and Sharing

We use and share your personal information as set forth below:
  • To onboard Customers, RIAs and RIA Clients, such as conducting ALM, KYC and other background diligence and identity verification;
  • To operate our business, provide the Services, and fulfill requests for other products and services;
  • To improve our Platform and the Services;
  • To deliver administrative notices, alerts, and other communications relevant to use of the Services;
  • For market research, project planning, and troubleshooting problems;
  • To third-party contractors and service providers that provide services to us in the operation of our business and providing the Services, such as technical support of our Digital Properties, servicing Customer Accounts and/or RIA Accounts, and providing services such as digital account service providers, custodial services, administrators, customer service organizations, IT and cloud service providers, among others;
  • To enforce our Terms of Use;
  • To disclose aggregated, anonymous, user statistics and other information to (i) affiliates, agents, business partners, and other third parties; (ii) describe the Services to current and prospective business partners; and (iii) other third parties for lawful purposes;
  • To receive assistance and services from our service providers, third-party advertising partners, and remarketers for marketing and advertising purposes, such as (i) direct marketing communications; (ii) interest-based advertising on the Digital Properties and other sites, apps, online services, digital properties and devices, and (iii) ad measurement and analytics;
  • To share some or all of your information with our parent company and affiliates;
  • As required by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • As we develop our businesses, we may be involved in a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event and we expect that your personal information will be part of the transferred assets;
  • To create anonymous, aggregated, or de-identified data from your personal information and other individuals whose personal information we collect, and use and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
  • To audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • To prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft; and
  • Otherwise with your consent.
We will take reasonable measures to require that any party receiving any of your personal information from us undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information.

III. Your Choices

Update Information: If the personal information we have for you changes, you may correct, update, or delete it by contacting us as set forth in Section XI of this Privacy Policy. Customers and RIAs may correct, update, or delete some of their personal information directly in their respective accounts. RIA Clients should contact their RIA to correct, update or delete their personal and other information. We will use commercially reasonable efforts to process all such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. Additionally, we will retain and use your information (or copies thereof) as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

Marketing Communications: You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing emails. Please note that you cannot opt out of receiving transactional e-mails. If you are part of our text messaging program, you can opt out of receiving marketing and non-transactional messages by texting “STOP” in response.

Cookie Management: Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies or other Tracking Technologies, the Services may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Advertising choices: You can limit use of your information for interest-based advertising by:
  • Browser settings. Blocking third-party cookies in your browser settings (above);
    Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block Tracking Technologies;- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:

  • Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
You will need to apply these opt-out settings on each device from which you wish to opt-out. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

IV. External Properties and Third Parties

Independent Third Parties: Certain Services offered through the Platform are provided by independent third parties. These services are not affiliated with Gridline, and do not make recommendations or offer investment, financial, legal or tax advice. If you would like additional information regarding these independent third parties, please contact us.

Our Privacy Policy: Unless explicitly stated otherwise, our Privacy Policy addresses only our use and disclosure of information we collect from and/or about you in your interactions with Gridline. If you disclose information to third parties, the use and disclosure restrictions contained in this Privacy Policy will not apply, as we do not control the privacy policies of such third parties, nor are we subject to them. For more information on the privacy practices of any third parties that you elect to use, please visit their respective privacy policies and terms of use for information relating to your use of their services.

External Properties: The Services may also contain links to other third-party websites or apps (“External Properties”). We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or External Properties to which we provide links. As such, we are not responsible for the content or the privacy policies of those External Properties. You should check the applicable third-party privacy policy and terms of use when visiting any External Properties.

V. Security

We follow commercially reasonable and generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. Please understand, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security regarding our The Services, please contact us.

VI. Children's Privacy

Our Services are only available to individuals aged 18 or older, and we do not knowingly collect personal information from any person under the age of 18. If an individual under the age of 18 has provided us with personal information , a parent or guardian of that child may contact us and request that such information be deleted, and we will endeavor to delete that information from our databases.

VII. Do Not Track

As discussed above, third parties such as advertising networks and analytics providers may collect information about your online activities over time and across different websites when you access or use the Services. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

VIII. Notice to California Residents

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via email at info@gridline.co.

IX. Notice to Nevada Residents

We do not sell your personal information as defined under Nevada law. Nonetheless, if you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us at info@gridline.co with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your Account.

X. Important Notice to Non-U.S. Residents

The Digital Properties and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us maybe transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to access or use the Services, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy, and you do so at your own risk.

XI. Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may update this Privacy Policy from time to time without notice to you. We will indicate at the top of this Privacy Policy when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing the Services after we change this Privacy Policy, you are deemed to have accepted such changes.

XII. Contacting Us

If you have any questions about our Privacy Policy or privacy practices, or if you would like to exercise your rights and choices, please contact us at:
  • Email: info@gridline.co
  • By phone: (470) 795-0282
  • Mail: 3340 Peachtree Rd NE #200, Atlanta, GA 30305
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Disclaimer
This site is operated by Gridline Holdings, LLC ("Gridline"). Gridline does not give investment advice, endorsement, analysis or recommendations with respect to any securities. All securities listed here are being offered by, and all information included on this site is the responsibility of, the applicable issuer of such securities. Gridline has not taken any steps to verify the adequacy, accuracy or completeness of any information. Neither Gridline nor any of its officers, directors, agents and employees makes any warranty, express or implied, of any kind whatsoever related to the adequacy, accuracy or completeness of any information on this site or the use of information on this site. By accessing this site and any pages thereof, you agree to be bound by the Terms of Service and Privacy Policy

Past performance is not indicative of future results. All securities involve risk and may result in significant losses. Investing in alternative investment funds is inherently risky and illiquid, involves a high degree of risk, and is suitable only for sophisticated and qualified investors. Investors must be able to afford the loss of their entire investment. Alternative investment funds should only be part of an investor’s overall investment portfolio. Further, the alternative investment fund portion of an investor’s portfolio should include a balanced portfolio of different alternative investments. Investments in alternative investment funds are speculative and involve a high degree of risk and those investors who cannot afford to lose their entire investment should not invest. Additionally, investors may receive illiquid and/or restricted securities that may be subject to holding period requirements and/or limited liquidity. Investments in Alternative investment funds are generally highly illiquid and those investors who cannot hold an investment for the long term should not invest.

Any specific alternative investments funds referenced on this site are included purely for illustrative purposes and selected based on name recognition. Such examples are only partial, and readers should not assume that the investments identified were or will be profitable or are representative of investments by the alternative investment funds identified on this site. There is no guarantee that any alternative investment fund will achieve the same exposure to, or quality of, investments held by any existing fund referenced on this site.

Nothing on this page shall constitute an offer to sell or a solicitation of an offer to buy an interest in any investment partnership or other security. Any offer to sell or solicitation of an offer to buy an interest in an investment partnership may be made only by way of the partnership's final definitive confidential disclosure document and other offering and governance documents of any given fund (collectively, “Offering Documents”). The information on this site is qualified in its entirety and limited by reference to such Offering Documents, and in the event of any inconsistency between this site and such Offering Documents, the Offering Documents shall control. In making an investment decision, investors must rely on their own examination of the offering and the terms of any offering. Investors should not construe the contents of this site as legal, tax, investment or other advice, or a recommendation to purchase or sell any particular security.

The information included in this site is based upon information reasonably available to Gridline. Furthermore, the information included in this site has been obtained from sources Gridline believes to be reliable; however, these sources cannot be guaranteed as to their accuracy or completeness. No representation, warranty or undertaking, express or implied, is given as to the accuracy or completeness of the information contained herein, and no liability is accepted for the accuracy or completeness of any such information. This site may contain certain “forward-looking statements,” which may be identified by the use of such words as “believe,” “expect,” “anticipate,” “should,” “planned,” “estimated,” “potential,” “outlook,” “forecast,” “plan” and other similar terms. All such forward-looking statements are conditional and are subject to various factors, including, without limitation, general and local economic conditions, changing levels of competition within certain industries and markets, changes in legislation or regulation, and other economic, competitive, governmental, regulatory and technological factors, any or all of which could cause actual results to differ materially from projected results.

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