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Privacy Policy

Last Updated: November 22, 2021
This Privacy policy (this “Policy”) describes how Passthrough, Inc. and its related and/or affiliated companies (the “Company,” “Passthrough,” “us,” “our,” “its,” or “we”) collects, uses, discloses, and shares personal information of investors and other users of this website, passthrough.com (“Site”). This Policy also applies to any other Passthrough online tools and platforms, and other interactions(such as customer service inquiries, user conferences, etc.) you may have with the Company.
What we collect
Passthrough gets information about you in a range of ways.
Information You Give Us. We collect your name, postal address, email address, phone number, username, password, demographic information (such as your occupation), banking information, as well as other information you directly give us on our Site.
Investor Information. If you are an investor or potential investor we collect certain information about you to allow you to participate in our customers’ fund closings. The information we collect varies based on the fund, but, in addition to the Information You Give Us, it may include your social security number or other tax identification numbers, government identification documents like passports and driver’s licenses, bank statements, proof of address, your accreditation/qualification status, the amount and source of the capital you intend to contribute to the fund, and contact information of third parties such as joint signers or partners.
Information We Get From Others. We may get information about you from other sources. We may add this to information you provide through our Site. For example, if you are an investor, we may receive Investor Information from our customers.
Information Automatically Collected. We may log information about you and your computer. For example, when visiting our Site, we may log information such as your computer operating system type, unique device identifiers, and crash data.

Cookies. We may log information using "cookies." Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your needs.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here.

Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
Third party data
Passthrough may receive data about organizations, industries, website visitors, marketing campaigns, and other matters related to our business from affiliates, subsidiaries, partners, or others that we use to make our own information better or more useful. This data may be combined with other information we collect and might include aggregate level data.
Use of personal information
Passthrough uses your personal information as follows:
To operate, maintain, and improve our sites, products, and services, including use of other information to support delivery of our services under contract, assist with service requests, monitor for errors, remedy security or technical issues, and to analyze website and application performances.
To authenticate investors’ identities and permit investors to use their authenticated identities to participate in fund closings and other regulated activities.
To respond to comments and questions, verify permission access, and provide customer service.

To send information including confirmations, invoices and billing, technical notices, updates, security alerts, and support and administrative messages.
To communicate system updates, service related notices, upcoming events, and other news and promotional messages about products and services offered by us and our selected partners that we believe will interest you.
To link or combine user information with other personal information.
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
To provide and deliver products and services that customers request.
Sharing of personal information
Passthrough may share personal information as follows:
We may share Investor Information with our customers as needed to facilitate fund closings.
We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding. The personal information shared may be shared with counterparties and others assisting with the deal.
We may share personal information for legal, protection, and safety purposes.
We may share information to comply with laws.
We may share information to respond to lawful requests and legal processes.
We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
We may share information with those who need it to do work for us. This includes granting Passthrough employees and service providers the necessary access in order to perform their duties.
We may share aggregated or anonymized data. This includes for marketing, analytics or research purposes.

We may share personal information with your consent. This includes when we engage third party companies or individuals as Service Providers to process information and support our services.
Information choices and changes
Passthrough’s marketing emails will provide information on how you can opt out. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.
Passthrough strives to provide you the tools to update your personal information. If you are unable to correct inaccurate information on your own, you may request our assistance to update such information by contacting support@passthrough.com.
Children
Our Site is not directed to children who are under the age of 16. Passthrough does not knowingly collect information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided information to Passthrough please contact us and we will try to delete that information from our databases.
Security
We implement commercially reasonable technical, administrative, and organizational measures to protect information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security measures are failsafe and we cannot guarantee the security of your personal information.
Personal Information Processing in the U.S.
By using our Service, you understand and acknowledge that your information will be transferred from your location to our facilities and servers in the United States, where data protection laws may differ from those in your jurisdiction.
Contact Information
We welcome you to email us at info@passthrough.com  with any comments or questions about this Policy. You may also contact us by letter delivered first class mail to the following address:

Passthrough, Inc.
651 N. Broad St.
Suite 206
Middletown, Delaware 19709
Changes to this Privacy Policy
We may change this Policy. If we make any changes, we will change the Last Updated date above.