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Legal notice

Terms of Use

Effective Date: January 29, 2021

Please read the terms and conditions in this Terms of Use agreement (the “Agreement”)
carefully. By accessing or otherwise using this website ( (the “Site”),
you agree to be bound by the terms and conditions in this Agreement. If you do not accept
these terms and conditions, do not use this Site.

This Agreement is a contract between you and Liberset Holdings S.a.r.l, Liberset Management
LLC and its affiliates (referred to below as “Liberset” or “we” or “us”), and applies only to this
Site and not to other Sites that may be accessible from or linked to this Site. We are responsible
only for the content of our own Site. We encourage you to review the user agreements of all
other Sites that you visit.

Liberset may change this Agreement from time to time, at our sole discretion. If we make any
substantial changes in this Agreement, we may notify you by reasonable means, including by
posting a prominent announcement on our home page. Please check this page regularly to
ensure that you are familiar with the current version of the Agreement. By your continued use
of the Site after publication of the revised Agreement, you accept and agree to the terms and
conditions in the revised Agreement.

Restrictions on Use

While using the Site, you agree to comply with this Agreement and all applicable laws, rules andregulations, and will not encourage or promote any activity that violates this Agreement.
By accessing or otherwise using the Site, you agree that you will not under any circumstances:

  1. copy or print material from the Site (including but not limited to individual Site pages or
    any research or reports posted on the Site) for commercial purposes without our prior
    permission. You must also get our permission before making more than minimal copies
    of Site materials or copying large portions of the Site. Any use of Site materials must not
    alter the original Site content, including all legal notices and legends. If you seek
    permission for such use of our Site, please contact us at;
  2. link to or frame this Site or any portion thereof;
  3. interfere or attempt to interfere with the proper functioning of the Site;
  4. interfere or attempt to interfere with the Site’s networks or network security, or attempt to use the Site to gain unauthorized access to any other computer system;
  5. make any automated use of the Site, or take any action that we deem to impose or to potentially impose an unreasonable or disproportionately large load on our serves or network infrastructure;
  6. bypass any measures we take to restrict access to the Site or use any software,
    technology or device to scrape, spider, or crawl the Site or harvest or manipulate data;
  7. publish or link to malicious content.

No Offer or Advice

You acknowledge that the content of the Site is for general, informational purposes only and is
not intended to constitute an offer to sell or buy any securities or other assets or promise to
undertake or solicit business and may not be relied upon in connection with any offer or sale of
securities or other assets. Offers can only be made where lawful under, and in compliance
with, applicable law. We make no representations that any information provided via the Site is
accurate, current, reliable or complete. You are solely responsible for evaluating the risks and
merits regarding the use of the Site and any services provided herein. We are not utilizing the
Site to provide investment, legal, accounting, tax or other professional advice, and nothing on
the Site is to be deemed a recommendation that you buy, sell or hold any security or other
investment or that you pursue any investment style or strategy. If you would like investment,
accounting, tax or legal advice, you should consult with your own advisors with respect to your
individual circumstances and needs. Any transactions listed on the Site are included as
representative transactions and are not necessarily reflective of overall performance.

All investments involve risk and may lose value. The value of your investment can go down
depending upon market conditions. Fixed income investments are subject to risk including
interest rate, credit, market and issuer risk. Currency exchange rates may cause the value of an
investment to go up or down. Alternative strategies involve higher risks than traditional
investments, may not be tax efficient, and have higher fees than traditional investments; they
may also be highly leveraged and engage in speculative investment techniques, which can
magnify the potential for investment loss or gain. BEFORE ACQUIRING THE SHARES OF ANY

Forward-Looking Statements and Past Performance

The contents of the Site may contain forward-looking statements that are based on beliefs,
assumptions, current expectations, estimates, and projections about the financial industry, the
economy, Liberset itself or its investments. These statements are not guarantees of future
performance and involve certain risks, uncertainties and assumptions that are difficult to
predict with regard to timing, extent, likelihood and degree of occurrence. Therefore, actual
results and outcomes may materially differ from what may be expressed or forecasted in such
forward­-looking statements. Furthermore, Liberset undertakes no obligation to update, amend
or clarify forward-looking statements, whether as a result of new information, future events or
otherwise. Furthermore, past performance is not indicative of future results; no representation
is being made that any investment will or is likely to achieve profits or losses similar to those
achieved in the past, or that significant losses will be avoided.

Privacy Notice and Cookies Policy

Your privacy is important to us. You can learn how we handle your information when you use
the Site by reading our Privacy Notice located at Privacy Notice and Cookies Policy located at
Cookies Policy. We encourage you to become familiar with the Privacy Notice and Cookies
Policy because by using the Site, you consent to the collection, use, disclosure and other
handling of information consistent with those policies.


The Site and all content included on the Site, such as graphics, logos, articles and other
materials, is the property of Liberset or others and is protected by copyrights, trademarks and
other intellectual property rights owned by Liberset or third parties that have licensed their
materials or provided services to us. Liberset reserves all of its intellectual property rights in
the Site and in the content included on the Site, and this Agreement does not grant you any
right or license with respect to any such intellectual property. You agree not to sell, license,
copy, reproduce, modify, republish, transmit, edit, adapt, create derivative works from,
distribute or otherwise make unauthorized use of any such intellectual property from the Site
without express written permission from Liberset. You agree not to reverse-engineer,
decompile, disassemble or otherwise attempt to extract or discover the source code of the Site
or any part thereof, except and only to the extent that such activity is expressly permitted by
applicable law notwithstanding this limitation.

Notice of Copyright Infringement

The Digital Millennium Copyright Act of 1998 provides recourse for copyright owners who
believe that material posted on Internet sites infringes their rights under U.S. copyright law. If
you believe in good faith that items, information or other materials appearing on the Site
infringes your copyright, please send us a notice containing the following information:

  1. A physical or electronic signature of a person authorized to act on behalf of the owner
    of an exclusive right that is allegedly infringed.
  2. Identification of the copyrighted work claimed to have been infringed, or, if multiple
    copyrighted works are covered by a single notification, a representative list of such
  3. Identification of the material that is claimed to be infringing or to be the subject of
    infringing activities and that is to be removed or access to which is to be disabled, and
    information sufficient to permit us to locate the material.
  4. Contact information for the notifying party, including name, address, telephone
    number, and email address.
  5. A statement that you have a good faith belief that use of the material in the manner
    complained of is not authorized by the copyright owner, its agent, or the law.
  6. A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Please submit this notice to Liberset at


As our Site indicates, we welcome your questions about us and our financial products and
services. Please be advised that any comments, suggestions, ideas or any other information
that you send to us through our Site (collectively, your “User Information”) may not be treated
as confidential. You hereby grant, and agree to grant, to Liberset an unrestricted, worldwide,
irrevocable, non-exclusive, perpetual, fully-paid, royalty-free, transferrable license to access,
view, display, reproduce, adapt, publish, translate, store, host, cache, maintain, modify,
distribute, and otherwise use and exploit your User Information in any manner, provided that it
is in accordance with the Privacy Notice. You also grant Liberset the right to sub-license these
rights through multiple tiers, and the right to bring an action for infringement of these rights.

Third Party Content

Much of the content on the Site is produced by users, publishers, and other third parties and is
not controlled by Liberset. You acknowledge that such content is the sole responsibility of the
third-party person or organization that created it and we assume no responsibility for any third-
party content or information. Although Liberset reserves the right to review all content and
information that appears on the Site and to remove any content or information at Liberset’s
discretion, we do not necessarily review all or any of it. Access and use of third-party content
made available through the Site is solely at your own risk and Liberset makes no warranties,
express, statutory, or implied, with respect to such third-party content or information. This
Agreement does not govern your use of any site or service other than the Site. You should
review applicable terms and policies of any linked third-party content, information or websites.
To the maximum extent permitted by applicable law, we will not be liable for any content
submitted, posted, linked to, shared or otherwise made available via the Site, including, but not
limited to, any inaccuracies, errors or omissions in any content, any intellectual property
infringement with relation to the linked content, or any loss or damage of any kind incurred as
a result of the use of any content linked in or otherwise made available via the Site.

Statement Regarding Internet Phishing and Fraud

Please be aware that bad actors may attempt to misuse Liberset’s name, brands and reputation
by publishing fake websites and engaging in phishing scams seeking personal or confidential
information. Liberset does not authorize such misuse of its name, brands and reputation and
investigates these matters to ensure that its legal rights and reputation are protected.

When you communicate with Liberset through a mobile or digital media platform, please
remember the following, especially before disclosing personal information:

  • Confirm that you are visiting a website authorized by Liberset.
  • Communicate only with individuals who are affiliated with an authorized office of
    Liberset. A listing of Liberset’s authorized office locations is available on our “Contact
    Us” page.
  •  Employees and authorized representatives of Liberset are only permitted to use an
    authorized email address of Liberset to conduct business on behalf of Liberset.
    Authorized email addresses of Liberset use “” Do not send emails to
    anyone claiming to be an employee or authorized representative of Liberset if they do
    not use an authorized email address of Liberset.

Do not share your password or login information with anyone, including anyone from Liberset.
Aside from the operation of certain private websites that are only available to investors through
a secure login procedure, Liberset will never ask you for your password or login information.
Please refer any questions regarding this information to

International Use

Due to the global nature of the Internet, this Site may be accessed by users in countries other
than the United States. We make no warranties that materials on this Site are appropriate or
available for use in such locations. If it is illegal or prohibited in your country of origin to access
or use this Site, then you should not do so. Those who choose to access this site outside the
United States do so on their own initiative and are responsible for compliance with all local laws
and regulations.





Limitations of Liability

To the maximum extent permitted by law, you agree to indemnify, defend and hold harmless
Liberset, its managing members, licensors, officers, directors, employees, agents, trustees,
subsidiaries, parent companies and affiliates (the “Indemnitees”) from and against all third
party complaints, charges, claims, losses, expenses, damages, costs, liabilities and expenses
(including, but not limited to, reasonable attorneys’ fees) due to, arising out of, or relating in
any way to: (a) your access to or use of the Site and (b) your breach of this Agreement, in each
case unless caused by such Indemnitee’s misrepresentation, gross negligence, willful
misconduct or fraud.

Governing Law

You agree that your use of this Site, the Privacy Notice and this Agreement and any disputes
relating to any of them shall be governed in all respects by the laws of the State of Delaware.
Any dispute relating to the above shall be resolved solely in the state or federal courts located
in Wilmington, Delaware.


This Agreement is effective unless and until terminated by either you or Liberset. You may
terminate this Agreement at any time, provided that you discontinue any further use of the
Site. We also may terminate this Agreement, in our sole discretion, at any time and may do so
immediately and without notice, and accordingly deny you access to the Site. The following
provisions survive the expiration or termination of this Agreement: No Offer or Advice;
Forward-Looking Statements and Past Performance; Ownership; Submissions; Third Party
Content; Disclaimers; Limitation of Liability; Indemnity; Governing Law; and Miscellaneous.


If a portion of this Agreement is determined to be unlawful, void or unenforceable, it will not
affect the enforceability of the remaining provisions and the remaining provisions will continue
in effect. If any unlawful and/or unenforceable provision would be lawful or unenforceable if
part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will

continue in effect. Headings used in this Agreement are for reference purposes only and in no
way define or limit the scope of the section.

Accessibility Statement

Liberset strives to provide individuals with disabilities with equal access to its programs and
activities, including through an accessible website. If you have questions, comments, or
encounter any difficulty in using this site, please e-mail

Contact Us

Thank you for visiting our Site. Please contact us at if you have any
questions about our Site or our Privacy Policy and User Agreement.

Privacy Policy
Effective Date: January 29, 2021

This Privacy Notice is provided by Liberset (“Liberset”, “we” and “us”), and it applies to ways in
which we interact with individuals, (“Data Subjects”) in connection with our business, including,
without limitation:

  • directors, officers, employees and other representatives of portfolio companies in which
    Liberset has made an investment or is considering making an investment;
  • individual representatives of third-party sellers, placement agents, finders, investment
    bankers, consultants, lawyers, accountants, advisers and other service providers,
    whether or not engaged by Liberset;
  • directors, officers, employees and other representatives of Liberset;
  • individuals applying for or enquiring about and employment with us;
  • individuals who consider or do invest with us and their representative agents with
    whom we interact during the normal course of business; and
  • visitors to our websites and users of any digital services we provide.

We respect the privacy of Data Subjects. This Privacy Notice describes how we collect, use,
store, process, disclose and transfer information that we may collect from Data Subjects.
Please note that Liberset may provide additional privacy notices or similar disclosures in respect
of certain categories of Data Subjects (e.g., certain investors or prospective investors in a fund
managed or advised by Liberset, certain former or existing employees associated with Liberset,
etc.), and certain geographies and jurisdictions.


What data do we collect and how?

Personal Data. When we use the term “Personal Data” we mean information that reasonably
can be used to identify you as an individual person. In connection with our business, we collect
various types of Personal Data, including, among other things:

  • Identifiers such as your name, postal address, tax ID, passport number, internet protocol
    address, email address, account name, social security number, driver’s license number,
    mail address, phone number, or other similar identifiers.
  • Information classified as personal or protected information by state, federal, or other
    applicable law, including your nationality, place and date of birth, gender, picture,
    marital status, number of children, and information on criminal history/unlawful
  • Commercial information, including tax information, bank account details, credit card
    number, money transfers including communications on bank transfers, assets, investor
    profile, credit history, debts and expenses.
  • Internet or other electronic network activity information, including, but not limited to,
    browsing history, search history, and information regarding a consumer’s interaction
    with an internet website, application, or advertisement.
  • Visual information, including your picture.
  • Professional or employment-related information, including your employment,
    employer’s name, and remuneration.
  • Education information, including your level of education.

We collect this Personal Data in various ways, including:

  • Directly from the Data Subject (e.g., when you voluntarily submit information to the
    Site, or send us an email or other written correspondence)
  • Indirectly from other sources (e.g., from public records or from a counterparty in
    possession of the data).

If you are located outside of the United States, please be aware that the Personal Data we
collect will be processed and stored in the United States, a jurisdiction in which the data
protection and privacy laws may not offer the same level of protection as those in the country
where you reside or are a citizen.

How and on what basis do we use your Personal Data?

We use your Personal Data for a variety of reasonable and legitimate business purposes,
including, but not limited to, the following:

  • Complying with legal or regulatory obligations, such as our obligations regarding know-
    your-client and anti-money laundering;
  • Performing a contract with you or to take steps at your request before entering into a
    contract, including to: (i) provide you with information regarding Liberset products or
    services, (ii) assist you and answer your requests, (iii) evaluate whether we can offer you
    a Liberset product or service and under what conditions;
  • Other legitimate purposes, such as:
    o Communicating with Data Subjects;
    o Performing activities relating to client management, financial management and
    o Creating, improving and developing our products and services;
    o Conducting market research, surveys, and similar inquiries to help us understand
    trends, client and Site visitor needs;
    o Investigating and resolving disputes and security issues and enforcing our Terms
    of Use and other agreements;
    o Monitoring and auditing compliance with internal policies and procedures, legal
    obligations and to meet requirements and orders of regulatory authorities; and
    o Processing and considering applications for employment, including evaluating
    and confirming your suitability for the position and accuracy of any information

We will not use your Personal Data for any purposes inconsistent with this Privacy Notice
without your permission.

We do not sell any personal data and have not sold any personal data in the past.

With whom do we share your Personal Data?

Within Liberset. We share your Personal Data among Liberset entities for the purposes set
forth above. In general, our group entities, in turn, are not permitted to share your information
with other non-affiliates entities, except as described herein or otherwise permitted by
applicable laws.

To Third Parties. We share your Personal Data with third parties in certain circumstances,
including the following:

  • Service Providers. We share Personal Data with service providers that perform services
    on our behalf (e.g., third-party service providers to operate the Site). These companies
    may have access to your Personal Data but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. We generally require
    these providers by contract to keep the information confidential.
  • Transaction or Other Corporate Event. Your Personal Data can be disclosed as part of a
    corporate business transaction, such as a merger, acquisition, joint venture, or financing
    or sale of company assets, including bankruptcy proceedings, and could be transferred
    to a third party as one of the business assets in such a transaction. It also can be
    disclosed in the event of insolvency, bankruptcy or receivership. In such an event, we
    will post prominent notice of the change in ownership.
  • As Required by Law. We also disclose your Personal Data if we are required to make
    disclosures by applicable law or to the government or private parties in connection with
    a lawsuit, subpoena, investigation or similar proceeding, or as part of our legislative or
    regulatory reporting requirements.

How do we protect your Personal Data?

We take seriously the obligation to safeguard your Personal Data. Your Personal Data held by
us will be kept confidential in accordance with applicable Liberset policies and procedures. We
will use all reasonable efforts to ensure that all Personal Data is kept secure and safe from any
loss or unauthorized disclosure or use. All reasonable efforts are made to ensure that any
Personal Data held by us are stored in a secure and safe place, and accessed only by our
authorized employees and transferees.

Keeping your Personal Data current

In general, we seek to ensure that we keep your Personal Data accurate and up to date.
However, you are responsible for, and we kindly request that you inform us of, any changes to
your Personal Data (such as a change in your contact details). To update or edit your Personal
Data that we have on file, including your communication preferences, please contact us using
the contact details set out under the “Contact and Complaints” heading below or by sending an
e-mail to

How long do we keep your Personal Data?

In general, we will process and store your Personal Data for at least as long as it is necessary in
order to fulfil our contractual, regulatory and statutory obligations. Subject to those
qualifications, our goal is to keep such data for no longer than necessary in relation to the
purposes for which we collect and use the Personal Data (we refer to the purposes as set forth
above). Liberset will retain your Personal Data in accordance with our Data Retention Policy. If
you have any specific questions in this respect, please feel free to contact us.

Contact and Complaints

Liberset takes very seriously any complaints we receive about our use of your Personal Data.
Questions, comments, requests or complaints regarding the Site, this Privacy Notice, the User
Agreement and/or our use of your Personal Data should be addressed to
Any Personal Data we receive from you when making a complaint will be treated in accordance
with this Privacy Notice and only to process the complaint and check on the level of service we
provide. Similarly, where inquiries are submitted to us, we will only use the information
supplied to us to deal with the inquiry and any subsequent issues and to check on the level of
service we provide.


The Site


Please be aware that the Site may contain links to other websites hosted by third parties.
Liberset does not control and is not responsible for the content or privacy practices and policies
of such third-party websites. We encourage you to be aware when you leave the Site and to
read the privacy policies of each third-party website, especially if such website collects Personal
Data from you.

Additional Information for Job Applicants

This Applicant Privacy Notice pertains to certain individuals applying to become employees or
members associated with Liberset. Questions, comments, requests or complaints regarding
this Privacy Notice and/or our use of your Personal Data should be addressed to

Additional Information for Residents of the European Economic Area (the “EEA”)

The below information applies to any Data Subject resident in the EEA. For purposes of the
General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the
Council of 27th April 2016 (the “GDPR”), we act as a “data controller” and our office is located
in the United States at Liberset Management Luxembourg Sarl, 9 Rue de Bitbourg, L-1273 Luxembourg. As a data controller, we are responsible for deciding
how we hold and use Personal Data about you.

GDPR Data Protection Principles

In respect of the collection, holding, storage, use, and processing of your Personal Data:

  • We will process the data lawfully, fairly and in a transparent way.
  • We will obtain the data only for valid purposes that we have clearly explained to you
    and not used in any way that is incompatible with those purposes.
  • The data we collect will be relevant to the purposes we have told you about and limited
    only to those purposes.
  •  We will take reasonable steps to ensure that the data is accurate and kept up to date.
  • Subject to applicable legal or other requirements, we will keep the data only as long as
  • We will use appropriate technical and/or organizational measures to ensure appropriate
    security of the data.

Transfer of Personal Data Outside of the EEA

The transfer of Personal Data from the UK/EEA to the Liberset entities outside the EEA is
governed by data transfer agreements which are in the form of the standard contractual
clauses approved by the European Commission (a copy of which can be obtained from us via
the contact details below).
Where your Personal Data is processed by third parties outside the EEA, we will ensure
appropriate safeguards are in place to adequately protect it, as required by applicable law,
including the execution of standard contractual clauses (referred to above) if the recipients are
not located in a country with adequate data protection laws (as determined by the European
Commission) or certified under the EU-US Privacy Shield framework.

GDPR Data Subject Rights

Under the GDPR, in certain circumstances, an EEA-resident Data Subject has certain individual
rights with respect to the Personal Data that we hold about them. In particular, you may have
the right to:

  • Request access to any data held about you
  • Ask to have inaccurate data amended
  • Request data held about you to be deleted, provided the data is not required by Liberset
    to perform a contract, defend a legal claim or to comply with applicable laws or
  • Prevent or restrict processing of data which is no longer required
  • Request transfer of appropriate data to a third party where this is technically feasible
  • Additionally, in the circumstances where you may have provided your consent to the
    collection, processing and transfer of your Personal Data for a specific purpose, you
    have the right to withdraw your consent for that specific processing at any time. Once
    we have received notification that you have withdrawn your consent, we will no longer
    process your information for the purpose or purposes you originally agreed to, unless
    we have another legitimate basis for doing so in law.

To exercise any of these rights, please contact us using the contact details set out under the
“Contact and Complaints” heading above.

Automated Decision Making

We respect your legal rights not to be subject to decisions that are based solely on automated
processing of your Personal Data, including profiling, especially where such processing has legal
or other significant effects on you. In establishing and carrying out a business relationship, we
generally do not use any automated decision making pursuant to the GDPR. We may process
some of your Personal Data automatically, with the goal of assessing certain personal aspects
(profiling), such as to comply with legal or regulatory obligations to combat money laundering,
terrorism financing, and offenses that pose a danger to assets.

Complaints to Local Authorities

As a resident of the EEA, you are also entitled to direct any complaints in relation to our
processing of your Personal Data to your national or local data protection supervisory authority.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request for access is clearly
unfounded or excessive.


Additional Information for Residents of California

The information below may apply to Data Subjects who are residents of California.
California’s “Shine the Light” law permits California residents to annually request and obtain
information free of charge about what Personal Information is disclosed to third parties for
direct marketing purposes in the preceding calendar year. For more information on these
disclosures, please contact us using the contact details set out under the “Contact and
Complaints” heading above.
In addition, Data Subjects in California may have a right under the California Consumer Privacy
Act (“CCPA”) to request erasure of their personal data or access to personal data that we have
collected in the last twelve (12) months.
You may submit requests for access or erasure of your personal information by contacting us at

Individuals who submit requests for access or erasure of personal information will be required
to verify their identity by answering certain questions. We will not disclose or delete any information until identity is verified.

If you are making a request for access, we may not be able to provide specific pieces of
personal information if the disclosure creates a substantial, articulable, and unreasonable risk
to the security of your personal information, your account with us, or our systems or networks.

If you are making a request for erasure, we will ask that you confirm that you would like us to
delete your personal information again before your request is addressed.

You may designate an authorized agent to submit a request on your behalf by providing that
agent with your written permission. If an agent makes a request on your behalf, we may still
ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals, will be required to verify the request by
submitting written authorization from the individual. We will not honor any requests from
agents until authorization is verified.

Under the CCPA, you cannot be discriminated against for exercising your rights to access or
request erasure of their personal data.

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