Privacy Policy

Welcome to Pathfinder Partners

Privacy Policy Last Revised: December 2020

Pathfinder Partners (“Company” or “We”) has created this Privacy Policy in order to set forth the principles governing our information-gathering and dissemination practices, including but not limited to such activities as forums, chat rooms, personal profile pages, product reviews, article commentary, blogs, RSS feeds and newsletters, among other offerings, all available through our site at www.pathfinderfunds.com (the “Site”), and any related services (the “Services”). Pathfinder Partners respects your privacy and are committed to protecting it through our compliance with this policy.

This policy applies to information we collect:

• On this Site.
• In email, text and other electronic messages between you and this Site.
• Through the mobile and desktop application you download from this Site.
• Through direct communications with the Company in email, text, telephone, or any other medium.

It does not apply to information collected by:

• Through websites operated by any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Site, except as expressly provided herein.

Information We Collect

There are two kinds of information that Pathfinder Partners can obtain about you: “Anonymous Information” and “Personally Identifiable Information.”

“Anonymous Information” consists of non-personally-identifiable data, such as your Internet Protocol (“IP”) address or domain, or information about your usage on Pathfinder Partners. For example, an IP address is a unique string of numbers that is assigned to your computer by your Internet Service Provider. Web servers automatically identify your computer by its IP address. We may collect our users’ IP addresses for a variety of purposes, including to help diagnose problems with our servers and to report aggregate information to our advertisers, corporate affiliates and consultants, and to third parties that perform particular services on our behalf.

We may also use the information linked to IP addresses to ban users who violate our Terms and Conditions of use.

“Personally Identifiable Information” is any information that personally identifies you, such as your name, street address, email address, or telephone number. We collect such information when, for example, you enter such information in response to a request for such information, subscribe to our email newsletter, or participate in other interactive online activities or Services. If you post messages, text, comments, or other content at various places on our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.

If you are an investor, we may also collect information related to your investments through the Investor Portal. For more information about our collection of information related to your investments, please see https://www.junipersquare.com/privacy-policy.

When we collect Personally Identifiable Information from you for the purpose of delivering our digital communications, e.g., our newsletter, you will have the opportunity to “opt in.”  You can opt-out of receiving these digital communications from us by following the instructions and links provided at the bottom of each communications. If you use this method, you will stop receiving promotional communications from us or our business partners that sent you the message.

If you have submitted your personal information to Pathfinder Partners as an investor, you may correct, amend or delete the Personally Identifiable Information maintained on file about you if it is incorrect, subject to our verification, through the Investor Portal or by contacting us at info@pathfinderfunds.com.

If you are a registered Community member of Pathfinder Partners, you may manage your membership information as well as your subscriptions. Simply login to your community account and click on “Account Options.” Click on the tab marked “Account” to manage your password and email address; click on the tab marked “Subscriptions” to manage your newsletter subscriptions and click on the tab, “Profile” to edit your public profile.

Mobile Services. We may also collect information from your mobile device if you are using it to access our Site. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Services, and information about the type of device you use.

Use of “Cookies”

The Site uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you on your computer, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Pathfinder Partners pages, or register with the Site or Services, a cookie helps Pathfinder Partners to recall your specific information on subsequent visits. This simplifies the process of recording your personal information. When you return to the same Site, the information you previously provided can be retrieved, so you can easily use the Pathfinder Partners features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Services or Web sites you visit.

Flash Cookies (or “Flash LSOs”)

When we post videos, third parties may use local shared objects (LSOs), known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Third Party Web Sites

Pathfinder Partners contains links to third-party Web sites not owned or controlled by Pathfinder Partners. Pathfinder Partners is not responsible for the privacy practices or the content of such third-party Web sites. Inclusion of any linked Web site on Pathfinder Partners does not imply or express an approval or endorsement of the linked Web site by us, or of any of the content, opinions, products or services provided on these Web sites. Even if an affiliation exists between Pathfinder Partners and a third-party Web site, we exercise no control over linked sites. Each of these linked sites maintains its own independent privacy and data collection policies and procedures. If you visit a Web site via a link from one of our Sites, we encourage you to consult that Web site’s privacy policy before providing any personal information, and whenever interacting with any such Web site.

Information You Provide to Facebook and other Social Networking Sites

The Services allow users to access Facebook to interact with friends and to share on Facebook through Wall and friends’ News Feeds. If you are already logged into the Services and Facebook or another Social Networking Site (SNS), when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to merge your profiles. If you are already logged into the Services but not logged into Facebook or another SNS that we support, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you are allowing the Services to access your information and you are agreeing to the Facebook or other SNS’s Terms of Use in your use of the Services. Conversely, if you are not currently registered as a user of the Services, and you click on “Sign in” using Facebook or another SNS that we support, you will first be asked to enter your Facebook or SNS credentials and then be given the option to register for the Services. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an Account on the Site and show our relevant content from your Facebook or SNS friends. Once you register on the Site and connect with Facebook or another SNS, you will be able to automatically post recent activity back to Facebook or the other SNS. Any information that we collect from your Facebook or other SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices. You can edit privacy settings for the reviews that appear on Facebook or disconnect your Services activity stream by visiting the Facebook Applications Settings page.

How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information to: present you with our Site; provide you with information, products, or Services that you request from us; provide you with information, products, or Services that we think may be of interest to you; to fulfill any other purpose for which you provide it; to carry out our obligations and enforce our rights; to allow you to participate in interactive features on our Site; in any other way we may describe when you provide the information; or for any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may share your Personally Identifiable Information with third party service providers we use to support our business to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other Services by the Company. These third-party service providers are required not to use your Personally Identifiable Information other than to provide the Services requested by Company.

We may also disclose personal information that we collect or you provide as described in this policy to our subsidiaries and affiliates to: provide you with Services that we offer you through our Site; provide you with information, products, or Services that you request from us; provide you with information, products, or Services that we think may be of interest to you; in any other way we may describe when you provide the information; or for any other purpose with your consent.

As we continue to develop our business, we may buy, merge or partner with other companies or businesses, and in so doing, acquire or share information about Site users or investors. In such transactions, Personally Identifiable Information held by the Company may be among the transferred assets. Similarly, in the event that a portion or all of Pathfinder Partners’ assets are sold or transferred to a third party, Personally Identifiable Information held by the Company would likely be among the transferred business assets.

Notwithstanding any other provision of this Privacy Policy, we may disclose Personally Identifiable Information to others if we are required to do so by law or we in good faith believe that such action is necessary to (a) comply with the law or with legal process; (b) protect and defend our rights or property; (c) protect against misuse or unauthorized use of the Site; or (d) protect the personal safety or property of our users or the public. Please note that we may not provide you with notice prior to disclosure in such cases.

Public Forums

Pathfinder Partners may make chat rooms, forums, blogs, article commenting, and personal profile pages available to users. Please remember that any such information that you may choose to provide in these areas becomes accessible to the public, and also becomes the property of Pathfinder Partners in accordance with our Terms and Conditions, and we may use such information in any way that we see fit. Though we take measure to limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your information. Consequently, you should exercise caution when deciding to disclose your personal information or to upload material of any kind.

Security

Pathfinder Partners has implemented measures designed to protect your personal information from accidental loss, misuse, unauthorized access, disclosure and alteration. Security of information communicated by or to us over the Internet is important to us; however, no networked data communications can be guaranteed to be 100% secure. Please note that your email, like most, if not all, unencrypted Internet communications, may potentially be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. For that reason, to protect your privacy, please do not use email to communicate information to us that you consider confidential. While we strive to protect your personal information, Pathfinder Partners cannot ensure or warrant the security of any information you transmit to us. Once we receive your transmission, we will use reasonable efforts to ensure its security on our internal systems. Depending on the nature of the inquiry, your communication may be discarded or archived.

Policy Regarding Minors

Children should always ask parents before providing any personal information online. No information should be submitted to or posted on Pathfinder Partners by any minor (a person under 18 years of age) without the consent of a parent or guardian. Unless otherwise disclosed during collection, we do not knowingly provide any Personally Identifiable Information about minors, regardless of its source, nor is this information knowingly used by Pathfinder Partners for any marketing or promotional purposes. Minors are not eligible to participate in contests.

In the event that we learn that we have collected information from any child under the age of 13 without verification of parental consent, we will delete this information from our database. If you believe that the Site has collected any information about anyone under 13, please contact Pathfinder Partners’ Site Administrator via postal mail or email at one of the addresses listed below.

Policy Regarding Users Outside of the United States

If you are a non-U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

Limitation of Liability

Pathfinder Partners PROVIDES THE INFORMATION, SERVICES AND PRODUCTS ON THIS WEB SITES “AS IS” WITHOUT WARRANTIES OF ANY KIND. YOU AGREE THAT Pathfinder Partners SHALL NOT BE RESPONSIBLE FOR ANY CONTENT FOUND ON OUR FORUMS, THAT ANY DOWNLOADING OF MATERIALS FOUND ON OR THROUGH Pathfinder Partners FORUMS IS DONE AT YOUR OWN RISK, AND THAT Pathfinder Partners IS NOT RESPONSIBLE FOR UNSOLICITED COMMUNICATIONS THAT ARISE FROM YOUR POSTINGS. Pathfinder Partners SHALL NOT BE RESPONSIBLE IN ANY MANNER FOR THE ACTS OF ANY THIRD PARTY, INCLUDING WITHOUT LIMITATION, ANY THIRD PARTY AD NETWORK.

Consent and Modifications to this Privacy Policy

Pathfinder Partners is controlled, operated and administered entirely within the United States. By using the Pathfinder Partners Site, Investor Portal, and/or participating in the activities of Pathfinder Partners’ community, you signify your agreement to the terms of this Privacy Policy. If you do not agree with this Privacy Policy, please do not disclose any personal information through our Site, Investor Portal or to us generally. At its discretion, Pathfinder Partners may modify this Privacy Policy at any time.  Modifications are effective upon being posted on the Site and your continued use of the Site after we make changes is deemed acceptance of those changes, so please check the policy periodically for changes.

Contacting Pathfinder Partners

If you have any questions about this Privacy Policy, you may contact us at:

Pathfinder Partners
Attn: Privacy
4380 La Jolla Village Drive, Suite 250
San Diego, CA 92122

Email: info@pathfinderfunds.com
Phone: 858-875-4400

This Privacy Policy is effective as of the date written above and supersedes all earlier versions of our Privacy Policy.