Valterra Partners
Investor Portal Privacy Policy

Valterra Partners, LLC (“Valterra,” “us”, “our” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy.

This privacy policy (this “Policy”) describes how we collect, use, disclose, transfer, store, retain, or otherwise process your information when you use the investor portal made accessible at https://investor.valterrapartners.com/users/sign_in (the “Services”). As described in our Investor Portal Terms of Service, the Services are provided by our fund administrator Gen II Fund Services, LLC (“Gen II”) and its affiliate Update Capital, Inc. (“Update Capital”), not Valterra.

You acknowledge and agree that information collected by Update Capital in connection with your use of the Services and information that you submit through the Services will be made accessible to us or be disclosed to us by Update Capital for use in accordance with this Policy, including to provide our investment related services to you. This Policy therefore applies to your information that we collect directly from you or indirectly from Update Capital.

This Policy applies to information we collect:
•  In connection with your use of the Services.
•  Through any other sources that include links to this Policy.

It does not apply to information collected by:
•  Us offline or through any other means, including on any other website or services operated by Valterra or any third party; or
•  Any third party other than Update Capital, including through any application or content (including advertising) that may link to or be accessible from or through the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Services. By accessing or using the Services, you agree to this Policy.

This Policy may change from time to time. Your continued use of the Services after we make changes is deemed acceptance of those changes, so please check this Policy periodically for updates.

1. Information We Collect About You and How We Collect It
We collect several types of information from and about users of the Services, including information:
•  By which you may be personally identified, such as name, email address, telephone number, and any other identifier by which you may be contacted online or offline (“personal information”);
•  Financial and tax information, such as your payment or bank account details, wire instructions, and W-9 forms, but only when necessary to provide our services to you.
•  That is about you but individually does not identify you; and
•  About your internet connection, the equipment you use to access the Services, and usage details.

We collect this information:
•  Directly when you provide it to us and indirectly when you provide it to Update Capital.
•  Automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

2. Information You Provide to Us
The information we collect on or through the Services may include:
•  Information that you provide by filling in forms to access or use the Services.
•  We may also ask you for information if you report a problem with the Services or submit any inquiries to info@valterrapartners.com. We will retain copies of any email correspondence between you and us.
•  Any information or documents you submit or upload to the Services.

3. Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
•  Details of your visits to the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
•  Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our service offerings and to deliver a better and more personalized service, including by enabling us to:
•  Estimate our audience size and usage patterns.
•  Store information about your preferences, allowing us to customize our Services.
•  Speed up your searches.
•  Recognize you when you return to the Services.

The technologies we use for this 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 the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Services.
•  Web Beacons. Certain webpages and emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that enable the ability to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

4. How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
•  To present the Services and its contents to you.
•  To provide you with information and services that you request from us regarding your investments.
•  To fulfill any other purpose for which you provide it.
•  To provide you with notices.
•  To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
•  To notify you about changes to the Services or our investment services.
•  To facilitate services we receive from our professional advisors, such as lawyers, accountants, auditors and consultants or other service providers (such as archiving, security services, IT, printing or other).
•  In any other way we may describe when you provide the information.
•  For any other purpose with your consent.

5. Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:
•  To our subsidiaries and affiliates.
•  To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
•  To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
•  To fulfill the purpose for which you provide it.
•  For any other purpose disclosed by us when you provide the information.
•  With your consent.

We 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 our agreements with you, including for billing and collection purposes.
•  If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Valterra, our investors, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

6. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
•  Tracking Technologies and Advertising. 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.
•  Promotional Offers from the Valterra. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Valterra as a result of an investment or other transaction.

We do not control third parties’ collection or use of your information to serve interest-based advertising.

7. Accessing and Correcting Your Information
You may send us an email at info@valterrapartners.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your Account and access to the Services. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

8. Information Security
We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your personal information in our possession or under our control. If you have any questions about security of the Services, you can email us at info@valterrapartners.com.

The transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services. Any transmission of personal information is at your own risk.

9. Changes to Our Privacy Policy
It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will notify you by email to the email address specified in your Account or through a notice posted on the Services or our website. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

10. Contact Information
If you have any questions about this Policy, you may contact us via email at info@valterrapartners.com.

Last Updated: April 8, 2024