Effective Date: July 22, 2019

Below is our privacy policy, which only covers the collection of information through Threshold.com (referred to herein as our “website,” and the users thereof, our “visitors”) and our own use of that information; it does not apply to the practices of companies we do not own or control, or people that we do not directly manage. For example, it does not cover the practices of any entity with whom we (or any of our affiliates) have an investment relationship, even if visitors are able to access such entity’s website or service through a link on our website.

Website Visitors and Aggregate Usage Information

Like most website operators, Threshold collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, the date and time of each visitor request, and other usage information and aggregate statistics. Threshold’s purpose in collecting non-personally identifying information is to better understand how Threshold visitors use its website. From time to time, Threshold may release non-personally-identifying information in the aggregate in a public manner, e.g., by publishing a report on trends in the usage of its website, or may otherwise share this aggregate information with whomever it deems appropriate. However, Threshold only discloses personally-identifying information as described in “Protection of Personally-Identifying Information” below.

Gathering of Personally-Identifying Information and Confidential Information

Certain visitors to Threshold’s website choose to interact with Threshold in ways that require Threshold to gather personally-identifying information. The amount and type of information that Threshold gathers depends on the nature of the interaction. In each case, Threshold collects such information only insofar as is necessary or useful to fulfill the purpose of the visitor’s interaction. Threshold does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.

Visitors to our website must not provide any information to us that they consider to be proprietary or a trade secret, or which they desire to be treated as confidential, including any proprietary information regarding businesses in which they wish to obtain Threshold’s investment. Threshold does not agree to any obligation of confidentiality, non-use or non-disclosure with respect to information submitted to Threshold via the website or in connection with a visitor’s use thereof. By submitting information or materials to Threshold, each visitor understands, acknowledges and agrees that such information and/or materials will not be treated as confidential or proprietary. Threshold undertakes no obligation to review any such information or materials, or to return the same to the submitting person or entity. Threshold may receive information that is similar to such information or materials, or may have already received information containing ideas and plans that are the same as or similar to ideas and plans contained in such information or materials. In no event shall Threshold be limited in, or restricted from, the pursuit of any opportunities, either alone or with third parties, including any of its affiliated funds.

Protection of Personally-Identifying Information

Threshold discloses [potentially personally-identifying and ]personally-identifying information to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Threshold Global Network’s behalf or to provide services available at Threshold’s website, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of a visitor’s home country; by using Threshold’s website, each visitor consents to the transfer of such information to them. Threshold will not rent or sell [potentially personally-identifying and] personally-identifying information to anyone. Threshold also discloses potentially personally-identifying and personally-identifying information in response to a subpoena, court order or other governmental request, or when Threshold believes in good faith that disclosure is reasonably necessary to protect the property or rights of Threshold, its personnel, third parties or the public at large. Threshold takes reasonable measures to protect against the unauthorized access, use, alteration or destruction of [potentially personally-identifying and] personally-identifying information, but cannot guarantee complete security.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Threshold uses cookies to help Threshold identify and track visitors, their usage of Threshold website, and their website access preferences. Threshold visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Threshold’s website, with the drawback that certain features of Threshold’s website may not function properly without the aid of cookies.

Business Transfers

If Threshold, or substantially all of its assets, were acquired, or in the unlikely event that Threshold goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. Each visitor acknowledges that such transfers may occur, and that any acquirer of Threshold may continue to use personally-identifying information as set forth in this policy.

Privacy Policy Changes

Although most changes are likely to be minor, Threshold may change its Privacy Policy from time to time, and in Threshold’s sole discretion. Threshold encourages visitors to frequently check this page for any changes to its Privacy Policy, which are binding on our visitors as soon as they are posted to the website.9, 2019