PRIVACY POLICY

Consumer Growth Partners, LLC and its advisory affiliates and related persons (collectively the “Firm”) is committed to handling information regarding its investors responsibly and is committed to safeguarding your privacy online. New technologies have dramatically changed the way information of all kinds is gathered, used and stored, but the importance of preserving the security and confidentiality of investor information has remained a core value of the Firm. We recognize and respect the privacy expectations of each of our investors. We believe the confidentiality and protection of investor information is one of our fundamental responsibilities. Please read this Privacy Policy, which will advise you about how we protect your personal information, and about what choices you have concerning the use of that information. Please read this policy carefully. We may need to change this policy from time to time in order to address new issues and reflect changes on our site. We will post those changes here so that you will always know what information we gather, how we might use that information, and whether we will disclose that information to anyone.

If you have any questions regarding our privacy statement, please feel free to contact Sandy Kokoruda at skokoruda@consumergrowth.com

Collection and Disclosure of Investor Information

Investor information collected by or on behalf of the Firm is obtained directly from the investor or the investor’s professional advisors and generally comes from the following sources:

Subscription agreements, investor questionnaires, investor web forms, investment advisory agreements, investment management agreements, account applications, other required forms and agreements, correspondence, written or telephone contacts with investors regarding their accounts; orThird parties. The information we collect may include an investor’s name, address, social security or Employee Identification Number, assets, net worth, income, investments, beneficial interests, investment history and other personal financial data. In addition, we obtain information about investors’ interests in funds (such as capital account balances and percentage interests) from the funds themselves and their other service providers. We may disclose investor information to affiliated and non-affiliated third parties: As authorized by the investor;

As permitted by law, for example, to service providers who maintain or service customer accounts for the firm or to an investor’s broker or agent; or As required by law, for example, as part of a regulatory or similar filing with certain regulatory and/or governmental agencies.

The Firm only collects personally identifying information about any individual website user when the information is provided by such user. We may employ outside agents, meaning other companies or individuals to perform functions on our behalf, such as sending postal mail and email and other promotional activities, analyzing data, providing marketing assistance and providing customer service. These agents may have access to personal information needed to perform their functions, but may not use it for other purposes.

When you are on an area of the website and are asked for personal information, you are sharing that information with the Firm as well as our business partners and vendors providing hosting and other services for us. If you do not want your information to be shared, you can choose not to allow the transfer of your information by not using that particular service. These parties may set their own cookies. As we continue to develop our business, we might sell or buy businesses or assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the event that the Firm or substantially all of its assets are acquired, customer information will of course be one of the transferred assets.

IP Address and Browser Level Information

The Firm may track the number of visitors to our site according to the number of IP (internet protocol) addresses. In addition, we may track information about a user’s browser level for system administration purposes. However, we currently do not store any information about the IP addresses and browsers of visitors.

Cookies

A cookie is a data file that certain websites write to your computer’s hard drive when you visit such sites. A cookie file can contain information, such as a user identification code, that the site uses to track the pages you have visited. We use cookies to remember information customers give us so they don’t have to reenter it each time they visit the site and to track user traffic patterns throughout the Firm��€™s website. We use both session and permanent cookies. We use this data on an anonymous basis and we do not correlate this information with personal data of any user. Most website browsers automatically accept cookies, but you can change your browser settings to display a warning before accepting a cookie, or to refuse all cookies. However, if you choose to disable the receipt of cookies from our website, you may not be able to use certain features of the site.

Security of Your Information

Our site has certain security measures in place intended to protect against the loss, misuse, and alteration of the information under our control. This helps to maintain the confidentiality of your information. The policies and practices described herein apply to our investors regardless of whether the investor is a current or former investor. We strive to protect your personal information, however, we cannot ensure or warrant the security of any information you transmit to us.

Your Acceptance of These Terms

By visiting this web site, you consent to the terms of this Privacy Policy and to the collection and use of this information by the Firm.

You agree that the Firm may retain and use any personal information you have provided to us until you inform us that you do not agree with this Privacy Policy and agree that you will not use the website for a reasonable period of time thereafter, in accordance with the Firm’s data retention policies and/or practices. By using this site after we post any changes to this Privacy Policy, you agree to accept those changes. If you choose to visit this web site, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions of Use.

Contacting the Web Site

If you have any questions about this privacy statement, the practices of this site, or your interactions with this website, please feel free to contact us.

Consumer Growth Partners
445 Hamilton Ave.
Suite 1102, White Plains, NY 10601