Privacy Policy

Welcome to Pathfinder Partners

Privacy Policy Last Revised: March 20, 2026

Pathfinder Partners (“Company” or “We”) has created this Privacy Policy in order to set forth the principles governing our information-gathering and dissemination practices, including but not limited to such activities as forums, chat rooms, personal profile pages, product reviews, article commentary, blogs, RSS feeds and newsletters, among other offerings, all available through our site at www.pathfinderfunds.com (the “Site”), and any related services (the “Services”).

This policy applies to information we collect:

• On this Site.
• In email, text and other electronic messages between you and this Site.
• Through our mobile and desktop application you download from this Site.
• Through direct communications with the Company in email, text, telephone, or any other medium.

It does not apply to information collected by:

• The Investor Portal or any means to collect nonpublic Investor account information for the purposes of providing advisement and related financial services that are subject to the Gramm-Leach-Bliley Act (“GLBA”) at 15 U.S.C. §§ 6281, et seq.), for more information about our collection of information related to your investments, please see https://www.junipersquare.com/privacy-policy;
• Websites operated by any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Site, except as expressly provided herein.

Information We Collect

“Personally Identifiable Information” or “PII” is any information that personally identifies you, such as your name, street address, email address, or telephone number. We collect PII such as user email addresses when you subscribe to our email newsletter or participate in other interactive online activities or Services. Similarly, we collect your full name, email, phone number, and company, when you directly provide this information on our “Contact Us” page. If you post messages, text, comments, or other content at various places on our Site, the information you volunteered contained in your posting will be stored on our servers and other users will be able to see it.

When you submit your email address to subscribe to our digital communications, e.g. our newsletter, you opt-in to these services and we collect this PII from you for the purpose of delivering our digital communications. You can opt-out of receiving these digital communications from us by following the instructions and links provided at the bottom of each communication to “Unsubscribe.” If you use this method, you will stop receiving promotional communications from us or our business partners.  Alternatively, if you are a registered Community member of Pathfinder Partners, you may manage your membership information as well as your subscriptions. Simply login to your community account and click on “Account Options.” Click on the tab marked “Account” to manage your password and email address; click on the tab marked “Subscriptions” to manage your newsletter subscriptions and click on the tab, “Profile” to edit your public profile.

Use of “Cookies”

By using our Site, we collect identifiers at the browser-level, such as Internet Protocol (“IP”) addresses, geolocation data, and your interactions with our Site and advertisements, through the use of cookies and other similar technologies. The Site uses “cookies” and similar technologies to enhance and help you personalize your online experience. A cookie is a small text file placed on your device by a webserver through your browser. Cookies cannot be used to run programs or deliver viruses to your computer. Each cookie is uniquely assigned to you on your device and can only be read by a web server in the domain that issued the cookie.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Pathfinder Partners pages, or register with the Site or Services, a cookie helps to the Site recall your specific information on subsequent visits. When you return to the same Site, the information you previously provided can be retrieved, so you can easily use the Pathfinder Partners features that you customized.

You have the ability to accept or decline cookies. The Pathfinder Partners website gives you the option to accept or reject cookies when you access it.  Many other web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Services or web sites you visit.

Flash Cookies (or “Flash LSOs”)

When we post informational videos about our Services, third parties may use local shared objects (“LSOs”), known as “Flash Cookies,” to store your preferences such as volume control or to personalize certain video features. Flash Cookies are different from standard browser cookies in that they may store data outside of the browser’s cookie storage and are managed through different browser or device settings. As a result, setting your cookie preferences on our Site will not translate to the removal of Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information to: present you with our Site; provide you with information, products, or Services that you request from us; provide you with information, products, or Services that we think may be of interest to you; to fulfill any other purpose for which you provide it; to carry out our obligations and enforce our rights; to allow you to participate in interactive features on our Site; in any other way we may describe when you provide the information; or for any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may share your Personally Identifiable Information such as your name, account name and postal address with third party service providers we use to support our business to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other Services by the Company. These third-party service providers are required not to use your Personally Identifiable Information other than to provide the Services requested by Company.

We may also disclose personal information that we collect or you provide as described in this policy to our subsidiaries and affiliates to: provide you with Services that we offer you through our Site; provide you with information, products, or Services that you request from us; provide you with information, products, or Services that we think may be of interest to you; in any other way we may describe when you provide the information; or for any other purpose with your consent.

As we continue to develop our business, we may buy, merge or partner with other companies or businesses, and in so doing, acquire or share information about Site users or investors. In such transactions, Personally Identifiable Information held by the Company may be among the transferred assets. Similarly, in the event that a portion or all of Pathfinder Partners’ assets are sold or transferred to a third party, Personally Identifiable Information held by the Company would likely be among the transferred business assets.

Notwithstanding any other provision of this Privacy Policy, we may disclose certain Personally Identifiable Information to others if we are required to do so by law or we in good faith believe that such action is reasonably necessary to (a) comply with the law or with legal process; (b) protect and defend our rights or property; (c) protect against misuse or unauthorized use of the Site; or (d) protect the personal safety or property of our users or the public. Please note that we may not provide you with notice prior to disclosure in such cases, but any personal information disclosed will be limited to the information necessary to fulfill any of the purposes described therein.

External Third-Party Websites

Pathfinder Partners contains links to external third-party websites not owned or controlled by Pathfinder Partners. Pathfinder Partners is not responsible for the privacy practices or the content of such third-party websites. Inclusion of any linked website on Pathfinder Partners’ Site does not imply or express Pathfinder Partners’ approval or endorsement of the linked website or of any of the content, opinions, products or services provided on these websites. Even if an affiliation exists between Pathfinder Partners and a third-party website, we exercise no control over linked sites or the data collected by the third-parties via their websites. Each of these linked sites maintains its own independent privacy and data collection policies and procedures. If you visit a third-party website through a link on our Site, we encourage you to consult that third-party’s privacy policy before providing any personal information and whenever interacting with any such website.

Information You Provide to Facebook and other Social Networking Sites

The Services allow users to access our Facebook page to interact with friends and to share on Facebook through Wall posts and friends’ News Feeds. If you are already logged into the Services and Facebook or another Social Networking Site (“SNS”), when you click on “Connect with Facebook,” or a similar SNS icon, you will be prompted to merge your profiles. If you are already logged into the Services, but not logged into Facebook or another SNS that we support, when you click on “Connect with Facebook,” or a similar SNS icon, you will be prompted to enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you are allowing the Services to access your information, and you are agreeing to Facebook or other SNS’s Terms of Use in your use of the Services. Conversely, if you are not currently registered as a user of the Services, and you click on “Sign in” using Facebook or another SNS that we support, you will first be asked to enter your Facebook or SNS credentials and then be given the option to register for the Services. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an account on the Site and show our relevant content from your Facebook or SNS friends. Once you register on the Site and connect with Facebook or another SNS, you will be able to automatically post recent activity back to Facebook or the other SNS. Any information that we collect from your Facebook or other SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices. You can edit privacy settings for the reviews that appear on Facebook or disconnect your Services activity stream by visiting the Facebook Applications Settings page.

Public Forums

Pathfinder Partners may make chat rooms, forums, blogs, articles commenting, and personal profile pages (“public forum”) available to users. Please remember that any such information that you may choose to provide on these public forums becomes accessible to the public and also becomes the property of Pathfinder Partners in accordance with our Terms and Conditions. We cannot control the actions of other users of the Site with whom you knowingly choose to share your information on the public forums. Consequently, you should exercise caution when deciding to disclose your personal information or uploading material of any kind.

Policy Regarding Users Outside of the United States

If you are a non-U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal data may be processed for the purposes identified in this Privacy Policy. In addition, your personal data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

Consent and Modifications to this Privacy Policy

Pathfinder Partners is controlled, operated and administered entirely within the United States. By using the Pathfinder Partners Site, Investor Portal, and/or participating in the activities of Pathfinder Partners’ community, you signify your agreement to the terms of this Privacy Policy. If you do not agree with this Privacy Policy, please do not disclose any personal information through our Site, Investor Portal or to us generally. At its discretion, Pathfinder Partners may modify this Privacy Policy at any time.  Modifications are effective upon being posted on the Site and your continued use of the Site after we make changes is deemed acceptance of those changes, so please check the policy periodically for changes.

Contacting Pathfinder Partners

If you have any questions about this Privacy Policy, you may contact us at:

Pathfinder Partners
Attn: Privacy
1111 6^th Ave., Suite 550

PMB 452738
San Diego, CA 92101-5211

Email: info@pathfinderfunds.com
Phone: 858-855-3977

This Privacy Policy is effective as of the date written above and supersedes all earlier versions of our Privacy Policy.