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Terms of Use and Other Disclosures

The Terms of Use and Other Disclosures (“Terms of Use”) set forth below apply to this website (collectively, the “Site”).Please read the following Terms of Use before using the Romero Capital, LLC and its affiliates (“Romero”) website or any data, products, materials, information, or services contained on this website. Should you not agree with any of the Terms of Use contained herein, then do not use this website. Romero may change the Terms of Use at any time, without prior notice. It is your responsibility to review Romero’s Terms of Use on a periodic basis.
This Site is offered to you conditioned on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of this Site constitutes your agreement to all such terms, conditions, and notices.  Romero makes every effort to use reliable information, but cannot make any representations as to the accuracy or completeness of any information contained herein and such information should not be relied upon as such. Romero has no obligation to inform a visitor when information contained herein changes or is updated. Romero disclaims any and all liability relating to this information, including, without limitation, any express or implied representations or warranties for statements or errors contained in, or omissions from, or the timeliness of, these materials.

This information has been prepared solely for informational purposes and does not constitute an offer to sell, or a solicitation of an offer to buy or sell, any security, investment or other financial product, nor does it constitute a general solicitation, general advertising or direct selling effort under the Securities Act of 1933 of the United States. Any such offer or solicitation may be made only by delivery of a fund's confidential private placement memorandum and other offering documents. Visitors must make their own investment decisions based on their own investment objectives and financial position. Romero does not provide tax, legal, regulatory, or other advice, and Romero recommends that any investors seek advice from independent financial advisers, accountants, or attorneys as deemed necessary. Romero is not advising the visitor to take any particular action based on the information, opinions, or views contained on this Site, and a visitor’s acceptance is deemed by Romero as acknowledgement of these conditions. Romero does not give any advice or make any representations through the Site as to whether any security or investment is suitable to you or will be profitable. Certain investment products and services described herein have not been and will not be registered in the United States with the Securities and Exchange Commission. 
Restrictions on Use of Materials
Unless otherwise expressly noted, all information and materials, including without limitation images, illustrations, designs, icons, photographs, and written and other materials, that are part of the Site are copyrights, trademarks, service marks, trade names, trade dress and/or other intellectual property owned, controlled or licensed by Romero. No material from the Site may be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way; provided, however, that you may download, where specifically permitted, one copy of the materials on any single computer for your personal, non-commercial use only, provided you keep intact and properly display all copyright and other proprietary notices. You may not distribute, modify, transmit, reuse, repost, or use the content of the Site, including, without limitation, any text, images, audio and video, for public or commercial purposes without Romero's written permission. Modification or use of the information or materials for any other purpose will violate the copyright and/or intellectual property rights of Romero. Romero will not treat users of this Site as its clients by virtue of their accessing this Site.

No Warranty
Romero makes no representation, warranty, express or implied, of any kind concerning the data, products, materials information and services contained on this website. The materials on this Site are provided “as is” without warranty of any kind, either express or implied, to the fullest extent permissible pursuant to applicable law. Romero shall not be liable for any damages, viruses, or services, repairs or corrections that must be performed on your computer or other property on account of your accessing or using this Site. Please note that some jurisdictions do not allow the exclusion of implied warranties, so some or all of the above exclusions may not apply to you.
Romero further assumes no liability, whether contingent or otherwise, to you or to third parties, or has any responsibility of any kind, for any loss or damage that you may incur in connection with the failure, interruption, or disruption of any connection, communication, or access to this Site, or for any erroneous communication between you and Romero. Romero shall have no liability, contingent or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data, products, information, material and/or services available on the Site. In no event will Romero be liable for any direct, indirect, incidental, consequential, special, punitive, or exemplary damages or loss which may arise from, or directly or indirectly relate to, (even if Romero has been advised of the possibility of such damages or loss) (i) your use of the data, products, information, material and/or services made available on the Site, (ii) any other matter relating to this Site, (iii) your downloading of any information, software or other materials through the Site, or (iv) any claim or cause of action arising out of, or relating to, breach of contract, breach of warranty, tort, negligence, strict liability, product liability or any other legal theory. Romero will have no responsibility to inform you of any difficulties experienced by Romero or third parties with respect to the use of the data, products, information, material and/or services or to take any action in connection therewith.
Romero operates this Site from its offices within the United States of America. Romero does not represent that the information in this Site is appropriate or available for use in other locations, and access from certain locations may be strictly prohibited. Those who access this Site do so on their own initiative and are responsible for compliance with all applicable local laws.

Privacy and Monitoring by Romero
Romero reserves the right to monitor and record activity on this Site for any and all or no reason, and to take all actions it deems necessary or appropriate in its sole discretion.Romero, however, has no obligation to do so. With respect to affected investors, Romero will at all times abide by its Privacy Policy.
Romero reserves the right, in its sole discretion, to change, modify, add or remove portions of these Terms of Use at any time. As a result of your use of this website, Romero may retain and use any information gathered from your use for its internal business purposes or in accordance with applicable regulatory requirements.
Visitors to this Site should be aware that electronic messages sent through the Internet are neither confidential nor secure and may be viewed by third parties, lost, intercepted or altered.For your protection, you should avoid sending certain personal identifying information via e-mail.Such information, includes, but is not limited to, account information, Social Security numbers or other confidential information.It is recommended that you communicate with Romero by using a secure channel, if such channel is provided by Romero.Unless explicitly stated otherwise, Romero does not accept any orders or instructions sent by e-mail or any other electronic messaging system.Romero reserves the right to monitor any electronic communications (subject to and in accordance with local laws).

Jurisdiction and Governing Law
Any dispute concerning any matter herein, including the validity, termination, or enforceability of the terms, conditions or agreements herein, shall be governed by and interpreted according to the substantive laws of the state of New York without regard for its choice of law or conflict of laws principles.You irrevocably submit to the exclusive jurisdiction of the United States District Court for the Southern District of New York and the courts of the State of New York located in the County of New York for any such dispute.
This Site and all information contained herein are not directed at or intended for distribution to, or use by, any person or entity in any jurisdiction or country where the distribution or use of such information is contrary to the laws or regulation of such jurisdiction, or such distribution or use would subject Romero to any registration requirement within such jurisdiction or country within such jurisdiction or country.
Intellectual Property
Romero, or the applicable third party owner, retains all right, title and interest to and under all patents (including all reissues, divisions, continuations and extensions of such patents) patent applications, trademarks, trademark registrations servicemarks, trademark registration applications, tradenames, all other names and slogans embodying business, product or service goodwill, copyrights, computer software, specifications, data, designs, trade secrets, technology, diagnostic tools, inventions, know-how, processes and confidential and proprietary information and any other intellectual property or other right, in all information and content (including all text, data, graphics and logos) on this Site. Individual pages and/or sections on the Site may be printed for personal or internal use only, provided that such printouts retain all applicable copyright or other proprietary notices. Without the prior written consent of Romero, visitors are strictly prohibited from, including, without limitation, modifying, copying, transmitting, distributing displaying, performing, reproducing, publishing, licensing, framing, creating derivative works from, transferring or otherwise using in any other way for commercial or public purposes, in whole or in part, any information, text, graphics, images, video clips, directories, databases, listings or software obtained from the Site. Systematic retrieval of content from the Site to create or compile, directly or indirectly, a collection, compilation, database or directory (whether through robots, spiders, automatic devices or manual processes) or creating links to the Site without express written permission from Romero is strictly prohibited.

If any provision of these terms shall be deemed unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from these terms and shall not affect the validity and enforceability of any remaining provisions. Romero reserves the right to alter or delete materials from this Site at any time at its discretion.

Conflict with Additional Terms
Certain web pages on the Site may contain additional terms, conditions, disclosures and/or disclaimers (hereinafter collectively referred to as the "Additional Terms"). In the event of a conflict between these Terms of Use and the Additional Terms, the Additional Terms will govern for those specific web pages.

Privacy Policy
Romero Capital , LLC and its affiliates (collectively, “Romero”) respect your privacy as a visitor to the http://www.Romero.comwebsite (the “Site”). It is important for you to understand what information Romero collects about you during your visit and what it does with that information. Your visit to this Site is subject to this “Privacy Policy” and Romero’s Terms of Use. By visiting this Site, you agree that Romero may collect, disclose and use information about you except as expressly provided below. You should review this privacy policy carefully, and if you do not agree with Romero’s practices you should not visit this Site.

The Types of Information Romero Collects About You
When you visit and browse the Site or otherwise interact with Romero, Romero may collect two different types of information about you: information you provide to it, and information that Romero collects by using “cookies” and other technological means.

Information You Provide To Romero
In order to obtain access to certain information or services provided via the Site, you may have to provide information that Romero may collect and store in a way that allows Romero to relate it to you personally, including but not limited to your name, e-mail address, address, phone number, fascimile number, investments, income information, assets and investor status. Romero refers to such information as personally identifiable information. Like many other web sites, Romero actively collects personally identifiable information from its visitors by various means, including asking questions on this website and permitting you to communicate directly with Romero via e-mail.

Information Romero Collects Through Other Means
When you visit this Site, you may be assigned a permanent “cookie” (a small text file) to be stored on your computer’s hard drive.Romero and other companies use cookies for a variety of purposes.For instance, when you return to Romero’s Site after logging in, cookies provide information to the Site so that the Site will remember who you are.
You can choose to browse this Site without cookies.However, without these identifier files you won’t have access to many features that may make your browsing of our Site smoother, and some of Romero’s services may not function properly.Each browser is different, so check your browser’s “Help” menu to learn how to change your cookie preferences.
Romero also collects certain technical information from your computer each time you request a page during a visit to this Site.This information may include the Internet protocol (IP) address used to connect your computer to the Internet; computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform; the full Uniform Resource Locator (URL) clickstream to, through, and from our Site, including date and time; cookie number; and the phone number you used to call Romero.Romero may also use browser data such as cookies, or similar data on certain parts of its Site for fraud prevention and other purposes.During some visits Romero may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Romero may use this information to measure Site activity, to develop ideas for improving its Site, and for any other purpose. Romero may freely share this information with others so long as it is not personally identifiable information.

How Romero Uses Personally Identifiable Information
Romero may store your personally identifiable information and use it for marketing, research and other business purposes, and Romero may associate your personally identifiable information with other information it collects about you, such as details about your usage patterns and interests.
Additionally, sometimes Romero hires companies to provide services to it.In those instances, there is sometimes a need to share your information with such companies.Sometimes Romero also works with other companies who help either to gather your information or to communicate with you.However, Romero will not sell your information to any other business without your consent except as necessary for you to continue to receive the benefits of any program or service you specifically request.Romero may also disclose any information it deems necessary, in its sole discretion, to its affiliates, orto comply with any applicable law, regulation, legal process or governmental request.
As Romero continues to develop its business, it might sell or buy entities, subsidiaries, or other business units.In such transactions, visitor information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy.Also, in the event that Romero or substantially all of its assets are acquired, visitor information will of course be one of the transferred assets.

Protection of Information; No Guarantee of Security
Romero endeavors to protect your personal information.Romero uses both technical and procedural methods to maintain the integrity and security of our databases, including firewalls.However, Romero will not be responsible for or liable in connection with any loss or disclosure of your personal information, other than disclosures that it knowingly makes in violation of this Privacy Policy.

Changes to this Privacy Policy
Romero may revise this Privacy Policy from time to time.If Romero decides to change its Privacy Policy, it will post the revised policy here.Romero may e-mail you notifying you of any changes to its Privacy Policy, but you should check its Site frequently to see recent changes.Any such changes will be effective upon the earlier of thirty (30) calendar days following Romero’s dispatch of an e-mail notice to you or thirty (30) calendar days following Romero’s posting of notice of the changes on this Site.

If you have any questions, comments or concerns about our privacy practices, or if you wish to request access to, correct or delete any personal information that you have provided to us, please contact us

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