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A.    Any capitalized terms used but not defined herein shall have the meaning assigned to them in the Terms and Conditions of Use found at

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

C.    Security. Stone House is strongly committed to protecting users’ privacy online and has taken steps to protect users’ information. For example, Stone House uses any one or more of the following techniques: firewalls, encryption, virtual private networks, secure access-restricted hosting facilities and much more to help protect users’ privacy. While Stone House uses SSL encryption to protect sensitive information online, we also protect user-information offline. All user information, not just sensitive information, is restricted in our offices. Only those who need the information to perform a specific job are granted access to personally identifiable information. HOWEVER, NO TRANSMISSION OVER THE INTERNET CAN BE 100% SECURE. To help Stone House protect your privacy, you should maintain the secrecy of your username and password.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

L.    California Residents. California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request: information regarding their personal data Stone House has collected (the categories of personal data collected, the source of such data, and how such data has been used); a description of whether Stone House has disclosed their personal data to third parties, and if so what categories of data have been disclosed, and to what categories of third parties); a copy of their personal data collected by Stone House in the past twelve (12) months; and that their personal data be deleted. To make such a request, California residents should contact Stone House as set forth in Paragraph N of this Privacy Policy. Stone House may require verification of the data subject’s identity before further processing the request. In certain instances, Stone House may be required or permitted by law to decline some or all of such requests. 

M.    Contact. Should data subjects have any questions, comments or concerns about Stone House’s privacy practices or wish to exercise any of their rights under this Privacy Policy, they can contact at (212) 543-1500 or 1-888-980-1290 (toll free) and

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


A.    PLEASE READ THESE LINKING AND FRAMING TERMS AND CONDITIONS (“L&F Terms”) BEFORE LINKING TO OR FRAMING THIS REPORTING SYSTEM. YOU MAY NOT LINK TO OR FRAME THIS REPORTING SYSTEM UNLESS YOU ACCEPT AND COMPLY WITH THESE L&F TERMS AS WELL AS ALL OTHER TERMS AND CONDITIONS OF SERVICE ON THIS REPORTING SYSTEM. From time to time, Stone House may modify the L&F Terms. Accordingly, please review the L&F Terms from time to time. YOUR CONTINUED ESTABLISHMENT OF A LINK TO THIS REPORTING SYSTEM OR YOUR CONTINUED FRAMING OF THIS REPORTING SYSTEM AFTER THE POSTING OF MODIFICATIONS TO THE L&F TERMS WILL CONSTITUTE YOUR ACCEPTANCE OF THE L&F TERMS, AS MODIFIED. If at any time you do not wish to accept the L&F Terms, you must discontinue linking to or framing this reporting system. Any terms and conditions proposed by you which are in addition to or which conflict with these L&F Terms are expressly rejected by Stone House and shall be of no force or effect.

B.    Restrictions on Other Linking and Framing Activities. Stone House is concerned about the integrity of this Website when it is accessed in a manner solely determined by third parties or viewed in a setting solely created by third parties. Specifically, Stone House is concerned with activities such as linking to an internal or subsidiary page of this reporting system that is located one or several levels down from the login page (“deep linking”) or bringing up or presenting content of this reporting system within another website (“framing”). In this regard, without limiting the provisions contained in these T&Cs, you must make a specific request for, and secure permission from, Stone House prior to deep linking to, or framing, this reporting system or any of its content, or engaging in similar activities. If you would like to deep link to or frame this reporting system, or any of its content, you must request permission from Stone House by writing to Please include: (a) your name, e-mail address, and telephone number; (b) the full legal name of your company; (c) its principal place of business; (d) the state of incorporation; (e) the website address(es) where the proposed deep linking or framing will occur; and (f) specific details about the contemplated deep linking or framing activities, including the content or website(s) of this reporting system to which you would like to deep link or frame.

C.    User Assent to Terms and Conditions for this reporting system. By linking to this reporting system, you represent that you have read and agree to be bound by the L&F Terms. You further represent that you have read and agree to be bound by these T&Cs for this reporting system as set forth above, as well as all other terms and conditions of service on this reporting system, including, but not limited to, obtaining permission from Stone House.

D.    Look and Feel. You acknowledge that this Website, including but not limited to the text, content, photographs, and graphics thereon, has been specially designed by Stone House for presentation in a unique format and appearance, with this Website’s look and feel (the “Look and Feel”), and that such Look and Feel is protected by copyrights, trademarks, service marks, international treaties, and/or other proprietary rights and laws of the U.S. and other countries.

E.    Restrictions on Linking to the Login page of this Website. Without limiting the provisions contained in these T&Cs, you may include a link on your website to the login page of this Website; provided, you may not link to the login page of this Website any site containing inappropriate, profane, defamatory, infringing, obscene, indecent, or unlawful topics, names, material or information, or material or information that violates any applicable intellectual property, proprietary, privacy or publicity rights.

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