PRIVACY POLICY

We Respect Your Privacy
J. Moore Partners places a high value on the trust and confidence our customers place in us. Today’s technology allows for broad and deep sharing of information, so it is important that we have put in place safeguards and policies to protect your information.

Collection of Information
We collect only the information we need to serve you and administer our business. We are committed to keeping your information confidential and we place strict limits and controls on the use and sharing of your information. We make every effort to ensure the accuracy of your information. We collect, retain and use client information to aid in providing you with suitable investment recommendations and high quality customer service. This information comes to us from a variety of sources. It can include information you provide on applications or forms such as name, address, social security number, date of birth, income, net worth, and information about account transactions (such as purchases, sales and account balances). The information could be received while you are a client of our firm and/or could have been collected by your advisor prior to joining our firm.

We Place Strict Limits and Controls on the Use and Sharing of Your Information

We do not disclose any non-public personal information about you or former clients to anyone, except as permitted by law and as set forth in this document. Specifically, so that our firm may continue to offer products and services that meet your investing needs, and to effect transactions that you request, we may disclose information to our employees, affiliates, registered representatives and their affiliated businesses, companies that perform administrative or marketing services on our behalf, and reporting and regulatory agencies (pursuant to Anti-Money Laundering requirements). As stated in our agreements with these companies, they will only use non-public information for the services for which we have specified, and are not permitted to use or share this information for any other purpose. These firms are required to have policies and procedures to protect your confidential information.

Access to your information will be provided only to authorized affiliates; employees; vendors including those permitted by law in order to prevent fraud, control risk, resolve complaints or as otherwise required by law; credit reporting agencies; registered associates; and staff members who require the information to facilitate and administer your business. We maintain (and require these authorized parties to maintain) physical, electronic and procedural safeguards that comply with federal and state standards to protect this information. If the representative serving your account(s) leaves our firm to join another firm, he or she may retain copies of your personal information to continue to service you at the new firm, but is otherwise required to keep confidential the personal information obtained from you while affiliated with us. Under no circumstances do we sell this information to any person or entity. If you decide at some point to close your account or become an inactive client, we will continue to adhere to the privacy policies and practices described in this notice.

LEGAL NOTICES

Disclaimer
The material on this website is for the general information of our clients and visitors.

This website does not constitute an offer to sell or a solicitation of an offer to buy or sell any security or investment product, and may not be relied upon in connection with any offer or sale of securities. Nothing on this website is a recommendation that you purchase, sell or hold any security, or that you pursue any investment style or strategy. Nothing on this website is intended to be, and you should not consider anything on the website to be, investment, accounting, tax or legal advice.

Customer Identification Program
To help the government fight the funding of terrorism and money-laundering activities, and to verify your identity, federal law may require J. Moore Partners to obtain your name, date of birth, address and a government-issued identification number before opening your account. If you are acting on behalf of a corporate entity, we may be required to obtain your name and title, and the corporation’s address and government-issued identification number. In certain circumstances, J. Moore Partners may obtain and verify this information with respect to any person(s) authorized to effect transactions in an account. Your account may be restricted and/or closed if J. Moore Partners cannot verify this information. J. Moore Partners will not be responsible for any losses or damages (including but not limited to lost opportunities) resulting from any failure to provide this information, or from any restriction placed upon, or closing of, your account.

Conflicts of Interest
J. Moore Partners and its affiliates may from time to time engage in activities that are in conflict with their securities customers. The employees of J. Moore Partners, its contract consultants, and its affiliates are bound to the customer’s best interests and are required to notify J. Moore Partners of any possible or potential conflict of interest which may result from their other activities, and may commence such other activities only after the prior, written approval of J. Moore Partners, which may not be unreasonably withheld.

Risk
IMPORTANT: All investing is risky, and no investor should decide to commit funds without first consulting with a competent professional adviser. Some or all invested funds can be lost. The past performance of any investment, investment strategy or investment style is not indicative of future performance. Future results may vary, and are not guaranteed. The value of investments and their income may increase or decrease, and a loss of principal - including all principal - may occur.

Private Placements
Growth Capital Services (GCS) is primarily a private placement banker and broker. A private placement is the sale of registered or unregistered securities to a limited number of qualified private investors, including institutional investors, accredited individuals, and entities that meet certain investor eligibility requirements. Securities purchased through private placements typically fall into the category of alternative assets - investments that often have a low correlation to public markets and offer essential diversification to portfolios dominated by traditional stocks and bonds.

However, private placements generally are highly illiquid, and are not subject to public disclosure obligations. Investors should consult professional advisers, perform deep due diligence, and engage in careful deliberation before investing.

Qualified Investors
Investing in private placements requires high risk tolerance, low liquidity concerns, and long-term commitment. Investors must be able to afford to lose their entire investment. For those reasons, these offerings may be made available only to certain institutional investors and high net worth individuals and entities. As with all alternative investments, investors must meet certain eligibility tests to qualify as purchasers. Currently, entities must have assets of at least $5 million (or all individual owners meet accredited investor tests). Individuals must have a net worth of more than $1 million or gross income for each of the last two years of at least $200,000 ($300,000 with spouse) with the expectation of the same income in the current year, excluding one’s residence.

Securities Investor Protection Corporation (SIPC)
Growth Capital Services is a member of the Securities Investor Protection Corporation (SIPC), which provides protection for owners of securities accounts. Our firm does not hold securities; all accounts and assets are held by our issuers, sponsors, or their clearing brokers or qualified custodians. No coverage protects against a decline in the market value of securities. An explanatory brochure about the SIPC protection is available upon request through the Securities Investor Protection Corporation, www.sipc.org.

GCS BUSINESS CONTINUITY PLAN

Growth Capital Services, Inc. has developed a Business Continuity Plan (BCP) as part of our ongoing contingency planning efforts to mitigate the impacts of business interruptions. Since disasters and disruptions are unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

We plan to quickly recover and resume business operations after a Significant Business Disruption and respond by safeguarding employees’ lives and firm property, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

• Our business continuity plan addresses:
• data back up and recovery;
• mission critical systems;
• financial and operational assessments;
• alternative communications with customers, employees, and regulators;
• alternate physical location of employees;
• critical supplier, contractor, bank and counter-party impact;
• regulatory reporting; and
• assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Significant business disruptions can vary in their scope. For example, an SBD could affect only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In any situation, we plan to continue in business, and notify you through our web site or our main customer number regarding how to contact us. This plan is reviewed periodically and subject to modification without notice. A written copy of the summary of this plan is provided to customers at account opening, posted on the firm’s website, and provided to customers upon request. If you have questions about our business continuity planning, please contact us at your convenience.

TERMS OF USE

User Agreement
Welcome to the J. Moore Partners website. By accessing this website, you agree to comply with this binding user agreement between you and J. Moore Partners, which governs your access and use of the website. If you do not accept these terms and conditions, do not use this website. Your use of this website indicates your full acceptance of this user agreement in its then-current form each time you use the website. J. Moore Partners reserves the right to change the terms and conditions at any time, without notice.

Ownership and restrictions on use
All content included on this website is the property of J. Moore Partners or others and is protected by copyright with all rights reserved. You may download or print out a hard copy of individual pages and/or sections of the J. MOORE PARTNERS website, provided that you do not remove any copyright or other proprietary notices. Any downloading or otherwise copying from the J. MOORE PARTNERS website will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the J. MOORE PARTNERS website without the prior written permission of J. MOORE PARTNERS. You may not disassemble, deconstruct or otherwise violate the security of all or any portion of this website. At any time and for any reason we may revoke your right to use all or any portion of the website.

Risks you assume by using this website
Information on this website speaks only as of the date indicated. We make reasonable efforts to provide accurate information, but at times we may not promptly update or correct this website even if we are aware that it is inaccurate, outdated or otherwise inappropriate. You agree that we are not liable for any actions you take or decisions you make in reliance on any information on this website.

We make reasonable efforts to avoid technological problems, but at any time this website may have, and/or may cause, technological problems including viruses. We are not liable for any defects, delays or errors in or resulting from your use of this website.

We may, but have no obligation to, monitor and record activity on this website for any reason or for no reason.

Linked websites
When you access certain links on the J. MOORE PARTNERS website you may leave the J. MOORE PARTNERS website. J. MOORE PARTNERS has not reviewed any of the websites linked to the J. MOORE PARTNERS website and does not endorse or accept any responsibility for the content of such websites nor the products, services or other items offered through such websites.

Password protected
The contents of the password protected area of this website are subject to the confidentiality provisions of the respective investor fund documents.

International use
The information provided on this website is not intended for distribution to, or use in, any jurisdiction where such distribution or use would be contrary to law. You are responsible for compliance with applicable local laws and regulations.

No warranty
The information and opinions contained on the J. MOORE PARTNERS website are provided without any warranty of any kind, either express or implied.

Limitation of liability
Neither we nor any of our affiliates, agents or employees is responsible for any damages, liabilities or injury, including but not limited to indirect, incidental, special, punitive or consequential damages however caused arising out your use of (or inability to use) this website or this user agreement. Our liability is limited to the maximum extent permitted by law and is limited even if we have been advised of the possibility of the damages, liability or injury that you suffer or if any remedy you have fails of its essential purpose, including any damages, liabilities or injuries caused by any failure of performance, error, omission, theft, interruption, deletion, defect, delay in operation, computer virus, communication line failure, or other computer malfunction.

Governing law
You agree that your use of this website and any disputes relating to the website or this user agreement shall be governed in all respects by the laws of the state of California. Any dispute relating to the above shall be brought solely in the state or federal courts located in San Francisco, California, and it is agreed that such courts shall have jurisdiction over the parties to this user agreement and any dispute arising hereunder.