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    <p>Pemberton Capital Advisors LLP or its affiliates and/or subsidiaries (collectively, “Pemberton”) may not be licensed or registered in a jurisdiction where it is not possible to provide investment advisory services to one or more types of
      investors, directly in a separately managed account or via a private fund. </p>
    <p>This website is directed only at investment professionals, professional clients, persons having professional experience of investing in unregulated schemes, high net worth companies, partnerships, associations or trusts and personnel of any of
      the foregoing having professional experience of investing in unregulated schemes (each within the meaning of the UK Financial Services and Markets Act 2000 (Financial Promotion) Order 2005, the Financial Services and Markets Act 2000 (Promotion
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      Regulation S under the U.S. Securities Act of 1933 (“Securities Act”), or the services of any Pemberton company. </p>
    <p>Access to the information contained in this website is restricted under applicable U.S. federal and state securities laws. The securities of any fund or compartment of a fund have not been and will not be registered with the U.S. Securities
      and Exchange Commission under the Securities Act or any state securities laws in the United States, and may not be offered or sold into, within the United States or to or for the account of any U.S. person except pursuant to an exemption from
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PRIVACY POLICY





PEMBERTON CAPITAL ADVISORS LLP WEBSITE PRIVACY POLICY



This privacy policy (“Privacy Policy“), together with our website terms of use
and any other documents referred to in it, set out the basis on which any
information from which you can be identified, such as your name, contact details
and ID data (“personal data“) Pemberton Capital Advisors LLP (“Pemberton Capital
Advisors“, “us“, “we” or “our“) collects from third parties (including its
clients and all visitors to the website https://pembertonam.com (the “Website“)
(“you“), or that you provide to us, will be processed by us. Pemberton Capital
Advisors is committed to ensuring that your privacy is protected, so please read
this Privacy Policy carefully to understand our views and practices regarding
your personal data and how we will treat it. By visiting and/or contacting us
through the Website (or otherwise engaging with us), you acknowledge that we may
collect, use and transfer your personal data as set out in this Privacy Policy.

For the purposes of the “Data Protection Legislation” (meaning any law
applicable from time to time relating to the processing of personal data and/or
privacy as the same may be re-enacted, applied, amended, superseded, repealed or
consolidated, including without limitation, the General Data Protection
Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC
Directive) Regulations 2003, in each case including any legally binding
regulations, directions and orders issued from time to time under or in
connection with any such law), the data controller is deemed to be Pemberton
Capital Advisors LLP of 52 Grosvenor Gardens, London, SW1W 0AU in respect of any
personal data that you provide to us or we otherwise obtain about you.

1 WHAT TYPE OF PERSONAL DATA DO WE COLLECT FROM YOU?

1.1 When you engage with us (e.g. by sending us emails, or by visiting, making
an enquiry through or filling in forms on the Website), you may provide
information about yourself including your name and contact details (e.g. your
address, email address and telephone number) and your job title and CV where you
apply for a role with us. If you consider investing with us, you may also
provide us with your financial information and various other necessary personal
data (e.g. your national insurance, social security or tax payer identification
number, investment history and bank details).Where you make use of our Website
we may also collect details of your visits to our Website (e.g. your IP address
and choice of web browser, and the resources that you access).

1.2 Some of this information is collected and processed so we can perform a
contract with you, some for the purpose of legal compliance and some for the
purposes of our legitimate business interests (namely to carry out and improve
our business, analyse the use of our Website and services and support our
customers/users).

2 WHAT TYPE OF PERSONAL DATA DO WE COLLECT FROM OTHER SOURCES?

2.1 We may receive information from third parties who collect personal data from
you and pass it on to us. For example: (i) where we are conducting due diligence
on prospective investee companies or deciding whether to invest in third parties
we may also receive personal data concerning key personnel; (ii) our staff may
also give us emergency contact information as part of our emergency scenario
planning and may give us details of their dependents and of other people in
relation to their employee benefits arrangements; (iii) where another individual
makes an investment on your behalf, they may provide us with certain personal
data to effect the transfer of the investment to you, such as your name and
contact details; (iv) your employer may provide your personal data to us in
connection with a service they provide to us or in connection with services that
we provide to our clients; and (v) we may receive information from past
employers and others concerning your employment history where you apply for a
job with us.

2.2 Where this is the case the third party is responsible for informing you that
they have shared your personal data with us, directing you to this Privacy
Policy and obtaining any relevant consents from you to ensure you are happy with
the ways in which your personal data will be used.

3 SENSITIVE PERSONAL DATA

3.1 “Sensitive personal data” is personal data concerning an individual’s (i)
racial or ethnic origin, (ii) political opinions, (iii) religious beliefs or
other beliefs of a similar nature, (iv) membership of a trade union, (v)
physical or mental health or condition, (vi) sexual life or orientation, (vii)
commission or alleged commission of any offence or any proceedings for any
offence committed or alleged to have been committed by him/her, the disposal of
such proceedings or the sentence of any court in such proceedings.

3.2 You may provide us with sensitive personal data from time in connection with
your application to invest with us, our provision of investment services to you,
or otherwise. In such cases, the provision of this information is entirely
voluntary and subject to your express consent, however, we may be unable to
carry out some activities necessary to process your application, instructions or
other requests without the provision of such information. For example, we may be
unable to process application forms or similar requests. We will use any
sensitive personal data in accordance with the consent you have given and, where
necessary, we may also process such information in the establishment, exercise
or defence of legal claims.

3.3 Where we do receive sensitive personal data, we will only keep such
information for as long as strictly necessary in order to comply with our
obligations under the law.

4 HOW DO WE USE YOUR PERSONAL DATA?

4.1 We will only use personal data held about you in the following ways:

4.1.1 to carry out our obligations arising from any contracts entered into
between you and us;

4.1.2 to provide you with information, products or services that you request
from us and correspond with you;

4.1.3 to provide support to you in respect of our services;

4.1.4 to ensure that content from our Website is presented in the most effective
manner for you and for your computer;

4.1.5 where relevant, to process your application for employment;

4.1.6 to comply with our own legal and regulatory obligations; and

4.1.7 for our internal business processes.

4.2 We may also use your personal data to provide you with information about
goods and services which may be of interest to you and/or inform you about
important changes or developments to our services by email where you have
explicitly consented at the time we collected your personal data or where we
otherwise have a right to do so.

4.3 If you do not want us to use your personal data in this way, please let us
know by writing to us at Pemberton Capital Advisors LLP, 52 Grosvenor Gardens,
London SW1W 0AU or by emailing us your request to unsubscribe at
info@pembertonam.com. You may also opt out of marketing emails by following the
instructions outlined in the email.

5 DISCLOSURE OF PERSONAL DATA

5.1 We may disclose your personal data to any member of our group, which means
our subsidiaries, our ultimate holding company and its subsidiaries, as defined
in section 1159 of the United Kingdom Companies Act 2006.

5.2 Where it is necessary for the performance of our contract with you or for
our internal business processes, we may share your personal data with certain
third parties, such as our suppliers, contractors, affiliates, professional
advisers, regulatory bodies, auditors, technology providers, and/or third party
partners and any duly authorised agents or related, associated or affiliated
companies of the foregoing.

5.3 By submitting your personal data to us, you acknowledge that such third
parties may receive and process your personal data. We ask all third parties to
treat your personal data securely and in accordance with this Privacy Policy and
will take reasonable steps to enforce this. We will never sell your personal
data.

5.4 In addition, it may be necessary to disclose your personal data if:

5.4.1 we are under a duty to disclose or share your personal data in order to
comply with any legal obligation, carry out an internal investigation, or in
order to enforce or apply our terms of use and other agreements, or to protect
the rights, property or safety of Pemberton Capital Advisors, our group
companies, customers or others, including exchanging information with other
companies and organisations for the purposes of fraud protection and credit risk
reduction;

5.4.2 Pemberton Capital Advisors or substantially all of its assets are acquired
by a third party, in which case personal data held by us about our customers
will be one of the transferred assets; or

5.4.3 we sell or buy any business assets, in which case we may disclose your
personal data to the prospective seller or buyer of such business or assets.

6 HOW WE PROTECT YOUR PERSONAL DATA

6.1 The personal data you provide to us will be transferred to and stored
securely on our servers in the UK or our Cloud hosted in the EEA. and we take
all reasonable care to ensure the security of the Website and of your personal
data from access by unauthorised persons and against unlawful processing,
accidental loss, destruction and damage.

6.2 We will only keep your personal data for as long as we reasonably require
and, in any event, only for as long as the Data Protection Legislation allows.

6.3 Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal data,
we cannot guarantee the security of your data transmitted to our Website. Any
transmission is at your own risk. Once we have received your information, we
will use strict procedures and security features to try to prevent unauthorised
access.

7 TRANSFERRING PERSONAL DATA OUTSIDE OF THE EEA

7.1 In processing your personal data, it will sometimes be necessary for us to
transfer your personal data to a destination outside the European Economic Area
(“EEA”). It may also be processed by staff operating outside the EEA who work
for us or for one of our suppliers or group companies. Such staff may be engaged
in, among other things, the fulfilment of contracts, the processing of details
or the provision of support services.

7.2 We will take all steps reasonably necessary to ensure that your data is
treated securely and in accordance with this Privacy Policy and the Data
Protection Legislation when it is processed in, or otherwise accessed from, a
location outside the EEA. This means that we will only transfer your personal
data to third parties outside the EEA if that third party (a) is situated in a
country that has been confirmed by the European Commission to provide adequate
protection to personal data, or (b) has agreed (by way of written contract
incorporating the “model clauses” as approved by the European Commission or by
some other form of data transfer mechanism approved by the European Commission)
to provide all protections to your personal data as required by the Data
Protection Legislation or (c) we have your explicit consent to do so. Where any
transfer takes place under a written contract, you have the right to request a
copy of the safeguards in that contract and may do so by contacting us at
data.protection.officer@pembertonam.com. For the avoidance of doubt, in the
event that the UK is no longer a part of the EEA, references in this paragraph
to the EEA shall mean the EEA and the UK.

8 YOUR RIGHT TO ACCESS AND UPDATE YOUR PERSONAL DATA

8.1 You have the right to ask us not to process your personal data for marketing
or research purposes. If you have given us your express consent, or where we
otherwise have the right to do so, we may use your personal data for marketing
purposes. If we intend to disclose your personal data to any third party for
marketing purposes, we will seek your explicit consent prior to any such
transfer. You can exercise your right to prevent such processing by checking
certain boxes on the forms we use to collect your personal data, or by
contacting us at data.protection.officer@pembertonam.com.

8.2 You are entitled to know some details about the personal data hold about you
and how that information is processed. If you would like to request this, please
contact us in writing at Pemberton Capital Advisors LLP, 52 Grosvenor Gardens,
London SW1W 0AU providing us with sufficient information to identify you (we may
need to request proof of identity in some instances), and we will provide you
with the information to which you are entitled.

8.3 You have the right to ask us to: (a) make any changes to ensure that any
personal data we hold about you is accurate and up to date; (b) erase or stop
processing any personal data we hold about you where there is no longer a legal
ground for us to hold it; or (c) in some circumstances, transfer any information
we hold about you to a specified third party. If you wish to do this, please
contact us at data.protection.officer@pembertonam.com.

9 COMPLAINTS

9.1 Should you have any queries or complaints in relation to how we use your
personal data, please contact us at data.protection.officer@pembertonam.com.
Should you wish to take any complaints or queries further, you have the right to
contact the Information Commissioner’s Office regarding such issues.

10 COOKIES

10.1 A cookie is a small file that is sent to your browser from a web server and
is stored on your computer. Cookies help us to analyse web traffic and identify
which pages of our Website are being used. Our Website also uses cookies to
respond to you as an individual so that it can tailor its operations to your
needs, likes and dislikes by gathering and remembering information about your
preferences as well as enabling you to login. We only use this information for
statistical analysis purposes and then it is removed from our systems.

10.2 A cookie in no way gives us access to your computer or any information
about you, other than information about how you use the Website and the personal
data you choose to share with us (including personal data you automatically
share with us by way of your browser settings).

10.3 In particular, we use the following cookies:

10.3.1 Functionality cookies. These cookies are used to identify unique visitors
to Websites. If you log in to the Websites, these are the cookies that allow us
to remember who you are and what your preferences are so that we can provide you
with access to pages personal to you, for example your account pages or your
selected font size. These cookies can help to keep your visit to the site
secure.

10.3.2 Session cookies. These cookies allow us to identify your device as you
use the Website, so that you are not treated as a new visitor each time you go
to another part of the Website.

10.4 You can choose to accept or decline cookies. Most web browsers
automatically accept certain cookies, but you can usually modify your browser
setting to decline cookies if you prefer. This may prevent you from taking full
advantage of our Website. We may also use banners and pop-ups from time to time
to give you options around cookie use.

10.5 You may also turn non-essential cookies on or off at any time by accessing
cookie settings using the button below. If you have already accepted all cookies
the non-essential or functional cookies will be set to ‘ON’. Non-essential
cookies help us to improve our website by collecting and reporting information
on how you use it. The cookies collect information in a way that does not
directly identify you. You can come back to this page to change your cookie
settings at any time by using the link to [Privacy Policy & Cookies] at the
bottom of the website.

[Insert cookie settings button – links to Functional Cookies page of the new
cookie settings pop-up]

10.6 You can find more information about the specific cookies we use and the
purposes for which we use them in the table below. You can also find more
information about cookies generally here: www.allaboutcookies.org.



[table id=1 /]



11 LINKS TO OTHER WEBSITES

11.1 This Privacy Policy extends only to our Website and does not cover your use
of, provision of data to and collection of data on any other website.

11.2 Our Website may from time to time contain links to and from other websites.
If you follow a link to any of these websites please note that these websites
have their own privacy policies and that we do not accept any responsibility or
liability for these websites or their related policies. You should always check
these policies before you submit any personal data to these websites.

12 CHANGES TO THIS PRIVACY POLICY

12.1 Our Privacy Policy may be reviewed and enhanced from time to time. The
up-to-date version of our Privacy Policy is always available by visiting here;
by writing to Pemberton Capital Advisors LLP, 52 Grosvenor Gardens, London SW1W
0AU; or by emailing info@pembertonam.com. If you are not happy with any changes
that we make, you should not use or access (or continue to use or access) the
Website and/or our services.

13 CONTACT

13.1 Questions, comments and requests regarding this Privacy Policy are welcomed
and should be addressed to data.protection.officer@pembertonam.com. If you no
longer wish to receive materials from us and/or from such third parties, you may
opt-out of receiving these communications by writing to us at Pemberton Capital
Advisors LLP, 52 Grosvenor Gardens, London SW1W 0AU or by emailing us your
request to unsubscribe at info@pembertonam.com.

Last Updated: 25/05/2018

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This website and the information, materials, products and/or services available
on or through it are not and are not intended to offer or promote the offer or
sale of securities, the securities of any fund or the services of any company,
in certain jurisdictions or to certain types of investors. In particular,
securities or investments may only be offered or sold, transactions effected, or
services offered or provided in certain jurisdictions as noted in a private
placement memorandum to eligible investors or otherwise in compliance with our
Terms and Conditions of Use.

Pemberton Capital Advisors LLP or its affiliates and/or subsidiaries
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where it is not possible to provide investment advisory services to one or more
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fund.

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persons having professional experience of investing in unregulated schemes, high
net worth companies, partnerships, associations or trusts and personnel of any
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information in it.

Pemberton will not make any investment or investment activity referred to on
this website available to any other person.

This website and all materials on it or available via it do not and are not
intended to offer for sale or promote the offer for sale of the securities of
any fund or private fund in the United States or to a U.S. person as defined in
Regulation S under the U.S. Securities Act of 1933 (“Securities Act”), or the
services of any Pemberton company.

Access to the information contained in this website is restricted under
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compartment of a fund have not been and will not be registered with the U.S.
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