Privacy Policy

Effective Date:  August 28, 2025

Introduction

This privacy policy (“Privacy Policy”) describes the data privacy practices of 154 Partners Investment Management LLC (together with its affiliates, “154 Partners”) with respect to the person accessing (“you” or “your”) our website (154partners.com) and/or any related mobile site, applications, or features, as well as any other personal information obtained when you call, email, or otherwise interact with 154 Partners (collectively, the “Site”).

The Privacy Policy outlines how we collect, use, disclose, and retain personal identification obtained through your interactions with 154 Partners, including when you visit our Site, communicate with us, or invest in one of our funds. If you are an investor, your privacy rights will be governed by the subscription agreement of the respective 154 Partners’ affiliated vehicle. We are committed to protecting the privacy of those who entrust us with their personal information.

For additional information concerning personal data we collect and process in relation to our investors, including through the investor portal on this Site, please refer to our investor privacy notices, including those provided in the respective subscription agreement.

This Privacy Policy applies regardless of the medium or method through which you interact with us and regardless of the jurisdiction from which that interaction originates, except where a more specific privacy notice or exemption applies under applicable law.

By visiting the Site or otherwise interacting with us, you are accepting the practices described in this Privacy Policy stated herein and agree to be bound by our Terms of Use. We recommend that you review this Privacy Policy periodically, as it may be updated from time-to-time. If you do not agree to the policy, please do not use the Site.

Information Collection Overview

For the 12-month period prior to the date of this Privacy Policy, we explain here what categories of personal information we have collected in the usual course of business from users of the Site, where we got it from, and with whom we have shared it:

154 Partners will only use personal information to the extent it is necessary to deliver the Site. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in this Privacy Policy.

In Connection with Business Transfers: In the event that a division or all of 154 Partners is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.

To Comply with Laws: 154 Partners may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry, or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our portfolio companies, investors, employees or others, in accordance with or as authorized by law.

Cookies and Information We Collect by Automated Means

Like many websites, we analyze how visitors use our Site through what is known as “cookie” or similar tracking technology. A cookie is a small text file that is placed on your computer or other internet-connected device when you access the Site and allows us to recognize you each time you visit the Site. We may use cookies to:

1. allow you to use the Site without having to re-enter your user name and password;
2. enhance or personalize your Site usage;
3. monitor the Site usage;
4. manage the Site; and
5. improve the Site and our products and Site, including providing you with interest-based ads.

For more information on our advertising, see below: “Interest-Based Advertising.” If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Site, or that we may put on our Site in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.

We may also use web beacons or pixels on the Site, in our emails, and in our advertisements on other websites. These are tiny graphic images that are used to collect information about your visit to the Site, such as the pages you view and the features you use, as well as information about whether you open and/or act upon one of our emails or advertisements. We may also collect the URL of the website you visited immediately before coming to the Site. These tools help us analyze our Site visitors’ behavior and measure the effectiveness of the Site and our advertising. We may work with service providers that help us track, collect and analyze this information.

154 Partners may use third party web analytics service providers, such as Google Analytics, to evaluate use of the Site. The information we obtain through our Site may be disclosed to or collected directly by these services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ Site or apps” located at https://google.com/policies/privacy/partners.

We may combine the information we collect through cookies and web beacons with other information we have collected from you or information from other sources.

Interest-Based Advertising

We may use third-party advertising companies that use tracking technologies to serve any of our advertisements across the Internet. These companies may collect information about your visits to the Site and other websites and your interaction with any of our advertising and other communications. These advertising companies may serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Site and elsewhere over time. Other companies may also use such technology to advertise on our Site.

You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in.

If you would like more information about this practice and to know your choices concerning interest-based ads, visit: https://networkadvertising.org/choices/

In Canada, please visit: https://youradchoices.ca/choices/

In the EU, please visit: https://youronlinechoices.eu/

Retention of Personal Information

Personal information that we collect, access or process will be retained as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and 154 Partners, is retained for legitimate business purposes, or as required or authorized by law.

Opt-Out of Communications

At any time while accessing our Site, any user while online may decline participation in any activity that asks for information (e.g., survey email). Your choice not to participate will in no way affect your ability to use any other feature on the Site.

If you do not wish to receive communications from us, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the Site we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications.

For more information about interest-based advertising, including how you can manage advertising, please see above “Interest-Based Advertising.”

Security

The security of your information is important to us. 154 Partners employs measures designed to prevent the unauthorized release of or access to personal information. Please be advised, however, that although 154 Partners strives to create a secure and reliable Site for you, the confidentiality of any communication or material transmitted to or from 154 Partners via the Site or e-mail cannot be guaranteed. When disclosing any personal information, you should remain mindful of the fact that it is potentially accessible to the public and consequently, may be collected and used by others without your consent. 154 Partners has no responsibility or liability for the security of information transmitted via the Internet. Please consider this when you choose to submit information to us via this Site or otherwise.

Third Party Websites

The Site may provide links to other online services (including but not limited to social media platforms) for your convenience and information and such websites may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we strongly recommend that you review the privacy policy posted on any external site before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.

Capacity

You represent to 154 Partners that you have the authority to visit this Site according to the Terms of Use. The Site is not directed to children, nor do we knowingly collect any personal information from children under the age of thirteen (or such other age as may be directed under applicable law) online without verifiable parental consent. If you believe that a child has provided Personal Information to us, please contact us promptly and we will endeavor to investigate and delete such information from our systems.

Your Privacy Rights in Certain Jurisdictions

The law in many jurisdictions provides you with the following rights with respect to your personal information: 

• The right to know what personal information we have collected, used, disclosed, and sold about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third-parties to whom we disclose personal information, and the specific pieces of personal information 154 Partners has collected about you.
• The right to obtain a copy of personal information we have obtained about you free of charge, however we may charge a ‘reasonable fee’ if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
• The right to correct inaccurate personal information about you or update such information.
• The right to request that we delete any of your personal information we retain, subject to certain statutory exceptions, including, but not limited to, compliance with U.S., state, local, and non-U.S. laws, rules, and regulations.
• The right to opt-out of sale or the sharing of your personal information for cross-context behavioral or targeted advertising. For more information, see Interest-Based Advertising.
• If we deny your request, the right to appeal our decision. If you are not satisfied with our response, you can contact the applicable privacy regulator, see Right to Lodge Complaints.

California’s Shine the Light Law

In addition, and as set forth below, California Civil Code Section 1798.83, known as the “Shine the Light Law”, permits our Site users who are California residents to request and obtain a list of their personal information (if any) that we disclosed to third-parties  for their own direct advertising purposes for the 12-month period prior to the date of this Privacy Policy. We have not engaged in this activity, but please contact us if you have any questions. For the 12-month period prior to the date of this Privacy Policy, we have not sold or shared any personal information about our users. We do not use or disclose sensitive personal information, as defined in applicable laws, for any purposes other than those stated herein and permitted by applicable law.

Submitting Requests

If you are a resident of the relevant jurisdictions, you may submit your requests to opt out, correct, delete, and/or to know/obtain personal information we have collected about you by contacting us at hello@154partners.com or by calling +1 (347) 629-9140.

We will respond to your request in compliance with the requirements of your state’s applicable laws.

Verification of Youri Identity

Be sure to include your contact information when submitting such requests. When you exercise these rights and submit a request to us, we will need to verify your identity and may ask for your email address or other information needed for verification. We may verify requests by matching information provided in connection with your request to information contained in our records. We may also use a third-party verification provider to verify your identity. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received and may reject your request. We will endeavor to honor such requests unless such a request conflicts with certain lawful exemptions under applicable privacy law.

Appeal

You have the right to appeal a decision we have made regarding their requests by emailing us at hello@154partners.com or by calling +1 (347) 629-9140.

Non-Discrimination

If you make a request under your state privacy law, we will not discriminate against you in any way. For example, we will not deny you service, suggesting that you will receive (or charging) different rates for services, or provide you with or suggest that you will receive a different level or quality of services.

Authorized Agents

You may permit an authorized agent to submit a request to know or to delete your personal information. If we receive a request on your behalf, we will ask you to give us proof that you gave that person written permission to make a request for you. If you do not provide us with written proof, we will deny their request so that we can protect your personal information. We may verify such authorized person’s identity using the procedures mentioned in Verification of Your Identity.

Automated Decision-Making

We generally do not use automated decision-making technology, as that term is defined by applicable privacy laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.

Visitor from Outside the United States—Cross-Border Transfer

The Site is hosted in the United States. If you are visiting the Site from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Site and/or providing personal information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.

Right to Lodge Complaints

We are transparent about the ways in which we collect and use personal information and welcome your questions and concerns. If you have any concerns or complaints about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns.

Changes to This Privacy Policy

We reserve the right, in our sole discretion, to amend, revise, or supplement this Privacy Policy at any time. If we decide to make changes, the revised Privacy Policy will be posted on this page with a new “Last Updated” date and will become effective upon posting, unless indicated otherwise.

We encourage you to review this Privacy Policy regularly. Your continued access or use of this Site after any changes to this Privacy Policy means that you accept such amendments, revisions, or supplements. If you object to any of the changes to this Privacy Policy, please discontinue accessing and using this Site.

How to Contact Us

If you have questions or concerns about this Privacy Policy or how we collect and use the information of our users or to request a copy of this Privacy Notice in another format, you can contact at hello@154partners.com or by calling +1 (347) 629-9140. If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.