Privacy

Fall Line Capital, LLC (“Fall Line”) is providing this notice on their behalf, and on behalf of the clients for which they manage assets, to explain their information collection practices and other important information. These measures reflect our commitment to maintaining the privacy of your confidential information. We are responsible for the protection of Personal Information entrusted to us.

Information We Collect
Fall Line collects information about actual and prospective investors or clients from the following sources:
a) Information received on applications and other forms including Investment fund subscription documents, questionnaires, and online registration forms of websites, whether received in writing or electronically. This information may include name, address, telephone number, e-mail address, tax identification number, income and other
financial data, investment experience, and possibly bank account information.

b) Information about transactions and account history with Fall Line, including initial and follow-on subscriptions, transfers and withdrawals or redemptions.

c) Information received from third parties such as solicitors, brokers, selling agents, advisers, product sponsors, exchanges, clearing firms and/or their respective service providers.

d) Information and data received when individuals visit a Fall Line website (such as internet protocol address, and browser software).

Disclosure and Use of Information Collected
Fall Line does not disclose personal or financial information collected from individual investors or clients, whether prospective, current, or former, without authorization or direction of persons from whom the information is collected, except as disclosed below. Fall Line may share information with affiliated or nonaffiliated service providers or other third parties:
a) for them to assist in providing services to Investors or Clients;

b) as may be required by regulatory authorities or law enforcement officials;

c) to the extent reasonably necessary to prevent fraud and unauthorized transactions;
or

d) as otherwise permitted by law.

Those receiving information under the circumstances described above are not permitted to use such information for any purpose other than to assist in the servicing of account(s), including helping to improve the services offered by them, or as permitted by law. Individuals choosing to withhold personal information requested by Fall Line may not be provided the services offered by them and/or may not be able to gain access to certain areas of websites hosted by them.

Confidentiality and Security
We implement technical, organizational, and physical security measures to ensure an appropriate level of security of the Personal Information we process.

Fall Line restricts access to nonpublic personal information about past, present or prospective individual investors and clients to those who need to know that information in order to assist them in providing services. Fall Line will maintain physical, electronic and procedural safeguards consistent with applicable U.S. and international standards to protect nonpublic personal information. These safeguards may include, but not be limited to, (i) implementation of network firewalls, dedicated guest-only Wi-Fi access and other network security protocols to prevent internal or external cyber intrusions or tampering, (ii) use of document shredding or third party secured disposal services; and (iii) restricted access to Fall Line offices (e.g., locks, periodic changes to access codes, electronic access cards, etc.).

Fall Line stores and uses the information collected in their roles as both “Controllers” (i.e., data users) and “Processors” (i.e., data storage) of that information. They will also utilize third parties as Processors to store and archive information collected (e.g., via cloud-based services offered by Dropbox, Google, and others), for which service
agreements are in place to address confidentiality, security and compliance with applicable privacy directives and laws.

International Privacy Laws
Individuals visiting websites hosted by any of Fall Line from outside the United States may be notified that they are sending information (including nonpublic personal information) to the United States where Fall Line’s principal offices are located, and that such information may then be transferred within the United States or back out of the United States to other countries outside of their country of residence, depending on the type of information and how it is stored. Such notices may also state that these countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in the website user’s country of residence; but that Fall Line’s collection, storage and use of their information will be governed by this privacy policy.

Use of Internet Cookies
Fall Line may use cookies on their websites to enhance a visitor’s experience on the site and to make decisions about ways to improve the website. A cookie (or browser cookie) is a small file placed on the hard drive of a computer. It contains information about preferences for using a website that have been established by someone using a browser on that computer. Unless adjustments to a browser’s settings are made so that it will refuse cookies, a website may issue cookies when a user accesses a website, including one sponsored by Fall Line. Cookies are used to store visitors’ preferences, collect information about how and how often visitors use the website, analyze user trends, and improve the website.

Fall Line may disclose the presence of a cookie to third parties to advertise their services. This may take the form of asking advertisers to display ads promoting their services on other websites based on the presence of a cookie. Fall Line may also contract with third-party advertising networks, including Google, that use cookies, or other tracking technologies to collect certain non-personal information about user activities on their websites and on third-party websites to provide users with targeted advertising based upon their interests. Fall Line may also use cookies delivered by third parties to track the performance of their advertisements.

If cookies are utilized, Fall Line will prompt individuals visiting their website(s), typically on the initial visit, to accept the use of cookies on the website. The visitor may refuse to accept the use of cookies when prompted on the site or may refuse to accept by activating the appropriate privacy settings on their browser. Refusal to accept cookies by a visitor to sites sponsored by Fall Line may prevent or limit access by such visitors to the entire website or the use of certain portions of the website.

Access to Information
Investors or clients, whether existing, prior, or prospective, and others, may contact Fall Line to request access to information they have collected about them. If they do so, Fall Line will first verify their identity before sharing any such information. Once verified, they will send a copy of the information collected electronically, unless a different method is specifically requested. If informed that any information collected is incorrect, Fall Line will take commercially reasonable steps to correct any errors.

Data that is no longer needed by Fall Line to provide services may be deleted (unless required to be retained by applicable books and records retention regulations or other laws).

Should you have any questions about our Privacy Policy, or to request (i) access to information collected about you, (2) correction of information we have about you, please contact us by email or by regular mail at:

Fall Line Capital
160 Bovet Rd, Suite 310
San Mateo, CA 94402
(650) 235-4032

info@fall-line-cap.com