PRIVACY POLICY

1. Introduction. Lateral Investment Management LLC (“Lateral Investment Management”) respects your privacy and is committed to protecting your privacy. We recognize your need for appropriate protection and management of the personal information we learn about you while you visit our website, www.lateralinvestors.com. This privacy policy lets you know how we use and protect the information received through our website. The information that we receive depends on what you do during your visit to our website, what service(s) you request, and whether you decide to voluntarily give us your personal information.

2. Purpose and Scope. This privacy policy describes Lateral Investment Management’ current policies and practices with regard to personal information and non-identifying information collected by Lateral Investment Management through this website. This privacy policy is independent from Lateral Investment Management’ offline personal information collection practices. The term “personal information” refers to personally identifiable information about you, such as your name, e-mail address, mailing address, telephone and fax number, and any other information that is identified with you personally. This privacy policy describes how we use that information and how you can control our use of such information.

3. Effective Date. This privacy policy is effective as of November 1, 2013.

4. Users Outside of the United States. YOU EXPRESSLY CONSENT TO LATERAL INVESTMENT MANAGEMENT’S PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. YOUR PERSONAL INFORMATION MAY BE PROCESSED BY LATERAL INVESTMENT MANAGEMENT IN THE COUNTRY WHERE IT WAS COLLECTED AND IN THE UNITED STATES. UNITED STATES LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY. IF YOU REPRESENT AN ORGANIZATION, YOU WILL BE RESPONSIBLE TO ENSURE THAT EACH MEMBER OF YOUR ORGANIZATION (INCLUDING EMPLOYEES AND CONTRACTORS) ABOUT WHOM PERSONAL INFORMATION MAY BE PROVIDED TO LATERAL INVESTMENT MANAGEMENT HAS GIVEN HIS OR HER EXPRESS CONSENT TO LATERAL INVESTMENT MANAGEMENT’ PROCESSING OF SUCH PERSONAL INFORMATION.

5. Information Lateral Investment Management Gathers and Tracks. Lateral Investment Management collects one kind of information about visitors to this website: aggregated tracking data we collect when visitors interact with our website.

6. Use of Personal Information. The only personal information that Lateral Investment Management currently collects about you through this website is the information you voluntarily give us when you use this website, if any. Lateral Investment Management may use personal information to help us improve the content and functionality of our website, to better understand our visitors, investors, customers and markets, for marketing purposes, and to improve our products and services. Lateral Investment Management may use this personal information to contact you in the future to tell you about company news, products or services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. Similarly, we may provide “subscription” e-mail and mail services, either directly or through affiliates or corporate partners, which enable you to receive current news about Lateral Investment Management and its products and services. For all such services, we will provide an opportunity to “opt-out” of, or cancel, the subscription. If you do not wish to receive further information from us, you may also contact us at the email address listed in the “Feedback; Removal from Contact List” section below, and request to be removed from the contact list. Once we receive your request, we will use commercially reasonable efforts to remove your name from the contact list. If you wish to update any of your personal information, please contact us at that email address, and we will use commercially reasonable efforts to update your contact information accordingly. Please be aware, however, that even if we update your personal information in our contact list, or we remove such information, it may still be stored in other databases (including those kept for archival purposes) and may still be used to compile aggregated or demographic information for supply to third parties in accordance with this privacy policy. It is our policy to not provide information that identifies you personally to a third party without your permission, except to process or fulfill your requests, or as otherwise set forth in this privacy policy.

7. Disclosure of Your Personal Information. Lateral Investment Management may share some or all of your personal information collected through this website with our affiliates and corporate partners, who may use the personal information in accordance with this privacy policy. Lateral Investment Management, our affiliates, and our corporate partners may also share personal information collected through this website with third-party vendors who act for or on behalf of Lateral Investment Management or our affiliates and corporate partners (for example, companies that provide support services to us, including data processing services, or that help us market our products and services). These companies may need personal information about you in order to perform their functions. These companies are not authorized to use the personal information we share with them for any other purpose.

8. Use and Disclosure of Non-Identifying Information. We may collect information about our visitors, investors, customers, page views, traffic patterns, and related website information. This information helps us evaluate and improve our website and is sometimes useful for business, marketing, and investment analysis. We may share this information with third parties, but only in aggregate statistical form that includes no personally identifying information.

9. Security. We use reasonable security procedures to protect the personal information you share with us from unauthorized access, use or disclosure.

10. Privacy Protections for Minors. Our website is not directed at or intended for minors. Therefore, we do not wish to receive, nor do we knowingly collect personal information from minors via this website.

11. Other Disclosures. Although your privacy is very important to us, due to the existing legal, regulatory, technical, and security environment, we cannot fully ensure, nor do we represent or warrant, that your private communications and other personal information will not be disclosed to third parties. For example, we may be required to disclose your personal information to the government or other third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. Additionally, in the unlikely event we need to investigate or resolve possible problems or inquiries, we can (and you authorize us to) disclose any information about you (including personal information) to private entities, law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate. In all instances, we will cooperate fully when required by law to provide information regarding visitors.

12. Changes to this Privacy Policy. We reserve the right, in our sole discretion, to change, modify, update, add or remove any portion of this privacy policy in whole or in part, at any time. If this privacy policy is changed by us we will notify you by posting the date of the change in the current privacy policy on this website. Any changes in this privacy policy will be effective when such changes are posted to this website. Your continued use of this website after any changes to this privacy policy are posted will be considered acceptance of those changes. This privacy policy was last updated on November 1, 2013.

13. Feedback; Removal from Contact List. If you have a question or comment about this website, or wish to update your contact information or be removed from our contact list, please email us at remove@latvest.com.

14. Transfer of Information. Notwithstanding anything expressed or implied in this privacy policy, in connection with an assignment, sale, joint venture or other transfer or disposition of some or all of the assets, stock or operations of Lateral Investment Management or any affiliated entities, you agree that we can accordingly assign, sell, license, or transfer any information, including personal information, that you have provided to us to those third parties directly involved in such transfer or disposition.