Privacy Notice

Overview:

Lateral Investment Management, LLC together with its private funds, pooled vehicles, related or affiliated investment vehicles, and general partner entities (“Lateral” or “we”) are committed to protecting the privacy of visitors to our website (the “Site”). This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit the Site and how we use such information. This Privacy Policy does not address our privacy practices concerning any nonpublic personal information we collect as to our investors; we address those practices in separate notices sent to our investors or potential investors.

This Privacy Policy applies when you visit the Site. By using the Site, you accept this Privacy Policy, which may be updated by us at any time. If you do not agree to this Privacy Policy for any reason, please do not use the Site or share your personally identifiable information with us as discussed below. Please note that this Privacy Policy applies only to the Site and not to any other website that may be linked to it. 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.

If you have any questions or comments about this Privacy Policy, you can write to us at General Inquires ir@lateralim.com or by writing to 400 S. El Camino Real, Suite 1100, San Mateo, CA 94402. 

What Information Do We Collect?

In general, we may gather certain information from the Site visitors, such as the number and frequency of your visits, through server logs. This information may include the URL of the last and next website you visit, your browser and operating system, your IP address, how long you spend on the Site, and what pages you view there. We may use this information on an aggregate basis to improve the Site, provide visitors with customized services and information, and for other similar purposes. We may also use this information to understand better how our visitors use the Site and to research our visitors’ demographics, interests, and behavior.

We do not collect any personally identifiable information from you through the Site except as described below. Personally identifiable information is information that personally identifies you, such as your name, postal address, e-mail address, or credit card information (or other information that is associated by us with such above information).

We are not responsible for any other websites accessible from or linked to the Site, including their privacy policies or information collection practices. 

We encourage you to review those privacy policies on third party sites. Further, we do not control any cookies, web beacons, or other similar devices that may be placed on the Site by third parties.

Nonpublic Personal Information: 

In connection with the formation and ongoing activities of Lateral, we collect and maintain nonpublic personal information about our individual investors (including potential investors) from the following sources:

· Information we receive from investor subscription agreements, investor questionnaires or other forms that investors submit to us or contracts that they may enter into with us;

· Information related to an investor’s transactions with us, our affiliates or others; and

· Information obtained from meetings and telephone conversations with an investor.

We may disclose any of the information we collect, as described above, in connection with the activities of our investment funds to our affiliates, agents and nonaffiliated third parties, including:

· Financial service providers, such as broker-dealers, custodians, banks and others used to finance or facilitate transactions by or operations of our private funds or pooled vehicles; and

· Actual and potential portfolio companies, purchasers thereof and potential co- investors, and each of their respective advisors if requested in connection with an investment or disposition.

We may also disclose nonpublic personal information about an investor to other nonaffiliated third parties for everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations, or report to credit bureaus.

To protect investors’ personal information from unauthorized access and use, we use security measures that comply with federal law.  These measures include computer safeguards and secured files and buildings.

Additional Information We May Collect and Share:

We will collect any other personally identifiable information from you if you voluntarily provide it through the Site – such as by providing your e-mail address and other personal information to receive further information about us – and will use such personally identifiable information for the purpose of processing and responding to your inquiries and requests and to improve the Site and offerings.

We may share your non-personally identifiable information with others, as deemed necessary. Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data. We may use service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and e-mail and providing technical, analytical, and hosting functions for the Site. These companies and individuals may have access to your personally identifiable information we collect through the Site, as permitted by law and as needed to perform their functions, but may not use it for any other purpose. 

We will not otherwise share your personally identifiable information, except as required by law, requested by governmental entity (including regulatory bodies) or law enforcement authority, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose us to liability. We can (and you authorize us to) disclose any of your information in such circumstances.

As stated above, we intend to use only the strongest security methods to protect our investors and your information form unauthorized disclosure, however your use of the Site and providing us with personal information is done so at your own risk, as you acknowledge that unintentional and unintended security breaches are inherent risks on any website.

Changes to This Privacy Statement

We reserve the right to change our Privacy Statement from time to time as necessary, including due to changes in the law or to our data processing practices or investment activities.