Privacy Policy

KEIRETSU CAPITAL LLC WEBSITE PRIVACY POLICY

Effective Date: May 1, 2013

YOUR PRIVACY MATTERS

Thank you for visiting www.keiretsucapital.com (this “Site”), which is owned and operated by Keiretsu Capital LLC (“KC”). KC is committed to respecting and protecting your privacy. Please read this Privacy Policy carefully in order to understand what information KC collects about visitors to the Site, and how KC uses that information. If you do not agree with the content of this Privacy Policy, please do not use this Site. We encourage you to check our Site frequently to see the current Privacy Policy and Terms and Conditions of Use in effect and any changes that may have been made to them. If we make material changes to this Privacy Policy we will post the revised Privacy Policy and the revised effective date on this Site. This Policy is part of our Terms and Conditions of Use. Please click here to see that agreement.

TYPES OF INFORMATION COLLECTED BY KC

KC collects two types of information from visitors to the Site, non-personal information and personal information. Non-personal information is information that does not, by itself, identify the visitor as a specific individual. Personal information, is information that identifies a visitor to the Site, or which includes contact information. If you submit a plan to KC, or express interest in the KC Co-Investment and Opportunity Fund, KC may request personal information from you, including your e-mail address. By providing KC with personal information via the Site, you expressly agree to its collection and use as described in this Privacy Policy. You may obtain access to your personal information collected by KC by sending an e-mail to [email protected]

COLLECTION OF INFORMATION

Visitors may access the Site while remaining anonymous and without revealing any personal information. KC may collect information during your visit to the Site through our automatic data collection tools, which may include cookies and other commonly used information-gathering tools. These tools collect certain standard information that your browser sends to our website such as your browser type and language, access times, and the address of the website from which you arrived at a KC website. They may also collect information about your Internet Protocol (IP) address and clickstream behavior (i.e. the pages you view, the links you click, and other actions you take in connection with KC websites).

A “cookie” is a small piece of data stored on a user’s browser, and contains non-personally identifiable information about the user. When you visit the website, KC may place a “cookie” in order to improve your experience by recognizing you when you visit the website and in order to allow the company to optimize the information presented based on your demonstrated areas of interest. Cookies may also be used to compile information about website usage. If you subsequently provide us with personal information such as your email address, we will associate any cookies on your browser with that information such that you will no longer be an anonymous visitor to the site.

CHILDREN’S PRIVACY

KC is committed to protecting the privacy of young children, and therefore does not knowingly collect or maintain personally identifiable information on the Site from persons under 13 years of age, and no part of our website is directed to persons under the age of 13. IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE SITE AT ANY TIME OR IN ANY MANNER. In the event that KC discovers that personal information has been collected from a person under 13 years of age, without verified parental consent in accordance with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), KC will delete such information.

HOW KC USES AND SHARES INFORMATION

KC may use personal information you provide in order to contact you. Because KC is committed to protecting your privacy, KC will not sell, rent or otherwise disclose this information to any third party, except as described in this Privacy Policy. Personal information may be disclosed under the limited circumstances described below, and you agree that KC may do so by submitting your personal information. By providing any personal information to the Site, all users, including without limitation users in the European Union, fully understand and unambiguously consent to the collection and processing of such information in the United States. KC may share non-personal information from which individuals cannot be identified, and which do not relate to individuals in aggregate form, with third parties for business purposes, such as consultants and advisors to the company. KC will disclose your personal information to a third party if required to do so by law or if, in good faith, KC believes that such action is necessary to: (1) comply with the law or with legal process; (2) protect and defend the company’s rights and property or prevent fraud; (3) protect the company against abuse, misuse or unauthorized use of KC’s products or services; or (4) protect the personal safety or property of its personnel, users of this Site or the public. The servers that serve the Site automatically identify a computer by its IP address. If KC, in good faith, determines that you have used the service to menace, threaten, harass, intimidate or otherwise deceptively pose as another person, your actions will be investigated and your IP address may be disclosed to the recipient of any email, their legal counsel or representatives, and law enforcement officials as part of such an investigation. KC may transfer its database, including personal information contained therein, to a third party who acquires all or substantially all of the assets or stock of KC whether by merger, acquisition, reorganization or otherwise.

LINKED WEBSITES

This Site contains links to other websites. Please be aware that KC is not responsible for the privacy practices of such other websites. KC encourages users to be aware when they leave this Site and to read the privacy statements of each website they visit that collects personal information. While KC carefully chooses the websites to link to, this Privacy Policy applies solely to information collected on this Site.