Disclaimer

This page contains the disclosures, terms, and privacy notices that govern TSG Invest’s public website, content channels, and the TSG Vault investor portal. Use the links below to jump to a specific document.

On this page:

1. TSG Invest Disclaimers
2. Terms of Use
3. Privacy Policy — Website
4. Privacy Policy — TSG Vault (Investor Portal)

TSG Invest Disclaimers

TSG Invest is a financial services holding company headquartered in Hauppauge, New York. TSG Invest does not itself provide investment advice, broker-dealer services, or insurance. Those services are provided by its affiliated entities: TSG Alpha Partners LLC, an SEC-registered investment adviser; TSG Capital Advisors LLC, a FINRA-registered broker-dealer and SIPC member; and TSG Insurance Services LLC, a state-licensed insurance agency. This page sets out the disclosures that apply to TSG Invest’s publicly available content — including its website, blog, YouTube channel, and social media — and links to the required disclosures, privacy notices, and terms maintained by each affiliated entity.

General Information Only

The content TSG Invest publishes publicly — including on tsginvest.com, the TSG Invest YouTube channel, and TSG Invest social media accounts — is provided for general informational and educational purposes only.

It does not take into account the investment objectives, financial situation, risk tolerance, or particular needs of any individual. Nothing published in these channels creates an advisory relationship, a brokerage relationship, or any fiduciary duty. An advisory relationship with TSG Alpha Partners LLC is established only through a written investment advisory agreement.

Information is presented as of the date published and may become outdated. TSG Invest and its affiliates undertake no obligation to update publicly available content as facts, valuations, or circumstances change.

Not a Recommendation, Offer, or Solicitation

No content published by TSG Invest or its affiliates in a public channel constitutes a recommendation to buy, sell, or hold any security, or to adopt any investment strategy.

References to a specific company, security, sector, or transaction are analytical and illustrative. They are not an endorsement of that company and should not be read as a view on the merits of any investment in it.

Nothing on this website or in TSG Invest’s public content is an offer to sell, or a solicitation of an offer to buy, any security. Any offer of securities is made only through definitive offering documents, to eligible investors, in jurisdictions where such an offer is permitted.

TSG Invest, its affiliates, its personnel, and its clients may hold positions in, or have economic exposure to, companies and securities discussed in public content. Such positions may change at any time without notice.

Forward-Looking Statements

Public content may contain forward-looking statements — including views on markets, sectors, technologies, regulation, or the potential outlook for private companies. Forward-looking statements reflect current views as of the date made, are based on assumptions that may prove incorrect, and are subject to risks and uncertainties outside TSG Invest’s control.

Actual outcomes may differ materially from any expectation expressed. Forward-looking statements are not guarantees, projections, or predictions of future results, and should not be relied upon as such.

Performance and Past Results

Past performance does not guarantee future results, and is not indicative of future results.

Any performance figure referenced in public content is historical, may be unaudited, and may not reflect the deduction of fees, expenses, carried interest, or taxes — all of which reduce returns. Where performance is presented net of any specific fee, that treatment is stated at the point of presentation.

Where public content references index or benchmark performance, indices are unmanaged, do not reflect fees or expenses, and cannot be invested in directly.

Comments, Endorsements, and Testimonials

TSG Invest maintains accounts on third-party platforms, including YouTube and social media, where viewers may post comments and other content.

Third-party comments are not authored, reviewed, verified, or endorsed by TSG Invest or its affiliates. They do not represent the views of TSG Invest, and TSG Invest does not adopt them. TSG Invest does not solicit, compensate, or offer any consideration for comments, reviews, or favorable statements about the firm, its personnel, or its services.

TSG Invest moderates comments and may remove, hide, or decline to publish any comment at its discretion, including comments that discuss investment performance, solicit or provide investment advice, or contain a testimonial or endorsement.

A statement by a third party about TSG Invest or its affiliates should not be construed as a testimonial or endorsement, and no such statement should be relied upon as an indication of any future result. Where TSG Alpha Partners LLC uses a testimonial or endorsement in its own advertising, it will do so with the disclosures.

No Tax or Legal Advice

TSG Invest and its affiliates do not provide tax, accounting, or legal advice. Content addressing tax treatment, retirement accounts, estate planning, trusts, insurance, or business structure is general and educational, is based on rules in effect as of the date published, and may not apply to any individual’s circumstances.

Tax and estate rules change and vary by jurisdiction. Consult a qualified tax professional and a licensed attorney regarding your own situation before acting.

Third-Party Content, Links, and Data

Public content may cite or link to third-party websites, filings, research, and data. Third-party material is provided for reference and is not verified by TSG Invest for accuracy or completeness. TSG Invest does not control and is not responsible for third-party content, and a link does not constitute an endorsement of the linked party or its views.

Company valuations, financing round details, and comparable market data referenced in TSG Invest content are drawn from filings, company disclosures, and secondary market sources believed to be reliable. Accuracy is not guaranteed, and figures may be estimates that change.

Private Market Investments

TSG Invest’s affiliated private funds are offered only to accredited investors under applicable SEC exemptions. They are not available to the general public and are not registered investment products.

Investments in private companies are illiquid, speculative, long-term, and may result in total loss of capital. There is generally no public market for these interests, no assurance any liquidity event will occur, and no ability to redeem on demand.

Any investment in a TSG private fund is made solely on the basis of that fund’s definitive offering documents, including its Private Placement Memorandum, which contain the controlling terms, business model, conflicts of interest, and risk factors. Prospective investors should review those documents carefully. Public content, including video, is not a substitute for them and does not summarize them completely.

The TSG Venture 50

The TSG Venture 50 is a proprietary index maintained by TSG Invest that tracks 50 mid-to-late-stage private companies.

The Venture 50 is a research tool, not an investable product. There is no Venture 50 Index fund, it cannot be purchased, and no investment product tracks it. Inclusion in the index is not a recommendation of any company and does not indicate that an investment in that company is available through TSG Invest.

Terms of Use

Please carefully review these Terms of Use (“Terms”). By accessing and using this website and its pages, you acknowledge that you have read, understood, and agree to abide by these Terms. If you do not accept these Terms, please do not use this website. TSG Invest reserves the right to modify these Terms at any time. Your continued use of this website after any changes constitutes acceptance of the updated Terms.

In these Terms, “TSG,” “TSG Invest,” “we,” “us,” and “our” refer to TSG Invest and its affiliated entities.

1. Eligibility and Geographic Restrictions

This website is intended primarily for residents of the United States who are at least 18 years of age. While the website may be accessible from other jurisdictions, the investment products and services described herein may not be available to all international visitors.

Investment Services: Investment advisory services, private placements, and other financial products offered through our affiliates are generally available only to investors who meet applicable regulatory requirements. International investors may be subject to additional restrictions and qualifications.

Compliance with Local Laws: If you access this website from outside the United States, you are responsible for compliance with your local laws and regulations. Nothing on this website constitutes an offer or solicitation in any jurisdiction where such offer or solicitation would be unlawful or where the person making such offer is not qualified to do so.

By using this website, you represent and warrant that you are at least 18 years of age, your access and use complies with all applicable laws in your jurisdiction, and if seeking investment services, you meet all applicable investor qualifications.

2. Company Information and Regulatory Disclosures

This site is operated by TSG Invest, a d/b/a of The Spaventa Group LLC, which is not a registered broker-dealer or investment advisor. TSG Invest refers certain financial services to its affiliated entities:

TSG Capital Advisors LLC (“TSGCA”) (CRD #147509) – Member FINRA/SIPC, providing broker-dealer services and private placements

TSG Alpha Partners LLC (“TSGA”) (CRD #319493) – SEC-registered investment advisor, providing financial planning and investment advisory services

TSG Insurance Services LLC (“TSGIS”) – Licensed insurance agency, providing insurance products These entities are affiliated due to common ownership under TSG Invest.

3. SMS Marketing and Communications

By providing your mobile phone number and opting in to receive SMS communications from us, you consent to receive marketing messages, alerts, and other communications via text message from TSG Invest and our affiliates.

SMS Terms: Message and data rates may apply based on your mobile carrier plan. Message frequency varies but will not exceed 10 messages per month unless you specifically request additional communications. You can opt out at any time by replying “STOP” to any message or by contacting us at marketing@tsginvest.com or 631-210-7623. For help, reply “HELP” or contact us using the information provided above. We use Mailchimp as our SMS service provider, and your information will be processed in accordance with their privacy policy. We will not share your mobile number with third parties for their marketing purposes without your explicit consent. SMS communications may include promotional offers, market updates, educational content, and service announcements.

Carrier Compatibility: Our SMS service is compatible with major carriers including Verizon, AT&T, T-Mobile, Sprint, and others. Please check with your carrier regarding message and data rates.

4. Website Services and Disclaimers

The services and information on this site are provided “AS IS” and “AS AVAILABLE” without warranties of any kind, either express or implied. We expressly disclaim all warranties, including but not limited to warranties of merchantability or fitness for a particular purpose, warranties of title or non-infringement, and warranties regarding accuracy, reliability, or completeness of information.

While we strive to use reliable sources, TSG Invest cannot guarantee the accuracy, validity, timeliness, or completeness of any information or data made available to you. TSG Invest is not responsible for losses or damages that may occur due to third-party interception of information or services provided to you via this website. The information and materials on this website may contain typographical errors or inaccuracies. Dated information is published as of its date only, and TSG Invest assumes no obligation or responsibility to update or amend such information.

5. Investor Portal Terms

If you create an account and use TSG Vault (the “Portal”), additional terms apply in addition to these general Terms of Use.

Account Creation and Access: You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You agree to notify us immediately of any unauthorized access or use of your account. We reserve the right to suspend or terminate your account at any time for violation of these Terms or applicable law. 

Information Accuracy: You represent and warrant that all information you provide through the Portal is accurate, complete, and current. You agree to promptly update your information if it changes. Providing false or misleading information may result in account termination and could affect your ability to invest.

Investment Processing: Use of the Portal does not guarantee acceptance of any investment. All investments are subject to suitability review, regulatory compliance checks, and approval by the issuer or fund manager. We reserve the right to reject any investment indication or subscription at our sole discretion.

Document Submission: Documents you upload to the Portal must be authentic, unaltered, and belong to you or the entity you represent. Submitting fraudulent documents is strictly prohibited and may result in legal action.

Portal Use Restrictions: You may not use the Portal to conduct any illegal activity, attempt to circumvent security measures, share your account credentials with others, use automated systems or bots to access the Portal, or interfere with the Portal’s operation or other users’ access.

Data Security: While we implement security measures to protect your information, you acknowledge that no system is completely secure. You agree to use strong passwords, enable multi-factor authentication when available, and take reasonable precautions to protect your account.

6. Investment-Related Disclaimers

No Investment Advice: TSG Invest does not provide investment advice, endorsements, analysis, or recommendations regarding specific investment products or strategies through this website. We have not verified the adequacy, accuracy, or completeness of any information on this site. Neither TSG Invest nor its partners, agents, or employees make any express or implied warranty about the adequacy, accuracy, or completeness of the information or its use. Nothing on this site should be construed as personalized investment advice.

This website’s content does not constitute a recommendation, solicitation, or offer by TSG Invest or affiliates to buy or sell securities, futures, options, or other financial instruments, or to provide investment advice or services. The information is not prepared for any specific user’s investment requirements or financial situation.

Important Investment Considerations: Past performance does not guarantee future results. Historical returns, expected returns, or probability projections may not reflect actual future performance. All investments carry risk of loss, including total loss of principal. You should conduct your own investigation and analysis. Consult with qualified investment, tax, financial, and legal advisors before making investment decisions. Consider all investment-related charges, expenses, uncertainties, and risks, including those described in offering materials. Certain transactions involve substantial risk and are not suitable for all investors.

Private Placements: Certain investments mentioned, such as private placements, are available only to accredited investors and involve substantial risks, including high risk of total loss of investment where investors must be able to afford the loss of their entire investment, illiquidity and lack of secondary markets, no FDIC insurance or government guarantees as these are not bank deposits, and speculative nature requiring ability to afford complete loss.

No federal or state securities commission or regulatory authority has recommended or approved any investment or the accuracy of information provided here. Before executing any transaction based on information from this site, consult your business, legal, tax, and accounting advisors regarding price, suitability, value, risk, and other aspects of any investment. Pricing and other information generated through data or services here may not reflect actual market prices or values at the time provided or when a user wants to trade.

The information and services on this site are not provided to and may not be used by any person or entity where doing so would violate applicable laws, rules, or regulations of any governmental, regulatory, or self-regulatory organization, or where TSG Invest is not authorized to provide such information or services. Some products and services described may not be available in all jurisdictions or to all clients.

7. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, TSG INVEST AND ITS AFFILIATES SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, LOSS OF PROFITS, DATA, OR USE, SERVICE INTERRUPTIONS OR FAILURES, THIRD-PARTY INTERCEPTION OF INFORMATION, VIRUS TRANSMISSION OR SYSTEM FAILURES, OR ANY DAMAGES ARISING FROM USE OF OR INABILITY TO USE THIS WEBSITE.

This limitation applies regardless of the theory of liability, whether in contract, tort, negligence, strict liability, or otherwise, and even if we have been advised of the possibility of such damages. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitation may not apply to you.

8. User Conduct and Prohibited Activities

This website consists of various web pages operated by TSG Invest. Certain sections or pages may have additional terms, conditions, or privacy policies supplementing these Terms of Use. You should carefully review any such additional legal disclosures. By accessing these sections or pages, you agree to be bound by their specific terms. In case of conflict, those additional terms will govern your use of the relevant sections or pages.

Unauthorized use of TSG Invest’s website and systems, including unauthorized entry, password misuse, or misuse of any information, is strictly prohibited. You agree not to use this website for any unlawful purpose or in violation of applicable laws and regulations, use this website in any way that could damage, disable, overburden, or impair any TSG Invest site or service or interfere with any other party’s use and enjoyment of the same, attempt to gain unauthorized access to our systems or networks through hacking, password mining, or other means, transmit viruses, worms, time bombs, malware, or other harmful code or similar system interference or corruption, interfere with other users’ access or enjoyment of the website, use automated systems including bots, scrapers, or crawlers to access or collect information from the website, frame this site or display this site as “framed” within another website or link to this site without permission, transmit defamatory, indecent, harassing, or otherwise objectionable content in our sole discretion, violate intellectual property, privacy, publicity, or contractual rights of others, impersonate any person or entity or falsely state or misrepresent your affiliation with any person or entity, or use this site to engage in any other unauthorized or unwelcome online conduct.

TSG Invest reserves the right, at its sole discretion and without obligation or notice, to modify, improve, or correct the information, materials, and descriptions on this website. TSG Invest may also suspend or deny access for maintenance, upgrades, improvements, or corrections, whether scheduled or unscheduled. TSG Invest may discontinue or change any product or service described on this website at any time.

TSG Invest has the right, but not the obligation, to monitor this site for any unauthorized or objectionable conduct and to take all appropriate actions in response, without notice to you. We reserve the right to change or supplement our policies as to prohibited uses at any time.

9. Content and Intellectual Property

All content on this website, including text, graphics, logos, images, audio, video, software, and the compilation thereof, is owned by TSG Invest or licensed to us and is protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property laws.

You may not reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store, or transmit any of the material on our website without our prior written consent, except that you may print or download one copy of a reasonable number of pages for your personal, non-commercial use, provided that you keep all copyright and other proprietary notices intact.

You may not use our trademarks, service marks, trade names, or logos without our prior written authorization. Nothing on this website grants you any right or license to use any trademark without the prior written permission of TSG Invest or the applicable third-party owner.

10. Third-Party Links and Content

This website may contain links to third-party websites, services, or resources that are not owned or controlled by TSG Invest. We provide these links as a convenience and do not endorse, control, or assume responsibility for the content, privacy policies, or practices of any third-party websites or services.

You acknowledge and agree that TSG Invest shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods, or services available on or through any such third-party websites or services. Your interactions with third parties found through this website, including payment and delivery of goods or services, and any other terms, conditions, warranties, or representations associated with such dealings, are solely between you and such third party.

We strongly advise you to review the terms of use and privacy policies of any third-party websites or services that you visit.

11. Privacy

Your privacy is important to us. Please review our Privacy Policy, which governs your use of this website and explains our practices regarding the collection, use, and disclosure of your information. By using this website, you consent to the data practices described in our Privacy Policy.

If you use our Investor Portal, the Investor Portal Privacy Policy governs the collection and use of information provided through that platform.

12. Indemnification

You agree to indemnify, defend, and hold harmless TSG Invest, its affiliates, and their respective officers, directors, employees, agents, partners, and licensors from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees, including reasonable attorneys’ fees and court costs, arising out of or relating to your use of this website or the Portal, your violation of these Terms, your violation of any rights of another party including any intellectual property rights, privacy rights, or publicity rights, any content or information you submit or transmit through the website or Portal, your violation of any applicable laws or regulations, or any misrepresentation made by you.

We reserve the right to assume the exclusive defense and control of any matter subject to indemnification by you, and you agree to cooperate with our defense of these claims. You will not settle any claim that affects TSG Invest without our prior written consent.

13. Forward-Looking Statements

This website may contain forward-looking statements identified by words such as “believe,” “anticipate,” “expect,” “intend,” “plan,” “will,” “may,” “estimate,” or similar expressions. These statements are based on current expectations and assumptions and involve risks, uncertainties, and other factors that may cause actual results, performance, or achievements to differ materially from those expressed or implied by such forward-looking statements.

These risks and uncertainties include, but are not limited to, general economic and business conditions, market conditions, regulatory changes, competition, and other factors discussed in offering materials or other disclosures. We are under no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events, or otherwise. You should not place undue reliance on forward-looking statements, which speak only as of the date they are made.

14. Modifications and Termination

We reserve the right to modify, suspend, or discontinue this website, the Portal, or any part thereof at any time, with or without notice, for any reason including but not limited to maintenance, upgrades, security concerns, or business decisions. We may update content, products, services, or features without notice. We may terminate or restrict your access to this website or the Portal at any time, for any reason or no reason, including if we believe you have violated these Terms, engaged in fraudulent activity, or posed a security risk.

Upon termination, your right to use this website and the Portal will immediately cease. However, certain provisions of these Terms, including but not limited to those relating to intellectual property, disclaimers, limitations of liability, and indemnification, shall survive termination.

We shall not be liable to you or any third party for any modification, suspension, or discontinuance of the website or Portal, or for any termination of your access.

15. Governing Law and Dispute Resolution

These Terms and your use of this website and the Portal are governed by and construed in accordance with the laws of the State of New York, without regard to its conflict of law principles.

Arbitration Agreement: Any dispute, controversy, or claim arising out of or relating to these Terms, or the breach, termination, enforcement, interpretation, or validity thereof, including the determination of the scope or applicability of this agreement to arbitrate, shall be determined by binding arbitration in New York, New York, before one arbitrator. The arbitration shall be administered by the American Arbitration Association (AAA) in accordance with its Commercial Arbitration Rules then in effect.

The arbitrator shall have the authority to grant any legal or equitable remedy or relief available under applicable law, including but not limited to specific performance of any obligation created under these Terms, but shall not have the authority to award punitive damages. The arbitrator’s decision shall be final and binding on the parties and may be entered as a judgment in any court of competent jurisdiction.

Exceptions to Arbitration: Notwithstanding the foregoing, either party may seek injunctive or other equitable relief in any court of competent jurisdiction to protect its intellectual property rights, confidential information, or to prevent irreparable harm. Additionally, either party may bring an action in small claims court if the matter qualifies.

Class Action Waiver: You agree that any arbitration or proceeding shall be conducted on an individual basis and not as a class action, consolidated action, or representative action. You waive any right to participate in a class action lawsuit or class-wide arbitration against TSG Invest or its affiliates. Venue and Jurisdiction: If arbitration does not apply or is found unenforceable, you agree that any legal action or proceeding shall be brought exclusively in the federal or state courts located in New York, New York, and you consent to the personal jurisdiction of such courts.

16. Severability

If any provision of these Terms is found by a court of competent jurisdiction to be invalid, illegal, or unenforceable, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, or if such modification is not possible, such provision shall be severed from these Terms. The invalidity or unenforceability of any provision shall not affect the validity or enforceability of any other provision of these Terms, and the remaining provisions shall continue in full force and effect.

17. Waiver

No waiver by TSG Invest of any term or condition set forth in these Terms shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition. Any failure by TSG Invest to assert a right or provision under these Terms shall not constitute a waiver of such right or provision.

18. Assignment

You may not assign or transfer these Terms or any rights or obligations hereunder without our prior written consent. TSG Invest may freely assign or transfer these Terms and any rights or obligations hereunder in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its assets. These Terms shall be binding upon and inure to the benefit of the parties and their respective successors and permitted assigns.

19. Entire Agreement

These Terms, together with our Privacy Policy, Investor Portal Privacy Policy (if applicable), and any additional terms applicable to specific sections of the website or Portal, constitute the entire agreement between you and TSG Invest regarding your use of this website and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, regarding such subject matter.

20. Electronic Communications

By using this website or providing your contact information to us, you consent to receive electronic communications from us, including emails, text messages if you have opted in, and notices posted on this website. You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

21. Contact Information

If you have questions about these Terms or need to report a violation, please contact us at:

TSG Invest Email: info@tsginvest.com Phone: 631-210-7623 Address: 1200 Veterans Memorial Highway Suite 201 Hauppauge New York 11788. For technical support regarding TSG Vault, contact: support@tsginvest.com

Copyright Notice

Copyright © 2026 The Spaventa Group, LLC. All rights reserved. All content, including textual, graphical, audio, video, and multimedia materials, is protected by United States and international copyright, trademark, and other intellectual property laws. Unauthorized reproduction, distribution, or use of any content is strictly prohibited.

Trademarks

TSG Invest, The Spaventa Group, and related logos are trademarks or registered trademarks of The Spaventa Group LLC. All other trademarks, service marks, and logos used on this website are the property of their respective owners.

Privacy Policy — TSG Invest Website

Introduction

TSG Invest (“we,” “us,” “our,” or “Company”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our public website at www.tsginvest.com. This Privacy Policy applies to our public website only. If you are using our Investor Portal, please refer to the separate Investor Portal Privacy Policy, which governs the collection and use of information provided through that platform.

By using our website, you agree to the collection and use of information in accordance with this Privacy Policy.

Information We Collect

Personal Information

We may collect personal information that you voluntarily provide to us, including your name and contact information such as email address, phone numbers, and mailing address. When you provide it to us, we also collect professional information including your occupation and employer. Additionally, we gather information about your communication preferences and subscription choices, as well as any information you provide when contacting us through forms or email.

Automatically Collected Information

When you visit our website, we automatically collect certain information about your device and browsing activity. This includes your IP address (which may be partially anonymized), browser type and version, device information and operating system details, pages viewed and time spent on our site, referring URLs and search terms used to find our site, approximate geographic location based on IP address, and the date and time of visits.

Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to enhance website functionality and user experience, remember your preferences and settings, analyze website usage and performance, deliver personalized content and advertisements, and estimate our audience size and usage patterns. You can control cookie settings through your browser preferences. Disabling cookies may limit certain website features. For more information about cookies, visit www.allaboutcookies.org.

How We Collect Information

We gather information through various channels including newsletter subscriptions and email communications, contact forms and general inquiries, media downloads and resource requests, calendar bookings and consultation requests, and surveys, contests, and promotional activities where participation is voluntary. We also collect information through website usage and interactions via analytics tools.

How We Use Your Information

We use your personal information for service delivery purposes, including providing requested information, resources, and services. Your information enables us to communicate with you by responding to inquiries, providing customer support, and sending service-related notifications. For marketing purposes, we send promotional communications about our services and those of our partners, with your consent where required by law. We use your information for website improvement by analyzing usage patterns to enhance user experience and optimize our website. Additionally, we process your information for legal compliance to meet regulatory and legal obligations, for security purposes to prevent fraud, protect against security threats, and ensure platform integrity, and for business operations including conducting internal analytics, research, and business development activities.

Information Sharing and Disclosure

We may share your information in the following circumstances.

With Your Consent

We share information when you explicitly agree to share it for specific purposes.

Service Providers

We work with trusted third-party service providers who assist with website hosting and maintenance, email marketing and communications platforms, data analytics and research tools, customer relationship management systems, and payment processing when applicable. These providers are contractually bound to protect your information and use it only for specified purposes on our behalf.

Legal Requirements

We may disclose information when required by law or to comply with legal processes such as subpoenas and court orders, enforce our Terms of Service and other agreements, protect the rights, property, or safety of our company, users, or others, investigate suspected illegal activities or fraud, and respond to government or regulatory requests.

Business Transactions

In the event of a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred to the acquiring entity. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

Affiliates

TSG Invest may share your website information with its affiliated companies for marketing and business purposes consistent with this Privacy Policy. Our affiliates include TSG Capital Advisors LLC (“TSGCA”) (CRD #147509), a FINRA/SIPC member broker-dealer; TSG Alpha Partners LLC (“TSGA”) (CRD #319493), an SEC-registered investment advisor; and TSG Insurance Services LLC (“TSGIS”), a licensed insurance agency. Information collected through our public website may be used by our affiliates to provide you with information about their services. If you register for our Investor Portal, different information sharing practices apply as described in the Investor Portal Privacy Policy.

Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit using SSL/TLS protocols, secure data storage with access controls, regular security assessments and updates, and employee training on data protection practices. However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information using commercially acceptable means, we cannot guarantee absolute security.

You are responsible for keeping any passwords and account details confidential, using caution when accessing our services on shared or public computers, being aware of potential risks when using unsecured networks, and reviewing your account activity regularly.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations and regulatory requirements, resolve disputes and enforce agreements, and maintain business records as required. Specifically, marketing and communication data is retained until you unsubscribe or request deletion, website analytics data may be retained in anonymized or aggregated form indefinitely, and information required for legal or regulatory purposes is retained as long as required by law. We may retain anonymized, aggregated information for research and improvement purposes beyond these periods.

International Data Transfers

Your information may be stored and processed in countries other than your country of residence, including the United States. When we transfer information internationally, we ensure appropriate safeguards are in place to protect your data in accordance with applicable privacy laws.

Your Rights and Choices

Depending on your location, you may have various rights regarding your personal information. Regarding access and portability, you may request access to your personal information and receive a copy of your data in a portable format. For correction purposes, you may request correction of inaccurate or incomplete information and update your preferences and contact information. Regarding deletion, you may request deletion of your personal information subject to legal retention requirements, and close your account and remove your data from our active systems.

You may opt out of marketing communications by using the “unsubscribe” link in marketing emails, contacting us to update your communication preferences, or for SMS messages, texting “STOP” to the number sending messages. You also have the right to object to or restrict certain processing activities, withdraw consent where processing is based on consent, and lodge a complaint with a supervisory authority.

To exercise these rights, contact us using the information provided below. We will respond to your request within the timeframe required by applicable law.

Mobile Text Messaging

If you opt in to receive text messages from us, message and data rates may apply. Service is available on major US carriers including AT&T, Verizon, T-Mobile, and Sprint. Carriers are not liable for delays or undelivered messages. You may opt out by texting “STOP” to any number you no longer wish to receive messages from, calling us at 631-210-7623 to unsubscribe, or emailing cr@tsginvest.com for assistance.

We maintain a zero-tolerance spam policy. To report spam, call 631-210-7623 and include the sender’s contact information, username, and message content.

Children’s Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information without parental consent, we will take steps to delete it promptly. If you believe we have collected information from a child under 18, please contact us immediately.

Third-Party Links

Our website may contain links to third-party websites, services, or resources. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information to third parties.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or services, new technologies or security measures, legal or regulatory requirements, or feedback from users or regulators. When we make changes, we will post the updated policy on our website, update the “Last Updated” date at the top of this policy, and notify you of material changes through email or prominent website notice where required by law. We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

State-Specific Privacy Rights

California Residents

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Under the right to know, you may request information about the categories and specific pieces of personal information we have collected, the sources of that information, our business purposes for collecting it, and the categories of third parties with whom we share it. Under the right to delete, you may request deletion of your personal information, subject to certain exceptions. Under the right to correct, you may request correction of inaccurate personal information. Under the right to opt-out, you have the right to opt out of the “sale” or “sharing” of your personal information. Note that we do not sell personal information in the traditional sense. Under the right to non-discrimination, you have the right not to be discriminated against for exercising your privacy rights. Under Shine the Light, California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes.

To exercise these rights, contact us using the information below. We will respond within 45 days.

Other State Rights

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights. Contact us to exercise your rights under applicable state law.

Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at TSG Invest by email at cr@tsginvest.com, by phone at 631-210-7623, or by mail at 1200 Veterans Memorial Highway Suite 201 Hauppauge, New York 11788.

Governing Law

This Privacy Policy is governed by the laws of the State of New York, USA, without regard to conflict of law principles.

Privacy Policy — TSG Invest Investor Portal (TSG Vault)

Introduction

TSG Invest (“we,” “us,” “our,” or “Company”) is committed to protecting the privacy and security of your personal and financial information. This Privacy Policy explains how we collect, use, disclose, and safeguard information you provide through the TSG Vault (the “Portal”).

This Privacy Policy applies exclusively to the Investor Portal. For information about our public website privacy practices, please refer to our Website Privacy Policy.

By creating an account and using the Investor Portal, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your information as described herein.

Important Information About Information Sharing

NOTICE: Information you provide through the Investor Portal will be shared with all TSG affiliates as described in the “*Affiliates and Information Sharing*” section below. This sharing is necessary to facilitate investment opportunities, ensure regulatory compliance, and coordinate financial services across our affiliate companies.

Information We Collect Through TSG Vault

When you create an investor profile and use the Portal, we collect comprehensive information necessary for investment suitability assessment, regulatory compliance, and investment processing.

Profile Information

We collect your full legal name including first and last name, email address, home address including street, city, state, and ZIP code, cell phone number, citizenship status, date of birth, marital status, occupation or profession, and employer name and information if applicable.

Financial Information

We gather information about your annual income, net worth excluding primary residence, liquidity measured as average 90-day liquid assets, annual expenses, liquidity needs and timeline, and sources of investment funds such as employment income, sale of business, inheritance, investment returns, and other sources.

Investment Experience and Background

For each asset class, we collect your years of experience and estimated number of active investments per year. These asset classes include individual stocks, fixed income securities such as bonds and treasury securities, mutual funds and exchange-traded funds, Real Estate Investment Trusts, direct real estate investments, annuities and insurance products, venture capital and angel investing, hedge funds and private equity funds, private debt and lending investments, digital assets and cryptocurrency, commodities and futures, options and derivatives, and other investment types. We also collect information about your investment decision-making process, including whether you make independent decisions, consult with advisors, or rely on recommendations.

Investment Objectives and Risk Profile

We collect information about your overall risk tolerance, which may be conservative, moderately conservative, moderate, moderately aggressive, or aggressive. We also gather information about your primary investment objectives, desired allocation to equity-based alternative investments such as venture capital, private equity, and hedge funds, desired allocation to income-based alternative investments such as private debt and real estate funds, investment time horizon, and investment monitoring frequency.

Investor Status and Qualifications

We collect information about your accredited investor status and the basis for your qualification, qualified purchaser status if applicable, Investment Company Act status for entity investors, and ERISA and employee benefit plan status for entity investors.

Tax Status and IRS Information

We gather your U.S. person or non-U.S. person classification, Form W-9 for U.S. persons or Form W-8 for non-U.S. persons, tax identification number or Social Security number, and tax residency information.

Trusted Contact Person (Optional)

If you choose to provide this information, we collect your trusted contact’s first and last name, phone number and email address, and their relationship to you.

Identity Verification Documents

We collect copies of government-issued identification such as driver’s license, passport, or state ID, including the photograph and document number from your ID and the document expiration date.

Entity Account Information (If Applicable)

For entity accounts such as corporations, LLCs, trusts, partnerships, or other legal entities, we collect the entity’s legal name and type, entity formation documents including articles of incorporation, operating agreements, partnership agreements, and trust documents, tax identification number, authorized person information and government-issued ID, corporate resolutions or trustee authorizations, certificates of good standing, and beneficial ownership information. For trusts, we additionally collect the trust agreement, certificate of trust, and grantor information. For tax-exempt organizations, we collect IRS determination letters. For employee benefit plans, we collect plan documents and ERISA information.

Account Activity and Transaction Information

We track and collect information about investment account creation and management activities, investment interests and indications, subscription documents and agreements, investment confirmations and transaction history, communications and correspondence with TSG and its affiliates, document uploads and downloads, and Portal usage data including login times, pages accessed, and features used.

Technical and Device Information

We automatically collect your IP address, browser type and version, device information and operating system, Portal session data, and information through cookies and similar tracking technologies.

How We Collect Information

We collect information through direct input when you manually enter information into Portal forms and fields, or when our team members enter information on your behalf with your authorization. We receive information through document uploads when you provide documents for identity verification, entity documentation, and investment processing. Information is captured through electronic signatures during electronic signature processes. We collect data based on account activity, including actions you take within the Portal such as viewing offerings, submitting indications of interest, and managing your profile. We may obtain information from third-party verification services including identity verification, accreditation verification, and background check providers. We also collect technical information automatically through cookies and analytics tools.

How We Use Your Information

We use the information collected through the Investor Portal for the following purposes.

Investment Processing and Suitability

We use your information to evaluate your qualifications to invest in investment fund offerings and other investments offered by affiliates, assess investment suitability based on your financial situation, experience, and objectives, process investment subscriptions and manage investment accounts, facilitate investment transactions and fund distributions, provide investment-related communications and updates, and generate subscription documents and agreements.

Regulatory Compliance and Verification

Your information is used to conduct Know Your Customer verification, perform Anti-Money Laundering checks, verify accredited investor or qualified purchaser status, comply with federal and state securities laws and regulations, meet SEC, FINRA, and state securities regulator requirements, maintain books and records as required by law, respond to regulatory inquiries and examinations, and file required reports and notices with regulatory authorities.

Account Management and Communication

We use your information to create and maintain your investor profile and accounts, provide customer support and respond to inquiries, send account notifications, confirmations, and updates, communicate investment opportunities from TSG and its affiliates, deliver tax documents and account statements, and facilitate communications with fund managers and issuers.

Security and Fraud Prevention

Your information helps us protect against unauthorized access to your account, detect and prevent fraudulent activity, verify your identity for account access, monitor for suspicious transactions or activity, and maintain the security and integrity of the Portal.

Legal and Business Operations

We use your information to enforce our Terms of Service and other agreements, resolve disputes and claims, protect our legal rights and interests, conduct internal audits and quality assurance, improve Portal functionality and user experience, analyze usage patterns and investor preferences, and develop new products and services.

Affiliates and Information Sharing

Sharing with TSG Affiliates

IMPORTANT NOTICE: All information you provide through the TSG Vault is shared with TSG Invest’s affiliated companies. This information sharing is integral to our business operations and necessary to facilitate investment opportunities across our affiliate platforms, ensure comprehensive regulatory compliance across all entities, coordinate financial services and investment advisory services, maintain unified client records and relationship management, provide seamless service delivery across TSG companies, and enable our affiliates to communicate relevant investment opportunities to you.

TSG Affiliates include TSG Capital Advisors LLC (“TSGCA”) (CRD #147509), a FINRA/SIPC member broker-dealer registered with the Securities and Exchange Commission that provides broker-dealer services, private placement offerings, and securities transactions; TSG Alpha Partners LLC (“TSGA”) (CRD #319493), an SEC-registered investment advisor providing financial planning, investment advisory services, and portfolio management; and TSG Insurance Services LLC (“TSGIS”), a licensed insurance agency providing insurance products, annuities, and risk management solutions.

By creating an investor profile, you explicitly consent to this information sharing among TSG affiliates. Each affiliate will use your information in accordance with their own regulatory obligations and may contact you regarding their respective services and investment opportunities.

Sharing with Other Third Parties

In addition to sharing with affiliates, we may share your information with other parties in the following circumstances.

We work with trusted third-party service providers who assist with Portal operations and investment processing. These include identity verification services to verify your identity and prevent fraud, accreditation verification services to confirm accredited investor or qualified purchaser status, background check providers to conduct AML and sanctions screening, document management services to securely store and manage uploaded documents, electronic signature platforms to facilitate document execution, payment processors to process investment funds and distributions, IT and security services to maintain Portal infrastructure and security, data analytics providers to analyze Portal usage and improve services, and customer support tools to provide assistance and respond to inquiries. These service providers are contractually obligated to protect your information, use it only for specified purposes, and comply with applicable privacy and security requirements.

When you express interest in or invest in an offering through the Portal, we share relevant information with the issuer or sponsor of the investment opportunity, fund managers and general partners, third-party administrators and custodians, and legal counsel representing the issuer or fund. This information is necessary to process your investment, maintain investor records, provide ongoing communications, and comply with fund governance and regulatory requirements.

We may disclose your information to comply with legal and regulatory obligations to entities including the Securities and Exchange Commission, Financial Industry Regulatory Authority, state securities regulators and administrators, Internal Revenue Service and tax authorities, law enforcement agencies, courts and legal proceedings including subpoenas, court orders, and discovery requests, and government agencies conducting investigations or audits.

We may share your information with other parties when you provide explicit consent, such as third-party financial advisors you authorize, co-investors in joint investment accounts, accountants or attorneys you designate, and other parties you specifically authorize.

In the event of a merger, acquisition, financing, sale of assets, bankruptcy, or similar corporate transaction involving TSG Invest or its affiliates, your information may be transferred to the acquiring or successor entity. You will be notified of any such change in ownership or control of your information.

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for research, analytics, marketing, or other business purposes. This information is not considered personal information and is not subject to this Privacy Policy.

Data Security and Protection

Security Measures

We implement comprehensive technical, administrative, and physical security measures to protect your information.

Our technical safeguards include encryption of data in transit using industry-standard SSL/TLS protocols, encryption of sensitive data at rest, secure authentication mechanisms and multi-factor authentication options, regular security testing and vulnerability assessments, intrusion detection and prevention systems, secure backup and disaster recovery procedures, and access controls and user authentication requirements.

Our administrative safeguards include employee training on data protection and security practices, confidentiality agreements with employees and service providers, role-based access controls limiting access to need-to-know basis, background checks for employees with access to sensitive information, regular security audits and compliance reviews, incident response and breach notification procedures, and data protection impact assessments.

Our physical safeguards include secure data center facilities with restricted access, environmental controls and monitoring, and secure disposal of physical documents containing personal information.

Limitations of Security

Despite our security measures, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information using commercially reasonable means, we cannot guarantee absolute security. Risks include unauthorized access by hackers or cybercriminals, data breaches affecting third-party service providers, interception of data during transmission, and human error or insider threats.

Your Security Responsibilities

You play a critical role in protecting your account. You must create strong, unique passwords and not share them with anyone. You should regularly review your account activity and report suspicious behavior immediately. You must log out after each session, especially on shared or public devices. You should be cautious of emails or communications requesting your login credentials. You must keep your devices and software updated with the latest security patches. You should avoid accessing your account on unsecured public Wi-Fi networks.

If you suspect unauthorized access to your account, contact us immediately at cr@tsginvest.com or (631) 210 – 7263.

Data Retention and Record Keeping

Retention Periods

We retain your information for varying periods depending on the purpose and legal requirements.

Information in active investor accounts is retained for the duration of your active account and investment holdings. Federal and state securities laws require us to retain certain records for specific periods. Investment records and subscription documents are retained for at least 6 years after the investment is liquidated. Communications and correspondence are retained for at least 3-6 years depending on the type. Identity verification and KYC documentation is retained for at least 5 years after account closure. Transaction records are retained for at least 6 years after the transaction. Information necessary for tax reporting and IRS compliance is retained for at least 7 years. Information may be retained longer if necessary to resolve disputes, enforce agreements, or defend legal claims. After you close your account, we retain your information as required by securities regulations, typically for at least 6 years from account closure.

Anonymized Data

We may retain anonymized, aggregated, or de-identified data indefinitely for research, analytics, and business intelligence purposes. This data cannot reasonably be used to identify you and is not subject to deletion requests.

Secure Disposal

When information is no longer required, we securely dispose of it through methods such as secure deletion or destruction of electronic files, shredding of physical documents, overwriting of data storage media, and decommissioning of hardware in accordance with data destruction standards.

International Data Transfers

Your information may be transferred to, stored, and processed in the United States and other countries where TSG Invest, its affiliates, or service providers operate. These countries may have data protection laws that differ from those in your country of residence.

When we transfer information internationally, we implement appropriate safeguards including standard contractual clauses approved by relevant authorities, adequacy decisions recognizing equivalent data protection, binding corporate rules for transfers within our corporate group, and your explicit consent for specific transfers when required.

By using the Investor Portal, you acknowledge and consent to the transfer of your information to the United States and other jurisdictions as necessary for the purposes described in this Privacy Policy.

Your Rights and Choices

Depending on your location and applicable law, you may have various rights regarding your personal information. However, please note that certain investor information must be retained to comply with securities regulations, even if you request deletion.

Access Rights

You have the right to access and request access to the personal information we hold about you, receive a copy of your information in a structured, commonly used format, and understand what information we collect, how it’s used, and with whom it’s shared. To exercise these rights, contact us using the information provided below. We will provide access to your information within the timeframe required by applicable law, typically within 30-45 days.

Correction and Update Rights

You have the right to correction, meaning you may request correction of inaccurate or incomplete information. For account updates, you may update your profile information, contact details, and preferences directly through the Portal. You are responsible for ensuring the accuracy of information you provide. Inaccurate information may affect investment suitability determinations and regulatory compliance.

Deletion Rights

You have the right to deletion, meaning you may request deletion of your personal information, subject to legal and regulatory exceptions. Important limitations apply: We may be unable to delete certain information if it is required by securities laws and regulations typically for 6 or more years, necessary to complete transactions or fulfill services you requested, required to detect and prevent fraud or security incidents, needed to comply with legal obligations or defend legal claims, or subject to ongoing regulatory examination or investigation. If we cannot delete your information due to legal requirements, we will inform you of the reasons and the retention period.

Objection and Restriction Rights

You have the right to object to certain processing of your information, particularly for direct marketing purposes, and the right to restriction, meaning you may request that we limit how we use your information in specific circumstances.

Marketing Communications

You have the right to opt out of marketing communications. For email, you may click “unsubscribe” in marketing emails or contact us to update preferences. For SMS, you may text “STOP” to opt out of text messages. For phone calls, you may request to be placed on our do-not-call list. For mail, you may contact us to opt out of postal mailings. Note that even if you opt out of marketing, we will still send transactional communications related to your account, investments, and legal obligations.

Withdrawal of Consent

Where processing is based on your consent, you may withdraw consent at any time. However, this will not affect the lawfulness of processing based on consent before withdrawal, and we may continue processing for other lawful bases such as regulatory compliance.

How to Exercise Your Rights

To exercise any of these rights, contact us by email at cr@tsginvest.com, by phone at 631-210-7623, by mail at 1200 Veterans Memorial Highway Suite 201 Hauppauge New York 11788, or through TSG Vault by submitting a request through the Portal’s support feature. We will verify your identity before processing requests and respond within the timeframe required by applicable law. We do not charge a fee for exercising your rights unless your request is manifestly unfounded, excessive, or repetitive.

Gramm-Leach-Bliley Act (GLBA) Notice

As a financial institution, TSG Invest and its affiliates are subject to the Gramm-Leach-Bliley Act (GLBA), which requires us to provide you with notice of our privacy practices.

Categories of Information We Collect

We collect information from applications and forms including name, address, income, and assets. We collect information about your transactions with us including account balances, payment history, and investment activity. We collect information from consumer reporting agencies including credit reports and background checks. We collect information from other sources including identity verification services and public records.

Categories of Information We Disclose

We may disclose all categories of information we collect to our affiliates for their everyday business purposes, to nonaffiliated companies that perform services for us with confidentiality agreements, and to other parties as required or permitted by law.

Your Right to Opt Out

Federal law gives you the right to limit some but not all sharing. Specifically, you cannot limit sharing for our affiliates’ everyday business purposes regarding information about your transactions and experiences, sharing for our affiliates to market to you, or sharing for nonaffiliates to market to you. This is because the information sharing described in this Privacy Policy is necessary for investment processing, regulatory compliance, and coordinated service delivery across TSG affiliates.

If we decide to share information in ways that would allow you to opt out under GLBA, we will provide you with a separate opt-out notice at that time.

Annual Privacy Notice

We will provide you with an annual privacy notice as required by GLBA. This notice will be delivered electronically through the Portal or by mail.

State-Specific Privacy Rights

California Residents

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Under the right to know, you may request detailed information about categories and specific pieces of personal information collected, categories of sources from which information was collected, business or commercial purposes for collecting information, and categories of third parties with whom we share information.

Under the right to delete, you may request deletion of personal information, subject to exceptions for regulatory compliance, legal obligations, and security purposes.

Under the right to correct, you may request correction of inaccurate personal information.

Under the right to opt-out of sale or sharing, you have the right to opt out of the “sale” or “sharing” of personal information for cross-context behavioral advertising. Note that we do not sell personal information for monetary consideration. We may share information with affiliates and service providers as described in this policy, which is necessary for investment processing and not considered a “sale” under CCPA.

Under the right to limit use of sensitive personal information, you may request that we limit the use of sensitive personal information such as financial account information, precise geolocation, or SSN to purposes necessary to provide services. However, the information we collect is necessary for investment processing and regulatory compliance.

Under the right to non-discrimination, you will not be discriminated against for exercising your privacy rights.

You may designate an authorized agent to submit requests on your behalf. We will require verification of the agent’s authority. We will respond to verifiable requests within 45 days, extendable by an additional 45 days if necessary. California residents may request information about our data practices, including the number and type of requests received and our response times.

To exercise California privacy rights, contact us at cr@tsginvest.com or call 631-210-7623.

Virginia, Colorado, Connecticut, Utah Residents

Residents of Virginia under VCDPA, Colorado under CPA, Connecticut under CTDPA, and Utah under UCPA have similar rights including the right to access personal data, correct inaccuracies, delete personal data, obtain a copy of personal data, and opt out of targeted advertising, sale of personal data, and profiling for certain decisions.

To exercise these rights, contact us using the information provided in the Contact section.

Other State Rights

We comply with all applicable state privacy laws. If your state has enacted comprehensive privacy legislation, contact us to understand and exercise your rights.

Children’s Privacy

The Investor Portal is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. To invest through the Portal, you must be at least 18 years old or the age of majority in your jurisdiction and legally capable of entering into binding contracts.

If we become aware that we have collected information from a minor without proper authorization, we will take steps to delete such information promptly. If you believe we have collected information from a minor, contact us immediately at cr@tsginvest.com.

Third-Party Services and Links

The Investor Portal may contain links to third-party websites, services, or resources, such as fund manager websites, issuer information pages, due diligence materials hosted externally, and third-party research or news sources.

We are not responsible for the privacy practices, content, or security of these external sites. Third-party sites are governed by their own privacy policies. We encourage you to review their privacy practices before providing any personal information. Some Portal features may integrate with third-party services such as identity verification or electronic signature platforms. When you use these features, you may be subject to the third party’s terms and privacy policy in addition to ours.

Cookies and Tracking Technologies

The Investor Portal uses cookies and similar tracking technologies to provide functionality and enhance your experience.

Types of Technologies We Use

Essential cookies are necessary for Portal operation, including authentication and session management, security features and fraud prevention, remembering your preferences and settings, and enabling core Portal features.

Analytics cookies help us understand how you use the Portal by tracking pages visited and features used, time spent on the Portal, navigation patterns and user flows, and error tracking and performance monitoring.

Functional cookies enhance Portal functionality by remembering your language preferences, customizing your user interface, and saving your progress on forms.

Your Cookie Choices

Essential cookies cannot be disabled as they are necessary for Portal operation. Optional cookies including analytics and functional cookies may be controlled through your browser settings, as most browsers allow you to refuse or delete cookies, through Portal preferences if available, or through opt-out tools provided by analytics providers. Note that disabling certain cookies may limit Portal functionality or require you to re-enter information.

For more information about cookies, visit www.allaboutcookies.org.

Automated Decision-Making

We may use automated systems to assist with certain decisions, such as initial screening for investor qualification requirements, risk assessment and suitability scoring, fraud detection and prevention, and identity verification.

However, significant investment decisions and suitability determinations involve human review and oversight. You have the right to obtain information about the logic involved in automated decisions, contest automated decisions, and request human review of automated determinations.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our data practices or Portal features, new legal or regulatory requirements, technological developments or security enhancements, changes in our corporate structure or affiliates, and feedback from users, regulators, or auditors.

Notice of Changes

When we make material changes to this Privacy Policy, we will update the “Last Updated” date at the top of this policy, post the revised policy on the Portal, notify you through the Portal notification system, send email notification to your registered email address, and for significant changes, require your affirmative consent before continuing to use the Portal.

Your Options

If you disagree with changes to this Privacy Policy, you may close your account subject to any ongoing investment obligations, exercise your rights to restrict processing where applicable, or contact us to discuss your concerns.

Continued use of the Portal after changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

Contact Information

Privacy Inquiries and Requests

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact TSG Invest by email at cr@tsginvest.com, by phone at 631-210-7623, or by mail at 1200 Veterans Memorial Highway Suite 201 Hauppauge New York 11788.

For Portal support including technical support or account assistance, email support@tsginvest.com or use the “Help” or “Contact Us” feature within the Portal.

Exercising Your Rights

To exercise your privacy rights including access, correction, and deletion, contact us by email at cr@tsginvest.com, by phone at 631-210-7623, through the Portal by submitting a request through the Portal’s privacy request feature, or by mail at 1200 Veterans Memorial Highway Suite 201 Hauppauge New York 11788.

Please include the following information in your request: your full name and contact information, description of your request, verification information for security purposes, and preferred method of response.

Response Timeframe

We will acknowledge receipt of your request within 5 business days and provide a substantive response within 30-45 days for most requests, or extended timeframes where permitted by law with notice to you.

Verification Process

To protect your information, we will verify your identity before processing requests. Verification may require matching information you provide with information in our records, answering security questions, providing government-issued identification, or confirming access to your registered email or phone number.

Complaints and Disputes

If you believe we have not adequately addressed your privacy concerns, you may request internal escalation to our Privacy Officer or senior management. You may file a regulatory complaint with your state Attorney General’s office, state securities regulator, Federal Trade Commission, California Attorney General for California residents, or your local data protection authority for EU/EEA residents. You may also consult with legal counsel about your rights and options.

We take privacy concerns seriously and will work diligently to resolve any issues.

Regulatory Framework and Compliance

This Privacy Policy is designed to comply with the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, SEC Regulation S-P governing privacy of consumer financial information, FINRA rules regarding customer information protection, state securities laws and regulations, California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), state privacy laws including Virginia VCDPA, Colorado CPA, Connecticut CTDPA, and Utah UCPA, Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) requirements, USA PATRIOT Act customer identification program requirements, and other applicable federal and state privacy laws.

Our data practices are subject to examination by the Securities and Exchange Commission, Financial Industry Regulatory Authority, state securities regulators, state attorneys general, and other regulatory authorities with jurisdiction.

Definitions

An accredited investor is an individual or entity meeting specific income, net worth, or professional criteria as defined under SEC Rule 501 of Regulation D. Affiliates are companies related by common ownership or control, specifically TSG Capital Advisors LLC, TSG Alpha Partners LLC, and TSG Insurance Services LLC. Personal information is information that identifies, relates to, describes, or is capable of being associated with you, either directly or indirectly. Portal refers to the TSG Vault, including web-based and mobile applications. A qualified purchaser is an individual or entity meeting higher financial thresholds as defined under Section 2(a)(51) of the Investment Company Act of 1940. Sensitive personal information includes information such as Social Security numbers, financial account information, precise geolocation, racial or ethnic origin, religious beliefs, or health information. Third party refers to any individual or entity that is not TSG Invest, its affiliates, or you.

Effective Date and Acknowledgment

This Privacy Policy is effective as of the “Last Updated” date shown at the top of this document. By creating an account and using the Investor Portal, you acknowledge that you have read and understood this Privacy Policy, you consent to the collection, use, and sharing of your information as described, you understand that your information will be shared with all TSG affiliates, you agree to the terms and conditions set forth in this Privacy Policy, and you understand your rights and how to exercise them. If you do not agree with this Privacy Policy, please do not create an account or use the TSG Vault.

Summary of Key Points

For your convenience, this summary highlights key aspects of our privacy practices. Please read the full Privacy Policy for complete details.

We collect comprehensive personal, financial, and investment information necessary for investment processing and regulatory compliance. We use this information for investment suitability assessment, transaction processing, regulatory compliance, and account management. We share your information with all TSG affiliates, service providers, issuers, and regulators as necessary. Your rights include access, correction, deletion subject to legal limitations, and opt-out of marketing. We implement industry-standard technical and organizational measures to protect your information. Information is retained as required by securities laws, typically 6 or more years. For questions or requests, contact cr@tsginvest.com or 631-210-7623.

Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the State of New York, USA, without regard to its conflict of law principles.

Any disputes arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the state and federal courts located in New York.

This Privacy Policy applies to the TSG Vault. For our public website privacy practices, please refer to our Website Privacy Policy in a separate section on this page.

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