Privacy Policy

This privacy policy (the “Privacy Policy”) describes the types of personal information 50T Holdings, LLC and its affiliates (collectively “50T”, “we”, “us”, or “our”) receives about you when you visit www.50tfunds.com (the “Website”) or otherwise interact with us, as well as what we do with it, how we protect it, and how you can contact us if you have a question or concern about the personal information we hold about you. Your visit to this Website and use of our investor login portal available via the Website (“Investor Portal”) and/or other ways that you may interact with us are subject to this Privacy Policy. By visiting this Website or otherwise providing your personal information to us, you acknowledge that your personal information will be processed in accordance with this Privacy Policy, which may be updated by us at any time. Any such updates will be posted here and will be effective upon posting. We encourage you to review the Privacy Policy each time you visit this Website.

Other than in relation to personal information processed through the Investor Portal, this Privacy Policy does not address our privacy practices concerning any personal information we collect concerning our investors or potential investors with respect to their participation as an investor in investment vehicles that we sponsor or manage; we address those practices in separate privacy notices provided to such individuals as required by applicable law. This Privacy Policy also does not apply to any other third-party website, including those that may be linked to in our Website. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

As used in this Privacy Policy, “personal information” refers to “personal information”, “personal data” and similar terms under applicable privacy laws.

If you have any questions or comments about this Privacy Policy, you can e-mail us at info@50tfunds.com or write to us at 50T Holdings 208 West 28th Street 2FL, New York, NY 10001.

Personal Information We Collect and How We Use It

We may collect (and may have collected in the past twelve (12) months) the following categories of personal information about you:

• Identifiers (e.g. Contact and Other Information). For example, contact information including your name, email address, phone number and city and state, if for example, you submit an inquiry via the “Contact Us” form in our Website. In such instances, we will use such information to maintain our business records, manage our relationship with you, communicate with you, and comply with applicable law.
• Internet or Other Electronic Network Activity Information (e.g. Device, Browser and Geolocation Information). For example, we collect your IP address and other website usage information via technologies like cookies, for the purpose of monitoring access to the Website, understanding how you (and others) are using the Website, to improve the Website’s usability and security, and other internal processes.
• Investor Information. If you are a 50T Investor and you choose to access the Investor Portal, we will also collect your email address and certain other information to provide you with log in credentials and to allow you to access the Investor Portal.
• Information included through automated means. Please see below the section ‘Cookies and Other Tracking Technologies’ for additional context.
• Other Information.

We may collect personal information from affiliates and third-party sources, which may include publicly available sources of information. Additionally, we may collect and retain a record of all communications with you, in accordance with applicable regulatory statutes. We may use your personal information for one or more of the following business purposes:

• to contact you and respond to your requests and inquiries;
• to perform services for you, including maintaining or servicing accounts and verifying information;
• to improve our Website and the services that we offer and notify you about changes to our services;
• or our legitimate business interests such as to operate, manage, develop and promote our business, sites and premises, to monitor access to the Website and to protect our business from fraud, money laundering and other financial or business crimes, and to screen, identify and evaluate candidates for job positions, including conducting background checks;
• to send you direct marketing in relation to our services and/or other activities such as events; and
• to comply with our legal and regulatory obligations and bring and defend legal and/or regulatory claims.

We may also use the information in other ways for which we provide specific notice at the time of collection.

You may opt-in to certain kinds of marketing, or all forms of marketing, at any time by contacting us, and you may unsubscribe to receiving marketing emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

Disclosing Your Personal Information

We do not disclose personal information we obtain about you through the website or other channels covered by this Privacy Notice, except as described in this Privacy Notice. We may disclose the personal information we collect to:

• our affiliates, including to facilitate services and perform functions on our behalf;
• third party service providers (for example, Web hosting and e-mail service providers and other IT service providers, providers of professional advisory services, including consultants, legal advisors and accountants and other third-party service providers);
• other partners and potential investors in 50T-related investment partnerships as necessary to effectuate or administer authorized transactions;
• transfer agents, portfolio investments, brokerage firms and the like, in connection with any investment or disposition;
• actual and potential portfolio companies and potential co-investors, and each of their respective advisors as necessary to effect or administer a contemplated or completed investment or disposition;
• government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions);
• other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena); and
• in connection with corporate business transactions, such as in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or any portion of our businesses, assets, or shares.

We may disclose anonymous or non-personally identifiable information to others, such as investors, for informational or promotional purposes. Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data.

Protection of Your Personal Information

The security of your information is important to us. We maintain operational measures, including physical, electronic and procedural protections designed to safeguard and secure our networks against unauthorized access to personal information we may collect through our Website, and have implemented policies designed to ensure that personal information we collect via our Website is used in compliance with this Privacy Policy. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. We will not be responsible or liable for any damages, losses, or causes of action arising out of or in connection with the disclosure of your personal information. You use our Website and send us such information at your own risk.

Data Retention

For each of the categories of personal information collected, 50T retains your personal information for as long as reasonably necessary to fulfil the purposes for which such personal information was collected and in compliance with applicable laws. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the Website services and otherwise operate our business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, regulatory, contractual, or other obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Cookies and Other Tracking Technologies

50T may use cookies and similar technologies (“cookies”) to support the operation of and maintain the Website and other digital offerings. A cookie is a small, sometimes encrypted data text file which a website stores on your computer’s hard drive and is read by websites that you visit. They can be used for various purposes, including to help users navigate websites efficiently, as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

How do we use Cookies?

When you use our Website, we may collect different types of usage information by automated means by different types of cookies, which are further described below. Through these technologies, we may also collect information about the website you were visiting before you came to our Website, and the website you visit after you leave our Website.

• Strictly necessary cookies: These cookies are essential to enable you to move around our Website and use its features, such as accessing secure areas. Without these cookies, the services on our Website you wish to access cannot be provided.
• Analytical/performance cookies: These cookies collect information about how you and other visitors use our Website, for instance, which pages you go to most often, and if you get error messages from web pages. We may use data from these cookies to help test designs and to ensure that a consistent look and feel is maintained on your visit. All information these cookies collect is aggregated and is used only to improve how a website works.
• Functionality cookies: These cookies allow our Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for, such as watching a video. Additionally, these cookies can be used to allow an optional service to function. The information these cookies collect may be anonymized and these cookies cannot track your browsing activity on other websites.
• Pixel tags: These are also known as a clear GIF or web beacons. These are invisible tags placed on certain pages of our Website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular device visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit.
• Tracking URLs: These are used to determine from which referring website our Website is accessed.
• Advertising/tracking cookies: These cookies allow our Website to collect data about your online activity to provide you with personalized and targeted advertising on the Website and across different websites and provide us with analytics to improve website functionality and experience. We may use Google Analytics, or similar tools to help us analyze and assess user interaction with the Website, including advertising, visitor tracking, personalization, site analytics and security services and the data may be disclosed to our vendors for these purposes.

In addition to the steps described below, you can opt-out of receiving targeted advertising from Network Advertisers by clicking the “Ad Options” icon on the advertisements or by going to www.networkadvertising.org. In addition, the Digital Advertising Alliance maintains a website where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).

Your choices

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies, and/or be notified when cookies are encountered. Tools from commercial browsers may also not be effective with regard to HTML5 cookies, or other similar technologies. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the Website.

You may exercise certain choices regarding the use of Google Analytics cookies by visiting this page, or downloading the Google Analytics Opt-out Browser Add-on.

We do not control any third-party cookies, web beacons or other similar devices that may have been placed in your browser by other websites you have visited and that remain in your browser when you visit our Website.

Do Not Track

We do not track visitors of our Website over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

Third Party Websites

Our Website contains links to websites controlled and maintained by third parties, such as social media networks. We provide these links solely as a convenience for you. These features are recognizable by their third-party brand or logo and may collect your IP address and set a cookie to enable the feature to work properly. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites is used. This Privacy Policy does not govern the use of information collected on such third-party websites.

Children’s Privacy

Our Website is not directed to individuals under the age of thirteen (13). 50T does not intentionally collect information from individuals we know are under 13. Anybody under 13 should not provide personal information through our Website.

Changes to This Privacy Policy

We reserve the right to modify, amend, add to, replace or remove this Privacy Policy at any time. Any changes we may make to this Privacy Policy in the future will be posted on the Website and shall be effective upon posting. Accordingly, you are strongly encouraged to review our Privacy Policy each time you visit our Website.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact via the methods below:

Email us at the following email address: info@50tfunds.com outlining your request and be sure to include your contact information.

Additional Information for California Residents

This section is provided for purposes related to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and all implementing regulations thereto (collectively, the “CCPA”) and applies solely to the personal information that is subject to the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Privacy Policy.

We do not use or disclose sensitive personal information for purposes other than those specified under applicable law. We do not “sell” or “share” (as such terms are defined by the CCPA) any of the personal information we collect about you to third parties. We do not have actual knowledge that we “sell” or “share” (as such terms are defined by the CCPA) the personal information of individuals under sixteen (16) years of age.

Your Rights Under the CCPA

The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA.

• Right to Know. You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:

  • the categories of personal information we collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting such personal information;
  • the categories of third parties to whom we disclose the personal information;
  • the specific pieces of personal information we have collected about you; and
  • whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
• Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Request Deletion. You have the right to request that we delete your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit certain uses and disclosures of your sensitive personal information.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA, including by denying service, suggesting that you will receive (or charging) different rates for services or suggesting that you will receive (or providing to you) a different level or quality of service.

Submitting a CCPA Request

For any requests relating to the exercise of your rights under the CCPA or to access this notice in an alternative format, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below:

• Emailing us at info@50tfunds.com

You should generally expect to receive a response within 45 days of the date we receive your request. However, in some instances, we may require an additional 45 days to process your request in which case we will notify you and explain why the extension is necessary.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (e.g., the risk of responding to fraudulent or malicious requests), we may request further information to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf if you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

CALIFORNIA’S SHINE THE LIGHT LAW

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our Website users who are California residents to request and obtain from us a list of their personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not disclose any personal information to third parties for their direct marketing purposes.

Please contact info@50tfunds.com with any questions about our privacy policies.