Privacy Policy

Partner Fund Services, LLC (“PFS”) is committed to the privacy of your information. This Privacy Policy is meant to help you understand the information we collect, why we collect it, and how you can manage it. This Privacy Policy applies to our website at www.partnerfundservices.com and our investor portal, www.icx.efrontcloud.com/partnerfundservices (the “Site”) and any related products, services, communications, or apps (the “Services”). By using our Site, or by purchasing our Services, you are acknowledging that you have read, understood, and accept this Privacy Policy and our Terms of Use.

In this Privacy Policy, any use of the words “you,” “yours,” or similar expressions refers to users of this Site and our Services, as well as any other individuals whose information we collect and process. References to “we,” “us,” “our” or similar expressions refer to PFS.

This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after this Site, and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

1. Information We Collect

1.1 Information We Collect and Receive

For you to use our Site and Services, we need to collect and process certain types of information. Depending on your use of our Site and Services, this may include examples such as the following, which we have collected in the preceding twelve (12) months:

1. Information you provide to us by completing forms on our Site, account applications, subscription agreements, and other forms or related documentation: For example, your name, contact, and address information, and any other information you may provide.
2. Information you provide to us by contacting us: Any personal information you may provide to us when you email or call us, such as name, phone number, employer, and any other details you provide in your communications. PFS may also request your contact information for the purposes of having someone contact you for additional information, or in response to your request for information from us.
3. Information protected under federal or state laws such as a signature or bank account or other financial information.
4. Characteristics of protected classifications under federal or certain state laws, including gender, national origin, or marital status.
5. Commercial information, including records of products or Services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth.
6. Professional or employment-related information, including occupation, compensation, employer, and title.
7. Transaction information when you purchase Services from us: For example, if you make purchases with your credit card, we may use your credit card information for shipping, billing, and credit card validation purposes. We may also collect information from investor transactions.
8. Information we obtain from third party sources such as our affiliates, our service providers, an investor’s brokerage or financial advisory firm, financial advisor, or consultant or our affiliates’ service providers, such as from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud. From time to time, we may receive personal information about you from third party sources, but only where we have received assurances from these third parties that they have either received your consent or are otherwise legally permitted or required to disclose your personal information to us. We may use the information we receive from these third parties to provide Services to those third parties. We may also obtain information from public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities.
9. Login information, such as username and password, that you may use in connection with our Services.
10. Information about your activity through our Services, including your device information, such as your IP address, the type of device or browser you use, and your actions on the Site.
11. Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds.

We will only use your personal information to provide you with information or Services you have requested, or for the purposes set out in this Privacy Policy. Personal information does not include aggregated information from which individual identities have been removed.

1.2 Information from Children

PFS does not knowingly solicit or collect any personal information from anyone under eighteen (18) years of age, and children under 18 are not permitted to register for or use our Site or Services, including by subscribing to receive information from PFS. Parents can contact our customer service department to access, change, or delete the personal information that has been submitted by a child. If we become aware that a child under the age of 18 has provided us with personal information, we will delete it.

1.3 Cookies and Tracers

We may use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across the Site and different Services and devices. A cookie is a small file that is placed onto your device (e.g., computer, smartphone or other electronic device) that stores information when you visit a website. However, you can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising. Neither the Site nor the Services respond to Do Not Track signals.

PFS uses cookies and related technologies on our Site to help us recognize your device as a repeat visitor and enable certain website features and functionalities. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Cookies are typically classified as either “session cookies”, which do not stay on your device after you close your browser, or “persistent cookies” which will usually remain on your device until you delete them from your cache or they expire. Sometimes cookies are placed by us (“first-party cookies”) and sometimes they are placed by others (“third-party cookies”).

Specifically, we use cookies and other similar technologies on our Site to:

• Recognize you whenever you visit this Site (this speeds up your access to the Site as you do not have to log in each time);
• Support security and any authentication features on our Site;
• Obtain information about your preferences and use of our Site;
• Carry out research and statistical analysis to help improve our content, and Services, and to help us better understand our customers’ requirements;
• Improve the speed and performance of our Site and Services;
• Make your online experience more enjoyable and efficient; and
• Keep track of the items stored in your shopping basket and take you through the checkout process.

The cookies that we place on your device may include:

• Essential cookies: these cookies are essential for you to be able to navigate our Site and use its features. Without these cookies, the services you have asked for could not be provided.
• Performance cookies: these cookies collect information about how you use our Site, for example, which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous and is only used to improve how our Site works.
• Functionality cookies: these cookies allow our Site to remember the choices you make (such as your username, language, last action, and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.
• Marketing cookies: also known as advertising cookies, these cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our Site and help measure the effectiveness of the advertising campaign. This is sometimes referred to as online behavioral advertising. In some cases, our partners may use cookies to provide us with information about your interactions with their services. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Those third-party cookies would be subject to the third-party service’s policies.

You can opt-out of online behavioral advertising cookies and similar technologies by using the Digital Advertising Alliance’s Consumer Choice Tool available here, or if located in the European Union you can make your choices here. Please note you may continue to receive generic or contextual ads.

Managing Cookies

You can opt-out of all non-Essential cookies by clicking on the “Reject All” button on the cookie banner at the bottom of the Site homepage. In addition, your browser may give you the ability to control some types of cookies. If you want to customize the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted.

If you turn off any cookies, please be aware that you may lose some of the functionality of this Site. For more information about cookies and how to disable them please check the following resource: www.allaboutcookies.org

For more information about targeted advertisements and/or to learn how to opt out of advertising cookies, please visit the below independent associations. You can visit these independent associations’ websites to opt out of all cookies served by their members. These independent websites are not sponsored by or affiliated with PFS.

• Network Advertising Initiative (NAI)
• Digital Advertising Alliance (DAA)
• European Interactive Digital Advertising Alliance (EDAA)
• Digital Advertising Alliance of Canada (DAAC)

When opting out, a cookie will be set to let advertisers know not to use your data for targeted advertising purposes. You will still see advertisements, but they will not be tailored to your interests. If you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt-out each browser or device that you use.

Consent to Use Cookies: The first time you visit our Site, a cookie notice is displayed describing our use of cookies and linking to this Privacy Policy. As described in that notice, the cookie choices you make the first time you visit our Site will be used for your future use of the Site.

2. How We Use Information

PFS may use the personal information we collect for the following purposes:

1. To deliver our Services, including maintaining or servicing accounts, providing investor relations services, processing subscriptions and withdrawals, providing updates on a fund’s performance, providing tax reporting, and other operational matters, and verifying information;
2. To allow you to log into and access your account;
3. To provide customer service and our support services;
4. To process any financial transactions you make while registering for or using our Services, including using bank account details to remit funds and process distributions;
5. To keep your information secure such as by detecting security incidents, and to be able to verify your identity and contact information, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks;
6. To alert you about product updates, special offers, updated information, and other news and services from PFS;
7. To ensure our Site and Services are relevant to you and your interests;
8. To help us create and publish content most relevant to you; and
9. To contact you in response to sign up forms or requests.

3. How Information May Be Shared

PFS does not sell or rent any of your personal information, and we do not share your personal information publicly without your consent. However, we may disclose your information to certain trusted third-party services to help us provide, improve, promote, or protect our Services. For example, we may use data storage vendors or partner with other companies to process your payments or to store your personal information when necessary to support delivery of our Services and respond to customer service requests. Whenever we share data with third-party services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information to at least the same standards we do.

We also reserve the right to disclose personal information (including sensitive information) when it is reasonably necessary to conduct our business, protect PFS’s legal rights and property, and to comply with the law or orders. Otherwise, your personal information is not shared with any individual or other organization.

4. Protection of your Personal Information

We take the security of your personal information seriously and follow industry-standard practices to protect the data we collect and process. PFS has therefore put in place commercially reasonable physical, electronic, and managerial procedures designed to safeguard and secure the personal information that PFS collects. Access to personal information will be restricted to our authorized personnel who require the information to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties.

Remember, the safety and security of your information also depends on you. Where you have chosen, or where we have given you a username and password for access to certain parts of the Site or Services, you are responsible for keeping your login credentials confidential. No method of transmission over the internet or electronic storage is completely secure, so PFS cannot guarantee its absolute security.

5. Data Transfers

PFS’ Site and Services are tailored for, and targeted to, users in the United States of America (“US”). Because PFS is a US-based company, your information may be collected and processed in the US. Additionally, as part of the Services offered to you through our Site, the information which we collect about you may be transferred to, and stored in, one or more countries other than where you currently reside. For example, this may occur if any of our servers or third-party service providers are located in a country other than yours. These countries may have different data protection laws that apply to personal information. However, if we transfer your information in this way, we will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Privacy Policy.

6. Email Notifications

We try to keep email communications to a minimum and give you the ability to opt-in/opt-out of any marketing communications we may send. For example, we may send you email relating to the Services we offer. You may also elect to receive certain marketing communications in accordance with your preferences, and from which you may opt-out at any time. You can always opt-out of receiving marketing emails from PFS (other than certain required communications, such as messages confirming orders, and notifying you of any privacy policy updates, and the like), by sending us an email at privacy_info@partnerfundservices.com stating your request. If we have sent you a promotional email or mobile device notification, you may follow the instructions, send us a return email or mobile device communication asking to be omitted from future optional notices.

7. Retention

We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. For example, we may retain your data for as long as you are a customer of ours and thereafter so we can comply with our legal obligations. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data, such that the data is not personally identifiable.

8. Questions, Comments, or Complaints

If you have questions or comments about this Privacy Policy, or if you are not completely satisfied with this Privacy Policy or its application by us, we invite you to convey your concerns or suggestions to us at privacy_info@partnerfundservices.com. If you have an applicable disability, you may also contact us at the above email address to request access to this Privacy Policy in an alternative format. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken to address your concern or implement the suggestion.

9. Updates and Changes to this Privacy Policy

This Privacy Policy is effective as of June 1, 2025. We may update this Privacy Policy from time to time. If we do, we’ll let you know about any material changes, either by notifying you on the Site or by sending you an email. Any updates to this Privacy Policy will not apply retroactively. If you keep using our Site or Services after a change, that means you accept this Policy.