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DISCLAIMER

 

All information contained herein is for informational purposes and should not be construed as investment advice.  The information provided on this page, including any information regarding Arena Digital Capital Management, LLC (“Arena Digital”) portfolio investments, is not intended to recommend any investment and is not an offer or sale of any security or investment product or investment advice.  Arena Digital provides investment advisory services to a variety of clients.  Arena Digital does not solicit or make its services available to the public.  Any offer or solicitation by Arena Digital will be made to qualified investors only by means of official documentation and only in those jurisdictions where permitted by law.

 

This website is prepared for information purposes only and should not be construed as legal, tax, investment or other advice.  It does not constitute an offer to sell, or a solicitation of an offer to buy, any interest in any product managed by Arena Digital (or any affiliate) or any other security.  Any such offer will made only to qualified investors, only by means of a confidential offering memorandum and other related documents and then only in those jurisdictions where permitted by law.  Consult your own attorney, business advisor and tax advisor as to legal, business and tax advice.  The information contained herein does not purport to be complete, is qualified in its entirety by the applicable fund documentation and is subject to change without notice.  All investments involve risk, including the loss of principal.  Past performance is no guarantee of future results.

 

It should not be assumed that all investments identified and described herein were or will be profitable.  Statements, opinions, general market performance and related commentary are based on sources of information believed to be accurate and reliable, but Arena Digital makes no representations or guarantees as to the accuracy or completeness thereof.

 

PRIVACY POLICY

 

Policy.  This Website is a website operated by Arena Digital. Arena Digital recognizes and appreciates the importance of respecting the privacy of users of this Website and is committed to safeguarding against unauthorized disclosure of, or access to, users’ personal information. This “Privacy Policy” sets forth Arena Digital’s current policies and practices with respect to personal information of the users of this Website. This Privacy Policy may change over time. Use of this Website after such change of Policy signifies your consent to such additional uses.

 

Data Subjects. This Privacy Policy applies directly to individuals who are data subjects in their interactions with Arena Digital. If business entities provide Arena Digital with personal data on individuals (e.g., employees, members, etc.) in relation to a relationship with Arena Digital, this Privacy Policy will apply to those individuals and such entity should transmit this document to such individuals or otherwise advise them of its content.

 

Data Types. In this Privacy Policy, “personal data” refers to any data related to an identified or identifiable data subject. Arena Digital may collect personal data including name, contact details (address, telephone, fax, email – both private and professional), date of birth, social security number, taxpayer identification number, bank account details, jurisdiction of tax residence, current or former employers, work authorization status, education, business activities, affiliations, investment objectives, assets, investment experience, transaction history, income, wire transfer instructions, signatures, and member portal login credentials.

 

Data Collection. Arena Digital may collect personal data provided directly by data subject when entering into an investment advisory contract, buying securities from Arena Digital through one or more of its investment funds, advising Arena Digital where to send money or write transfers, entering data at the Website or other sites owned by Arena Digital, communication via Arena Digital’s member portal, manager portal, email, phone, or other correspondence, or as otherwise voluntarily provided by the data subject. Data subjects control what personal data they choose to disclose to Arena Digital, but Arena Digital may be unable to provide certain information or services if relevant personal data is not provided. Arena Digital may also collect personal data from third-party sources, affiliates, or non-affiliated companies, such as information from recruiting services providers or others regarding candidates or potential candidates for employment.

 

Arena Digital may automatically collect information (“automatically collected data”) when data subjects visit its Website. This information may include device type, browser type, Internet Protocol (IP) address, pages visited, download errors, date and time of visit, and interaction with the Website. Automatically collected data may be obtained via tracking technologies, such as cookies, tracking pixels, web server logs, JavaScript and other tools and used to better understand, customize, and improve the user experience of Arena Digital’s Website and services. Data subjects’ website browsers can be set to allow them to control whether they will accept cookies, reject cookies, or to notify them each time a cookie is sent to them. If their browser is set to reject cookies, the Website may not recognize data subjects when they return to the Website, and some Website functionality may be lost. To find out more about cookies, including how to see what cookies have been set and how to manage or delete them, data subjects may visit www.allaboutcookies.org.

 

Data Usage. Arena Digital may use personal data: to communicate and respond to inquiries from data subjects,  to provide advisory services,  to open data subjects’ accounts or process transactions for such accounts (and to evaluate eligibility for accounts and participation in funds),  to contact data subjects with information or promotional materials about Arena Digital,  for recruitment and talent management,  to develop new products or services,  to review usage of and enhance experience with its Website,  to operate, evaluate, and improve its business, and  to comply with and enforce applicable regulatory and legal requirements and industry standards.

 

To opt-out of any marketing emails from Arena Digital, data subjects should follow the unsubscribe or opt-out instructions in such emails, and Arena Digital will use commercially reasonable efforts to promptly implement such requests. Data subjects may continue to receive non-marketing communications related to administrative or transactional matters regarding their existing relationship with Arena Digital.

 

Data Sharing.  Arena Digital does not sell personal data to any third parties. Arena Digital may share personal data as needed to fulfill the purposes described in the “Data Usage” section above, including: with nonaffiliated persons and entities that assist it in managing and operating its funds and investments, including attorneys, tax advisors, broker-dealers, fund administrators, accountants, auditors, and custodians that assist Arena Digital with the distribution of stock to clients and/or investors; to lenders who provide financing for relevant funds; to Arena Digital affiliates, for marketing purposes  unless the data subject has opted out of such sharing, or for purposes of facilitating a data subject’s investments or requests for information; to the relevant funds in which a data subject has invested or is interested in investing; as permitted or required by law, including to verify eligibility under OFAC, for governmental permits or licensing, or other regulatory and compliance requirements; or as requested or approved by the applicable data subject (including to such data subject’s advisors, which can include, among others, accountants, investment advisors, and/or attorneys).

In the event of a merger, consolidation, sale, or transfer of all or substantially all of Arena Digital’s assets or business, one of the assets which would generally be transferred is the personal data that has been collected. Arena Digital will advise a successor or successors in interest of the terms of this Privacy Policy and the expectation that such successor(s) will comply with the terms hereof.

Arena Digital requires third-party service providers to protect the confidentiality of data subjects’ information and to use the information only for the purposes for which Arena Digital discloses the information to them.

 

Data Security.  Arena Digital takes commercially reasonable physical, administrative, and technical precautions designed to protect data subjects’ personal data from loss, misuse, or unauthorized alteration. While Arena Digital uses reasonable efforts to safeguard the confidentiality of data subjects’ personal data, it cannot guarantee that data will always remain secure due to transmission errors, outside events, third party hacking or other causes.

 

Arena Digital restricts access to any nonpublic personal data about data subjects to those employees who need to know that information to provide services to the partnership and its investors.

Arena Digital will typically maintain personal data so long as it can reasonably foresee such personal data may be required in connection with its relationship with the applicable data subject. Arena Digital may retain personal data for a longer period as necessary to comply with any applicable legal or regulatory requirements and reasonable records retention policies or as otherwise necessary for a legitimate reason (such as to resolve disputes and enforce its agreements and contracts).

Data Access. Data subjects may request access and correction of personal data held by Arena Digital. Data subjects may also request erasure of their personal data (subject to any applicable legally required or permitted retention standards). To request access to, correction of, or erasure of personal data, data subjects should contact Arena Digital as set forth at the end of this Privacy Policy. In the case of a request to exercise one of the above listed rights, data subjects may be required to submit a valid personal identification proof to Arena Digital. Arena Digital will deal with such requests in accordance with applicable law and process the request within the time provided by applicable law.

Children. Arena Digital’s Website and services are not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided Arena Digital with personal data, they should contact Arena Digital as set forth at the end of this Privacy Policy and Arena Digital will take reasonable steps to promptly remove such data from its systems (subject to any applicable, legally required or permitted retention standards).

 

California Residents. California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request: information regarding their personal data Arena Digital has collected (the categories of personal data collected, the source of such data, and how such data has been used); a description of whether Arena Digital has disclosed their personal data to third parties, and if so what categories of data have been disclosed, and to what categories of third parties); a copy of their personal data collected by Arena Digital in the past 12 months; and that their personal data be deleted. To make such a request, California residents should contact Arena Digital as set forth below. Arena Digital may require verification of the data subject’s identity before further processing the request. In certain instances, Arena Digital may be required or permitted by law to decline some or all of such request. Contact. Should data subjects have any questions, comments or concerns about Arena Digital’s privacy practices or wish to exercise any of their rights under this Privacy Policy, they can contact general@arenadigital.capital.

 

Policy Updates. This Privacy Policy may be updated to reflect changes in its practice or to comply with applicable laws. Arena Digital will notify data subjects of any material changes to this Privacy Policy, as required by law, including by posting the updated version on the Website. The revised Policy will be effective immediately upon posting to the Arena Digital Website.

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