Legal

Welcome to www.truebridgecapital.com (including any successor website, the “TrueBridge Website”), the website of TrueBridge Capital Partners, LLC, a Delaware limited liability company (“TrueBridge”, “we”, “us” or “our”). As used herein, the term “Website” refers to the TrueBridge Website and our partner portal currently located at [https://truebridge.altareturn.com] (including any successor website, the “Partner Portal”). We provide the Website to you subject to the following Terms and Conditions (“Terms”).

Please carefully read and review the following Terms before use of the Website. By accessing and using the Website, you acknowledge that you have read and understand and agree to be bound by these Terms. If at any time you do not agree to these Terms, please do not access or use the Website or any of our content made available to you through the Website (“Our Content”).

YOUR ACCESS TO, USE OF AND BROWSING OF THE WEBSITE AND OUR CONTENT IS SUBJECT TO THE TERMS CONTAINED HEREIN AND ALL APPLICABLE LAWS AND REGULATIONS. IF YOU DO NOT AGREE TO THESE TERMS, YOUR PERMISSION TO ACCESS OR USE THE WEBSITE IS AUTOMATICALLY AND IMMEDIATELY REVOKED.

TrueBridge may revise or update the Terms from time to time with or without notice to you, however if you use our Partner Portal, you will be required to approve the updated version of the Terms when you sign into the Partner Portal. You should check the Terms regularly for updates. You can determine when the Terms were last revised by referring to the “Last Revised” legend at the top of this page. Any changes in the Terms take effect upon posting and only apply to use of the Website after that date. Each time you access, use or browse the Website, you signify your acceptance of the then-current Terms. You consent to receive communications from TrueBridge in an electronic form. You agree that all terms and conditions, agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications would satisfy if they were in writing. You may download a copy of these Terms here.

In consideration of your use of the Website, you represent that you are of an age to form a legally binding contract and you are not prohibited from receiving services under the laws of the United States or any other applicable jurisdiction. If you are viewing the Website on behalf of a legal entity, you agree that you have the right to bind that legal entity to these Terms, and that such entity is so bound.

The Website is directed to persons 18 years of age or older. TrueBridge and the Website do not knowingly collect information from children under age 18. If you are under age 13, you are not permitted to use the Website or to submit any personally identifiable information to the Website. If you provide information to TrueBridge through the Website, you represent that you are 13 years of age or older. If you are between 13 and 17 years of age, when you visit, browse and use the information on the Website, you represent that you have the permission of a parent or guardian to do so and who agrees to these Terms on your behalf; you may post messages, but you may not submit any personal information. If you are a parent or guardian and believe TrueBridge may have inadvertently collected personal information from your child, please notify TrueBridge immediately by sending an email to info@truebridgecapital.com.

Our Content is the sole and exclusive property of TrueBridge, our affiliates and/or our licensors. You agree not to reproduce, duplicate, modify, copy, sell, resell or exploit for any commercial purpose, any portion of the Website or Our Content other than as expressly authorized by TrueBridge in writing or as contemplated by the purpose of the Partner Portal. Use of the Website or Our Content in any way not expressly permitted by these Terms is prohibited, and may be actionable under United States or international law. You agree not to access the Website by any means other than through a standard web browser in any media. You agree not to use the Website for any unethical or illegal purpose or in contravention to federal, state, local or international laws or regulations. You agree not to use the Website for any purpose that impairs or disrupts the Website, including (i) using monitoring, crawling, harvesting or scraping technologies, (ii) attempting to overload a system by mail bombing, news bombing, broadcast attacks, flooding techniques, or denial of service attacks, (iii) evading any access limits, storage restrictions, or other limitations placed on the system, or (iv) engaging in conduct likely to result in retaliation against TrueBridge, our employees, officers, agents or partners. The Website and Our Content are provided solely for your own information and personal use. You may not publish, modify, distribute, perform, sell, resell, exploit, or create derivative works from any part of the Website or Our Content unless expressly authorized by TrueBridge in writing. You agree that you will not remove, obscure or modify any acknowledgements, credits or legal, intellectual property or proprietary notices, or any marks or logos contained on the Website or in Our Content.

You may make information available to us through the Website, including through the Partner Portal (“Your Content”). You agree that (i) you have the right to provide Your Content to us for the purposes contemplated herein, (ii) we may use Your Content in accordance with the terms of our Privacy Policy and applicable law, (iii) Your Content is correct, accurate, and complete, (iv) Your Content does not contain any virus, malware, disabling device or other harmful code, and (v) Your Content does not contain any illegal, exploitative, sexually explicit, violent, abusive, or other content that we may deem, in our sole discretion, harmful to our interests (clauses (iv) and (v) collectively, “Harmful Content”). We reserve the right to delete any Harmful Content from the Website at any time with or without notice to you, refer any such Harmful Content to governmental authorities, and take any other such actions as we deem necessary or appropriate to maintain the integrity and reputation of the Website.

The TrueBridge Website may contain postings and links to websites operated by other parties, such as the Partner Portal (“Linked Websites”). The TrueBridge Website provides these postings and links as a convenience, and your use of these websites, products or services, which are not under our direct control, is at your own risk. Such postings or links or references to third party goods or services do not imply endorsement of information, material, products or services of any third party or on any other site. TrueBridge disclaims all liability with regard to your access to and use of such information, material, products or services or transactions with such linked website or third parties. You acknowledge and agree that TrueBridge shall not be responsible or liable, directly or indirectly, for any damage, loss or other claim caused or alleged to be caused by or in connection with, access to, use of or reliance on any content available on or through any other site or resource.

YOUR CORRESPONDENCE AND BUSINESS DEALINGS WITH OTHERS FOUND ON OR THROUGH THE WEBSITE AND/OR SERVICES, INCLUDING, WITHOUT LIMITATION, THE PAYMENT AND DELIVERY OF PRODUCTS AND SERVICES, AND ANY TERMS, CONDITIONS, WARRANTIES AND REPRESENTATIONS ASSOCIATED WITH ANY SUCH DEALINGS, ARE SOLELY BETWEEN YOU AND THE THIRD-PARTY, PROVIDED THAT THESE TERMS SHALL APPLY TO YOUR USE OF THE PARTNER PORTAL. TRUEBRIDGE ENCOURAGES YOU TO REVIEW ALL POLICIES, RULES, TERMS AND REGULATIONS, INCLUDING THE PRIVACY POLICIES AND TERMS OF USE OF EACH AND ANY THIRD-PARTY SITE THAT YOU VISIT.

You acknowledge and agree that, as between TrueBridge and you, all right, title and interest in and to the Website and Our Content, including without limitation any patents, copyrights, trademarks, trade secrets, inventions, know how, or any other intellectual property rights, are owned exclusively by TrueBridge, its affiliates, or its licensors, are valid and enforceable, and are protected by United States intellectual property laws and other applicable laws. You agree that you will not modify, decompile, disassemble, reverse engineer or create derivative works of the Website or any portion thereof except as permitted by applicable law.

Copyright

All of Our Content, such as text, graphics, videos, logos, icons, images, media, data, audio, animation, software and other information and materials, is the copyright and property of TrueBridge, its affiliates or licensors and content suppliers and protected by U.S. and international copyright laws. Permission is granted to electronically copy and print hard copy portions of the Website solely for your own information and personal use. Any other use, including without limitation the reproduction, modification, distribution, transmission, publication, display, performance or commercial exploitation of Our Content, is strictly prohibited.

Trademarks

The trademarks, service marks, logos, slogans, trade names and trade dress used on the Website are proprietary to TrueBridge or its affiliates or licensors. Without limiting the foregoing, ‘TrueBridge Capital Partners’ is a trademark of TrueBridge. Unauthorized use of any trademark of TrueBridge, its affiliates, or licensors may be a violation of applicable trademark laws. Any third party names or trademarks referenced in the Website do not constitute or imply affiliation, endorsement or recommendation by TrueBridge of the third parties, or by the third parties of TrueBridge.

YOU AGREE TO INDEMNIFY, DEFEND AND HOLD TRUEBRIDGE, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SUBSIDIARIES, AFFILIATES AND LICENSORS HARMLESS FROM AND AGAINST ANY LOSS, LIABILITY, CLAIM OR DEMAND, INCLUDING WITHOUT LIMITATION ATTORNEYS’ FEES, MADE BY YOU OR ON YOUR BEHALF OR BY ANY THIRD PARTY DUE TO OR ARISING OUT OF (A) YOUR CONTENT; (B) YOUR VIOLATION OF THESE TERMS, ANY APPLICABLE LAWS, OR THE RIGHTS OF TRUEBRIDGE OR ANY THIRD PARTY; AND (C) YOUR USE OF ANY LINKED WEBSITE.

THE WEBSITE AND OUR CONTENT AND ALL INFORMATION, CONTENT, SERVICES, PRODUCTS AND ACTIVITIES OFFERED, CONTAINED IN OR ADVERTISED ON THE WEBSITE, INCLUDING WITHOUT LIMITATION TEXT, VIDEO, GRAPHICS AND LINKS, ARE PROVIDED ON AN “AS IS,” “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED. TO THE MAXIMUM EXTENT PERMITTED BY LAW, TRUEBRIDGE AND ITS AFFILIATES, LICENSORS, VENDORS AND SUPPLIERS DISCLAIM ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, WITH RESPECT TO SUCH INFORMATION, CONTENT, SERVICES, PRODUCTS, ACTIVITIES AND MATERIALS, AND EXPRESSLY DISCLAIM LIABILITY FOR ERRORS OR OMISSIONS IN THE FOREGOING, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, SUITABILITY, FREEDOM FROM COMPUTER VIRUS, ACCURACY, RELIABILITY, SAFETY, NON-INTERRUPTION, PERFORMANCE, COURSE OF DEALING OR COURSE OF PERFORMANCE, OR COMPLIANCE WITH APPLICABLE LAW. YOUR USE OF THE WEBSITE AND OUR CONTENT IS ENTIRELY AT YOUR OWN RISK.

Without limiting the foregoing, you are responsible for taking all necessary precautions to insure that Your Content and access to the Website is free of viruses or other harmful content.

TrueBridge reserves the right at any time and from time to time to modify, suspend or discontinue, temporarily or permanently, the Website, products, services or any portion thereof, with or without notice. You agree that TrueBridge will not be liable to you or to any third party for any modification, suspension or discontinuance of a Website, product, or service.

TrueBridge reserves the right, at its sole discretion, immediately and without notice, to suspend, discontinue, or terminate your access to the Website, products, services or any part thereof for any reason, including without limitation any breach by you of these Terms. You agree that TrueBridge shall not be liable to you or any third party for any such suspension, discontinuance or termination.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, TRUEBRIDGE AND ITS AFFILIATES DISCLAIM ALL LIABILITY, WHETHER BASED IN CONTRACT, TORT (INCLUDING WITHOUT LIMITATION NEGLIGENCE), STRICT LIABILITY OR ANY OTHER THEORY ARISING OUT OF OR IN CONNECTION WITH THE WEBSITE, USE, INABILITY TO USE OR PERFORMANCE OF, OR THE INFORMATION, CONTENT, PRODUCTS, SERVICES, ACTIVITIES OR MATERIALS AVAILABLE FROM OR THROUGH THE WEBSITE. IN NO EVENT SHALL TRUEBRIDGE OR ITS AFFILIATES BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, PUNITIVE, INCIDENTAL, EXEMPLARY OR CONSEQUENTIAL DAMAGES OF ANY KIND RESULTING FROM THE USE OF OR THE INABILITY TO USE THE WEBSITE, PRODUCTS, OR SERVICES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLES, EVEN IF TRUEBRIDGE WAS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THESE LIMITATIONS SHALL APPLY NOTWITHSTANDING ANY FAILURE OF ESSENTIAL PURPOSE OR THE EXISTENCE OF ANY LIMITED REMEDY, AND TRUEBRIDGE WOULD NOT HAVE MADE THE WEBSITE AVAILABLE TO YOU WITHOUT THE BENEFIT OF SUCH PROTECTIONS.

Exclusions and Limitations: Because some jurisdictions do not allow limitations on how long an implied warranty lasts, or the exclusion or limitation of liability for consequential or incidental damages, the above limitations may not apply to you. This Limitation of Liability shall be to the maximum extent permitted by applicable law.

Pursuant to California Civil Code Section 1789.3, California residents are entitled to the following specific consumer rights notice:

The name, address and telephone number of the provider of this service is TrueBridge Capital Partners, LLC, 1011 South Hamilton Road Suite 400 Chapel Hill, North Carolina 27517. Complaints regarding the service or requests to receive further information regarding use of this service may be sent to the above address or to info@truebridgecapital.com or 919.442.5201.

The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Boulevard, Suite N-112, Sacramento, CA 95834 or by telephone at (916) 445-1254 or (800) 952-5210.

These Terms shall be governed by, and will be construed in accordance with, the laws of the State of Delaware U.S.A., without regard to choice of law principles. You irrevocably agree that the federal and state courts located in or for Delaware, U.S.A., are the sole and exclusive forum and venue for any dispute, as the most convenient and appropriate to address any disputes, and you agree to submit to the jurisdiction and venue of such courts. You agree that to the fullest extent permitted by law: (1) no claims by you shall be joined with any other and you agree not to participate in any claim brought by others; (2) YOU HAVE NO RIGHT OR AUTHORITY FOR ANY DISPUTE TO BE LITIGATED ON A CLASS-ACTION BASIS OR TO UTILIZE CLASS ACTION PROCEDURES; (3) no claims shall be brought by you more than one (1) year after such claim has accrued; and (4) you have no right or authority for any dispute to be brought in a purported representative capacity on behalf of the general public or any other persons.

The TrueBridge Website is currently controlled within the state of North Carolina, and the Partner Portal is currently controlled within the state of Virginia. Access to this Website from jurisdictions or territories where Our Content or this Website are illegal or penalized is prohibited. TrueBridge has no obligation to provide access to the Website, products, or services and reserves the right to limit the availability of the Website to any person, geographic area or jurisdiction at any time in its sole discretion.

These Terms set forth the entire understanding and agreement between you and TrueBridge with respect to the use of the Website. If any provision of the Terms is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties’ intentions as reflected in the provision, and the other provisions shall remain in full force and effect. Headings are for reference only and in no way define, limit, construe or describe the scope or extent of such section. TrueBridge’s failure to act with respect to any failure by you or others to comply with these Terms does not waive its right to act with respect to subsequent or similar failures. You may not assign or transfer these Terms or your rights or obligations under these Terms without the prior written consent of TrueBridge, and any assignment or transfer in violation of this provision shall be voidable. TrueBridge may assign, transfer, sublicense or delegate our rights or obligations under these Terms either in whole or in part, at any time, at our sole discretion, and without your consent. There are no third party beneficiaries to these Terms. No joint venture, partnership, shareholder, employment or agency relationship exists between TrueBridge and you as a result of agreeing to these Terms or your use of the Website, products, or services. Notwithstanding any reference to ‘affiliates’ herein, such term does not include you or your affiliates to the extent you or your affiliates may be considered an affiliate of TrueBridge by virtue of your equity ownership in one or more of our funds.

Certain information on this site may constitute forward-looking statements, which can be identified by the use of terms such as “may”, “will”, “should”, “expect”, “anticipate”, “target”, “project”, “estimate”, “intend”, “continue” or “believe” (or the negatives thereof) or other variations thereof. Due to various risks and uncertainties, actual events, results or performance may differ materially from those reflected or contemplated in such forward-looking statements. As a result, users of this site should not rely on such forward-looking statements. Any market analysis and statements of opinions provided on the Website are inherently uncertain and are based on a number of assumptions. You should carefully review information regarding any such analyses and underlying assumptions.

In considering any prior performance information contained herein, prospective investors should bear in mind that prior performance is not indicative of future results, and there can be no assurance that any TrueBridge fund will achieve favorable results or be able to avoid losses. Unless otherwise indicated, performance results that are presented on a “gross” basis do not reflect management fees, “carried interest,” taxes and other expenses that will be borne by investors, which TrueBridge expects to be material. Values of unrealized investments contained herein are estimates made by TrueBridge that TrueBridge believes to be reasonable. Actual realized proceeds on unrealized investments will depend on, among other factors, future operating results, the value of the assets and market conditions at the time of disposition, any related transaction costs and the timing and manner of sale, all of which may differ from the assumptions on which the valuations reflected in the historical investment performance data contained herein are based. Accordingly, the actual realized proceeds on these unrealized investments may differ materially from the returns indicated herein. Performance figures contained herein are presented to sophisticated prospective investors in one-on-one meetings of a confidential nature and where the communication of performance results is not made through any print, electronic or other media. TrueBridge will make materials available to a sophisticated prospective investor upon request.

All data is presented as of December 15, 2021.

This Privacy Policy applies to information that TrueBridge Capital Partners, LLC, and its affiliates (collectively referred to in this policy as “TrueBridge,” “our,” “we” or “us”) collects, uses, and shares from and about you in connection with certain TrueBridge’s services, TrueBridge’s website www.truebridgecapital.com, TrueBridge Investor portal [https://truebridge.altareturn.com], and any other affiliated website or services authorized by TrueBridge that links to this Privacy Policy (collectively, the “Services”).

Your privacy and security are very important to us at TrueBridge. We’re committed to transparency when it comes to our privacy practices and how we safeguard your information. This Privacy Policy (“Policy”) outlines what kinds of information we may collect from and about you as you use our Services and website, how that information may be used and shared, and what rights and choices you may have.

This Policy applies to any use of our Services or when you communicate with us. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby consent to our collection, use, and sharing of your information in the following ways. This Policy is part of our Terms of Use which you can find here. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

This Privacy Policy describes the information that we collect (directly or indirectly) and why we collect it, what we do with the information we collect and how you can manage your personal information (defined below). You may download a copy of this Privacy Policy here.  If you require an alternative format to access this policy due to a disability, please contact us at (info@truebridgecapital.com) for assistance.
Access to the TrueBridge Investors webpages is governed by the Privacy Policy for Investors located here.
BY USING THE SERVICES YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.
PLEASE BE AWARE THAT TRUEBRIDGE, TRUEBRIDGE INVESTORS, AND ALL ASSOCIATED WEBSITES AND SYSTEMS ARE HOUSED ON SERVERS LOCATED IN THE UNITED STATES. IF YOU ARE LOCATED OUTSIDE OF THE UNITED STATES, INFORMATION WE COLLECT (INCLUDING COOKIES) ARE PROCESSED AND STORED IN THE UNITED STATES, WHICH MAY NOT OFFER THE SAME LEVEL OF PRIVACY PROTECTION AS THE COUNTRY WHERE YOU RESIDE OR OF WHICH YOU ARE A CITIZEN. BY USING THE WEBSITES AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO AND PROCESSING OF THE INFORMATION IN THE UNITED STATES.

As used in this Policy, “Personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you personally. Below are some examples of the Personal Information we may collect through the Services:

We may link together different types of information or link information to Personal Information. If linked information directly or indirectly identifies an individual person, we treat the linked information as Personal Information. In this Privacy Policy, to “process” Personal Information means to perform any operation on Personal Information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying. Where we need to collect Personal Information by law, or under the terms of the contract between us and you do not provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In that case, we may have to cancel a product or service you have with us, and we will notify you if this is the case.

We collect information as follows.

How We Use Cookies

We use Cookies to track how you use the Services by providing usage statistics. Cookies are also used to allow product authentication to you based upon your browsing history and previous visits to the Services. Information supplied to us using cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them, as the case may be.

While this information on its own may not constitute your Personal Information, we may combine the information we collect via Cookies with Personal Information that we have collected from you to learn more about how you use the Services to improve them.

Types of Cookies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on the Services can be grouped into the following categories:

Cookies Set by Third Party Sites

To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on our website. We currently use, and may in future use content from websites such as LinkedIn and Twitter. You may be presented with Cookies from these and other third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the third parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.

We also use Google, a third-party analytics provider, to collect information about website usage and the users of our website, including demographic and interest-level information. Google uses cookies to collect demographic and interest-level information and usage information from users that visit our website, including information about the pages where users enter and exit our website and what pages users view on our website, time spent, browser, operating system, and IP address. Cookies allow Google to recognize a user when a user visits our website and when the user visits other websites. Google uses the information it collects from our website and other websites to share with us and other website operators’ information about users, including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link information we receive from Google with any of your Personal Information. For more information regarding Google’s use of cookies, and collection and use of information, see the Google Privacy Policy (available at https://policies.google.com/privacy?hl=en). If you would like to opt out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout).

Other Similar Technologies

TrueBridge web pages may use other technologies, such as web beacons, to help deliver cookies on our website and count users who have visited those websites. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.

In addition to standard cookies and web beacons, our website can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments.

If you are using a mobile device to access our website, you will need to refer to your instruction manual or other help/settings resource to find out how you can control cookies on your device.

Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the website may not operate properly, and you may not have access to the website. TrueBridge shall not be liable for any impossibility to use the website or degraded functioning thereof, where such are caused by your settings and choices regarding cookies.

To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including TrueBridge, do not respond to DNT signals.

We may use your Personal Information for the following purposes or otherwise as described at the time we collect it:

Deliver Services.  We may use your Personal Information to:

Research and Development,  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing.  We may send you direct marketing communications related to TrueBridge and as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your Personal Information to:

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or required for compliance or protection, as described above. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

TrueBridge may use your Personal Information  for the following purposes based on our legitimate interests:

We may also use your personal information when necessary for the performance of a contract in the following contexts:

We may also use your personal information when necessary to comply with legal obligations.

We may share your Personal Information with our corporate subsidiaries and affiliates, for purposes consistent with this Policy.  TrueBridge may also share your Personal Information with its service providers and other third-parties that perform services on our behalf, such as:

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as information technology, hosting, customer relationship management and support, payment processing, email delivery, advertising, marketing, and website analytics).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquiring and other relevant parties to business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, TrueBridge or our affiliates (including, in connection with a bankruptcy or similar proceedings). TrueBridge requires that the shared Personal Information remain subject to the promises made in our then-current Privacy Policy, unless and until you agree to a new privacy terms.

Additionally, we may share your information with companies that are conducting marketing and advertising to benefit TrueBridge. These third party companies may use your contact information for communications and marketing purposes that support our activities. You are under no obligation to respond and the companies are restricted from using your contact information for any other purpose. TrueBridge will ensure that any service provider with which we share Personal Information agrees to safeguard it in substantially the same manner as TrueBridge has described in this Privacy Policy and in accordance with all applicable laws.

TrueBridge may aggregate Personal Information collected through the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Anonymized Information”). TrueBridge shares Anonymized Information with third parties and does not limit third parties’ use of the Anonymized Information because it is no longer Personal Information.

Applicable law may require TrueBridge to disclose your personal information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) disclosure would mitigate TrueBridge’s liability in an actual or threatened lawsuit; (iii) necessary to protect legal rights of TrueBridge, users, customers, business partners or other interested parties; or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law).

The Services are not directed to or intended for use by individuals under the younger of the age of 16 (“Minors”). Consistent with the requirements of applicable law, if we learn that we have received any Personal Information directly from a minor without his or her parent’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Services and subsequently will delete that Personal Information.

TrueBridge uses a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no system or electronic data transmission is completely secure. Any transmission of your Personal Information is at your own risk and we expect that you will use appropriate security measures to protect your Personal Information.

If we become aware of a breach that affects the security of your Personal Information, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, TrueBridge will provide any such notice that TrueBridge must provide to you under applicable law at the email address associated with your TrueBridge account. By using the Services, you agree to accept such email notice.

We retain Personal Information in identifiable form only for as long as necessary to fulfill the purposes for which the Personal Information was provided to TrueBridge or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements and similar essential purposes.

If you have registered for an online account with us, you  may request access to your Personal Information and correction of an error or omission in your Personal Information by contacting us at info@truebridgecapital.com or by writing to us at: TrueBridge Capital Partners, LLC, Attn: Privacy Inquiries, 1011 South Hamilton Road Suite 400, Chapel Hill, North Carolina 27517. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical. Residents of California may have additional rights concerning the access and updating of their Personal Information (see Section 11 below).

Data Collection

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect or may have collected in the last twelve (12) months the categories of personal information as described in Section 2 above.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the business purposes indicated in Section 5 above.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the categories of third parties listed in Section 6 above.

In the preceding twelve (12) months, we have collected, used and disclosed the following categories of personal information, by reference to the categories of Personal Information specified in the CCPA (California Civil Code § 1798.140):

We do not sell personal information and have not done so over the previous 12 months. In the event that we do sell any personal information, we will update this Privacy Policy to list the categories of consumers’ Personal Information sold.

Your Rights and Choices

The CCPA (as amended by the California Privacy Rights Act “CPRA”, collectively the “CCPA/CPRA”) provides California resident consumers  with specific rights regarding their Personal Information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

Right to Access Specific Information and Data Portability Right. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

We may limit the disclosure of any sensitive Personal Information for your security and safety in accordance with the law.

Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  Under the CCPA/CPRA, the deletion right is subject to certain exceptions: for example, we may need to retain certain Personal Information to provide you with the Services or complete a transaction or other action you have requested, or to comply with our legal obligations. If your deletion request is subject to one of these exceptions, we may deny or partially deny your deletion request.

Right to Correct.  You have the right to request correction of any inaccuracies in your Personal Information (to the extent you are unable to make corrections directly via your account).

Right to Restrict Processing of Sensitive Personal Information. You have the right to request restricted processing of Sensitive Personal Information subject to the exceptions and limitations of the CCPA/CPRA including, for example, processing of sensitive Personal Information that may be necessary or required to meet legal or tax obligations or to provide the Services you have requested.

Exercising Your Rights

To exercise the rights described above, please complete and email us a copy of this Verifiable Consumer Request Form to info@truebridgecapital.com or call us at 919-442-5201 to provide required validation information. Each request that meets this requirement will be considered a “Valid Request.” 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make such a request for access or data portability twice within a 12-month period. The Valid Request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a Valid Request does not require you to create an account with us. We will only use Personal Information provided in a Valid Request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a Valid Request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the Valid Request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your Valid Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Under the Virginia Consumer Data Privacy Act (“VCDPA”), Virginia residents have certain additional privacy rights regarding the collection, use and sharing of Personal Information. The section “Personal Information We Collect” of this Policy serves as notice of the categories of Personal Information we may collect about you and our processing purposes and the section “How We Process Your Personal Information”  provides detail about how we may disclose your Personal Information to others such as Service Providers.

Your Rights to Manage and Control Your Personal Information

TrueBridge does not sell Personal Information of Virginia residents and has not done so in the last 12 months.

You have the right to request access to or deletion of your Personal Information, or to make corrections to inaccuracies. You can initiate a request by clicking on “Verifiable Request Form” or by emailing us at info@truebridgecapital.com. We may limit the disclosure of certain information in an access request for your security and safety in accordance with the law and the right to deletion is subject to certain exceptions: for example, we may need to retain certain Personal Information to provide you with the Services or complete a transaction or other action you have requested, or to comply with our legal obligation. Appeals may be made by writing to info@truebridgecapital.com using the subject line: “DSR Appeal.”

Beginning July 1, 2023, under the Colorado Privacy Act, Colorado residents have additional privacy rights regarding the collections, use and disclosure of their Personal Information. The section “Personal Information We Collect” of this Policy serves as notice of the categories of Personal Information we may collect about you and our processing purposes and the section “How We Process Your Personal Information”  provides detail about how we may disclose your Personal Information to others such as Service Providers.  We do not sell Personal Information of Colorado residents and we do not process Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects.

Your Rights to Manage and Control Your Personal Information

Beginning July 1, 2023, you have the right to opt out of the processing of your Personal Information for purposes of targeted advertising. The opt out mechanism will be made available as of the effective date.

Beginning July 1, 2023, you have the right to request access to or deletion of your Personal Information, or to make corrections to inaccuracies. You can initiate a request by clicking on “Verifiable Request Form” or by emailing us at info@truebridgecapital.com.  We may verify your identity through email verification or by other methods as appropriate. You can submit requests regarding inaccuracies by emailing info@truebridgecapital.com. We may limit the disclosure of certain information in an access for your security and safety in accordance with the law and the right to deletion is subject to certain exceptions: for example, we may need to retain certain Personal Information to provide you with the Services or complete a transaction or other action you have requested, or to comply with our legal obligation. You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to do so, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf. You have the right to appeal a decision to deny processing of a request by emailing info@truebridgecapital.com using the subject line: “DSR Appeal”, and you have the ability to contact the Colorado Attorney General if you have concerns about the result of the appeal.

Beginning July 1, 2023, you have the right to opt out of the processing of your Personal Information for purposes of targeted advertising. The opt out mechanism will be made available as of the effective date.

Beginning July 1, 2023, you have the right to request access to or deletion of your Personal Information, or to make corrections to inaccuracies. You can initiate a request by clicking on “Verifiable Request Form” or by emailing us at info@truebridgecapital.com.  We may verify your identity through email verification or by other methods as appropriate. You can submit requests regarding inaccuracies by emailing info@truebridgecapital.com. We may limit the disclosure of certain information in an access for your security and safety in accordance with the law and the right to deletion is subject to certain exceptions: for example, we may need to retain certain Personal Information to provide you with the Services or complete a transaction or other action you have requested, or to comply with our legal obligation. You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to do so, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf. You have the right to appeal a decision to deny processing of a request by emailing info@truebridgecapital.com using the subject line: “DSR Appeal”, and you have the ability to contact the Colorado Attorney General if you have concerns about the result of the appeal.

If we change this Privacy Policy, we will post the updated Privacy Policy and its effective date on this page. If TrueBridge makes material changes that reduce your privacy rights, TrueBridge will notify you in advance by sending you an email and/or by posting a notice in the website.

If you have any questions, comments, or concerns about how we handle your personal information, you may contact us at info@truebridgecapital.com or write to us at: TrueBridge Capital Partners, LLC, Attn: Privacy Inquiries, 1011 South Hamilton Road Suite 400, Chapel Hill, North Carolina 27517.