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Privacy Policy

Last modified – March 2025

Introduction

Onward Investors, LLC (“Onward”) is sensitive to the privacy concerns of its clients and investors. Onward respects your privacy and is committed to protecting it through compliance with this Website Privacy Policy (“Policy”).

This Policy describes the types of information Onward may collect from you or that you may provide when you visit the website www.onwardinvestors.com (the “Website”) and Onward’s practices for collecting, using, maintaining, protecting, and disclosing that information.

User Consent to Notice

By using this Website, you agree to the terms and conditions of this Policy. This Policy applies to the collection, use and disclosure of information that Onward collects:

  • On this Website; and
  • In email, text, and other electronic messages between Onward and you.

It does not apply to information collected by:

  • Onward, offline or through any other means, including on any other website operated by Onward or any third party (including Onward’s affiliates and subsidiaries); or
  • Any third party (including Onward’s affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on this Website. Linked websites may contain privacy provisions that are different from those provided in this Policy.

Please read this Policy carefully to understand Onward’s practices and procedures regarding your information and how Onward will treat it. If you do not agree with Onward’s policies and practices, do not use this Website. This Policy may change from time to time (see Changes to Website Privacy Policy). Your continued use of this Website after Onward makes changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

We also work with third-party providers who are contractually obligated to comply with Onward’s policies to protect information. However, if you visit or access one of these third-party provider sites or mobile apps, please review the online privacy practices of that site or mobile app to understand the specifics of how your online personal information may be collected, used and shared.

The United States Gramm-Leach-Bliley Act of 1999 (the “GLB Act”) excludes publicly available information (including publicly listed address, telephone numbers, or email addresses), and such publicly available information may be collected in the course of your use of this Website, as further explained below in the section titled: Information Collected About You and How Onward Collects It. Non-public personal information includes, but is not limited to, nonpublic personally identifiable financial information plus any list, description or grouping of Onward’s clients (each, an “Advisory Client” and collectively, “Advisory Clients”) and investors in private funds managed by Onward or its affiliates (each, an “Investor” and collectively, “Investors”) that is derived from nonpublic personally identifiable financial information. Non-public personal information may also include, without limitation, personal financial and account information, such as: names, addresses, contact details, or information that identifies a person as an Advisory Client or Investor; social security numbers or tax identification numbers; assets, net worth, income, or other information provided on a financial product application; bank account information; consumer report information; occupation; information acquired through an Internet “cookie” (as explained in the section titled: Information We Collect Through Automatic Data Collection Technologies); or other information regarding Advisory Clients or Investors not available to the public. Non-public personal information also may include advice provided by Onward to Advisory Clients, and data or analyses derived from Non-public personal information.

Information Collected About You and How Onward Collects It

Onward collects several types of information from and about users of this Website or if you contact Onward, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access this Website, and usage details.

Onward collects this information:

  • Directly from you when you provide it to Onward.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.

Information You Provide to Us.

The information Onward collects on or through this Website may include:

  • Information that you provide by filling in forms on this Website. This includes information provided at the time of requesting further services. Onward may also ask you for information when you report a problem with this Website.
  • Records and copies of your correspondence (including email addresses), if you contact Onward.

Information Onward Collects Through Automatic Data Collection Technologies.

As you navigate through and interact with this Website, Onward may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to this Website, including traffic data and other communication data and the resources that you access and use on this Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information Onward collects automatically helps it to improve this Website and to deliver a better and more personalized service, including by enabling Onward to:

  • Recognize you when you return to this Website.
  • Estimate Onward’s audience size and usage patterns.
  • Store information about your preferences, allowing Onward to customize this Website according to your individual interests.
  • Speed up your searches.

Cookie Notice

The technologies Onward uses for automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of this Website. Unless you have adjusted your browser setting so that it will refuse cookies, Onward’s system will issue cookies when you direct your browser to this Website.
  • Flash Cookies. Certain features of this Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on this Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How Onward Uses and Discloses Your Information.
  • Cookies Placed by Third Parties. You may also encounter cookies on this Website that are placed by third parties. This Cookie Notice does not apply to the cookies, applications, technologies, or websites that are owned and/or operated by third parties, or the practices of such third parties, even if they use or access Onward’s technology to store or collect information.

Onward does not collect personal information automatically, but it may tie this information to personal information about you that Onward collects from other sources or you provide to Onward.

How Onward Uses Your Information

Onward may use information that we collect about you or that you provide to Onward, including any personal information:

  • To present this Website and its contents to you.
  • To provide you with information, products, or services that you request from Onward.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out Onward’s obligations and enforce its rights arising from any contracts entered into between you and Onward, including for billing and collection.
  • To notify you about changes to this Website or any products or services Onward offers or provides through it.
  • In any other way Onward may describe when you provide the information.
  • For any other purpose with your consent.

Onward may also use your information to contact you about services that Onward provides that may be of interest to you. If you do not want Onward to use your information in this way, please check the relevant box located on the form on which Onward collects your data (the registration form). For more information, see Choices About How Onward Uses and Discloses Your Information.

Disclosure of Your Information

Onward may disclose aggregated information about Onward’s users, and information that does not identify any individual, without restriction.

Onward may disclose personal information that it collects or you provide as described in this Policy:

  • To Onward’s subsidiaries and affiliates.
  • To contractors, service providers, and other third parties Onward uses to support its business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which Onward discloses it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Onward’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Onward about users of this Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by Onward when you provide the information.
  • With your consent.

Onward may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply Onward’s investor agreements and other agreements, including for billing and collection purposes.
  • If Onward believes disclosure is necessary or appropriate to protect the rights, property, or safety of Onward, Onward’s customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How Onward Uses and Discloses Your Information

Onward strives to provide you with choices regarding the personal information you provide to Onward. Onward has created mechanisms to provide you with the following control over your information:

  • Automatic Data Collection Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Data Security

Onward has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Onward’s electronic systems are protected by security software, which software may include firewalls, anti-virus, anti-spam, malware and trojan protection, as well as reasonably up-to-date software patches and security ‘definition’ updates. Although Onward seeks to establish and maintain a security system that covers the use of the internet, its servers, its computers and other IT equipment (such as desktop computers, laptops, tablets and smartphones), please be aware that no security measures are perfect or impenetrable. The safety and security of your information also depends on you.

Unfortunately, the transmission of information via the internet is not completely secure. Although Onward does its best to protect your personal information, Onward cannot guarantee the security of your personal information transmitted to this Website. Any transmission of personal information is at your own risk. Onward is not responsible for circumvention of any privacy settings or security measures contained on this Website.

Children Under the Age of 16

This Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on this Website. Onward does not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If Onward learns that it has collected or received personal information from a child under 16 without verification of parental consent, Onward will delete that information. If you believe Onward might have any information from or about a child under 16, please contact Onward at: compliance@onwardinvestors.com.

California Residents

The California Privacy Rights Act (“CPRA”) gives California residents a number of rights regarding their personal information. These rights, and how to exercise them, are described in more detail below.

  • Delete data. You can ask Onward to erase or delete all or some of your personal data subject to certain limited exceptions, and that Onward directs any of its service providers to do the same.
  • Change or correct personal data. You can also ask Onward to change, update or fix your data in certain cases, particularly if it is inaccurate.
  • Object to, limit, or restrict use of personal data. You can ask Onward to stop using all or some of your personal data (e.g., if Onward has no legal right to keep using it) or to limit Onward’s use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • Right to access and/or take your personal data. You can ask Onward for a copy of your personal data in machine readable form.
  • The right not to be discriminated against. Onward will not discriminate against you in any manner for exercising any of the above rights with respect to your personal data.

In addition to these rights, you have the right to request the following information about your personal information that Onward has collected in the past 12 months:

Information about Data Collection.

  1. The categories of personal information that have been collected about you.
  2. The specific pieces of personal information that have been collected about you.
  3. The categories of sources from which Onward has collected personal information.
  4. The business or commercial purpose for which Onward has collected personal information.

Information about Data Disclosure.

  1. The categories of third parties with whom personal information has been disclosed.
  2. The categories of personal information that Onward has disclosed for a business purpose.

To exercise any of the above rights or to request any of the above information, email compliance@onwardinvestors.com and either explain what information you are requesting or describe what right you would like to exercise. Please include in your request sufficient information that allows Onward to reasonably verify that you are the person about whom Onward has collected personal information. An authorized agent may also submit requests asserting those rights on your behalf, subject to verification. Onward will not discriminate against you in any way based on your exercise of these rights. If you would like to appeal a Onward decision with a request to exercise any of these rights, please email Onward at compliance@onwardinvestors.com and explain the basis for your appeal.

In the last 12 months Onward has not sold or shared any personal information, including sensitive personal information.

California Notice at Collection

California law requires certain businesses to provide users with timely notice about the categories of personal information to be collected, the purposes for which the personal information is collected or used, and whether that information is sold or shared. Onward has described in fuller detail in this Policy the personal information that Onward collects, how Onward uses and discloses it, but provide the following additional disclosure:

  • Information collected by Onward. Onward has collected the following category of personal information within the past 12 months – internet or other similar network activity.
  • Purpose of collecting the information. Onward may collect the above information in order to provide and maintain this Website.
  • Sources of information. Onward obtains these categories of personal information directly and indirectly from your activity on https://www.onwardinvestors.com/. For example, website usage details may be collected automatically by cookies on this Website.
  • Purposes of disclosure. Onward discloses the personal information Onward collects to service providers with whom Onward contracts for one or more of the following business purposes: (1) to operate, de-bug and improve this Website and (2) to protect against malicious or fraudulent activity and prevent security incidents.
  • Retention of information. Onward does not store any historical activity from this Website, but Onward and its service providers may collect and retain some information about site usage and interactions. These aggregated identifiers may be retained for as long as necessary to continue to fulfill the business purpose for which the information was collected, or until you request that this information be deleted.
  • Sensitive Personal Information. Onward does not collect sensitive personal information about you when you visit this Website, and thus Onward does not use or disclose your sensitive personal information.
  • Right to Opt Out of Sale/Sharing. Onward does not sell or share your personal information.

Residents of Virginia, Colorado, Connecticut, Oregon and Utah

Virginia, Colorado, Connecticut, Oregon, and Utah also have adopted privacy laws that give consumers certain rights, including the right to confirm whether controllers are processing the consumer’s personal data, the right to access that data, the right to obtain a copy of that data, the right to correct inaccuracies in that data, and the right to delete that data. Onward provides these rights to all consumers, regardless of where they reside. Please see above for information on how you can exercise these rights.

Additionally, these five states have adopted rights to opt out of: (1) targeted advertising; (2) the sale of personal data; and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. Onward does not engage in targeted advertising and does not sell or share your personal data. Onward does not profile consumers in furtherance of decisions that produce legal or similarly significant effects.

Residents of the European Union, European Economic Area, United Kingdom and Switzerland.

Onward will transfer personal data it collects about you to the United States, where Onward’s servers are located. Onward will only transfer data for the purposes outlined in this Policy. The United States may not be deemed to provide the same level of data protection as your home country. For transfers of personal information from the European Economic Area to the United States or United Kingdom, and from transfers from the United Kingdom to the United States, Onward may rely on the Standard Contractual Clauses (“SCCs”), as adopted by the European Commission on June 4, 2021, and as it may be amended from time to time. If General Data Protection Regulations (“GDPR”) adopted by the European Commission or the United Kingdom do not apply to an agreement you have with Onward, then the SCCs will not apply.

It is important that the personal information Onward holds about you is accurate and current. By law, you may have the right to request access to, correct, and erase the personal information Onward holds about you, or object to the processing of your personal information under certain circumstances. Please note that United States regulations may prohibit Onward from erasing your personal information. You may also have the right to request that Onward transfer your personal information to another party. If you want to review, verify, correct, or request erasure of your personal information, object to the processing of your personal information, or request that Onward transfer a copy of your personal information to another party, please contact Onward at compliance@onwardinvestors.com.

Onward may request specific information from you to help Onward confirm your identity and your right to access, and to provide you with the personal information that Onward holds about you or to make your requested changes. Applicable law may allow or require Onward to refuse to provide you with access to some or all of the personal information that Onward holds about you, or that Onward may have destroyed, erased, or made your personal information anonymous in accordance with Onward’s recordkeeping obligations and procedures. If Onward cannot provide you with access to your personal information, Onward will inform you of the reason(s) why, subject to any applicable legal or regulatory restrictions.

Period of Retention

Onward retains personal information in compliance with Onward’s obligations under applicable law and any applicable internal policies. Onward may destroy personal information without notice or liability.

Enforcement and Dispute Resolution

Onward commits to resolve complaints about your privacy and Onward’s collection or use of personal information. Any inquiries or complaints should first contact Onward at compliance@onwardinvestors.com.

Changes to Website Privacy Policy

It is Onward’s policy to post any changes it makes to the Policy on this page with a notice that the Policy has been updated on this Website’s home page. If Onward makes material changes to how its treats users’ personal information, Onward will notify you through a notice on this Website’s home page. The month in which the Policy was last revised is identified at the top of the page. You are responsible for ensuring Onward has an up-to-date active and deliverable email address for you, and for periodically visiting this Website and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and/or Onward’s privacy practices, contact Onward at: compliance@onwardinvestors.com.