Privacy Policy

Your privacy concerns are important to us at Townsend Holdings LLC (d/b/a The Townsend Group) (“Townsend”), and we are committed to protecting your privacy. Please read the following Privacy Policy to understand how your personal information will be treated as you use this website. When you use this website, you consent to the use of your personal information by Townsend in the manner specified in this Privacy Policy. This policy may change periodically, so please check back from time to time. For your information, the date of the last update to this Privacy Policy is stated at the top of this document.

Please note that Townsend’s website may contain links to other sites. Townsend is not responsible for the privacy practices, privacy statements, or content relating to these other sites.


Townsend collects and uses information about our customers and website visitors for a variety of purposes. Townsend does not collect any personally identifiable information from you (e.g., name, address, telephone number, e-mail address) unless you voluntarily choose to disclose such information. We will not sell, trade or rent your personally identifiable information to third parties. Your information may be used for research on usage patterns, online site customization and targeted marketing.

Portal: If you are a registered fund manager, you may receive information through the Townsend portal. Townsend may use your personally identifiable information to provide you access to the Townsend portal.

Cookies: Townsend from time to time may collect information about your use of this Website through the use of cookies. A “cookie” is a small data file stored by your web browser on your computer’s hard drive. Cookies allow us to recognize who you are when you arrive at our website. Information collected via cookies helps Townsend determine what areas of our website are important to our users and to provide you with a more personalized experience. Townsend does not use cookies to identify individual users.

Aggregate Information: We may from time to time collect non-personal information about our customers, and aggregate this statistical information in order to improve our website. When we say that we may share such information in “aggregate” form, we mean that we will not disclose individual names, addresses, telephone numbers and e-mail addresses unless we have your permission. External companies may be provided aggregate information about our customers.

Use of IP Addresses: An Internet Protocol (“IP”) address is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers automatically identify your computer by its IP address. When visitors request pages from the website, our servers log the guests’ IP addresses. We do not normally link IP addresses to anything personally identifiable, which means that a visitor’s session will be logged, but the visitor remains anonymous to us. Townsend collects IP addresses for the purposes of system administration and to audit the use of this Website. We may also use IP addresses to collect statistical information for our marketing and promotional purposes.

Information from Children: Townsend does not direct its website to children under thirteen (13) years of age. Individuals under eighteen (18) should consult with their parent or guardian about the use of this website for their benefit.

Monitoring, Enforcement and Legal Requests: Townsend has no obligation to monitor the website or the use of the website, or to retain the content of any user session. However, Townsend reserves the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, regulation, legal process, or governmental request or to cooperate with law enforcement and other authorities in investigating a claim of illegal activity. We may use IP addresses to identify a user when we feel it is necessary to protect our service, website, customers, or others.

Change of Ownership or Control: If Townsend becomes owned or controlled by other individuals or entities, the information we have collected may be transferred to such party or parties. In this case, such individuals or entities will follow this Privacy Policy.

Other Sites: Except as otherwise expressly discussed in this Privacy Policy, this policy only addresses Townsend’s use and disclosure of information we collect from you. To the extent that you disclose personal information to other web sites, you are subject to the privacy customs and policies of these other websites. We encourage you to ask questions before you disclose any personal information.


Transmission Errors or Unauthorized Acts: Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Townsend cannot ensure or warrant the security of any information you transmit to us or any information provided by our on-line products or services, and you do so at your own risk. Townsend will not be liable for disclosures of your personal information due to errors in transmission or unauthorized acts of third parties. However, once we receive your transmission, we do our best to ensure its security on our systems by making reasonable efforts to protect the information.

Security: Any information provided to Townsend is treated with care and discretion. When information is shared, Townsend will take a proactive approach to ensure the information is kept private and not misused.

Passwords: If you are a registered fund manager, your account and personal information is password protected. Townsend encrypts your password on its database. However, you are responsible for maintaining the confidentiality of your password. Therefore, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also, remember to close your browser window when you have finished using our Web Site.

Encryption: When you submit personal information to Townsend, we may encrypt it. Encryption is the industry standard means to protect information as it passes over the Web to our server. We use care to protect this information against unauthorized access and modification once it is stored on our database.


Your Choice: Townsend respects your decisions about the collection and use of your information. You have the opportunity to elect to receive future press releases and investor-oriented materials from us. Based on this choice, you may receive information from Townsend or a trusted third party. Every communication we send to you will contain instructions on how to cancel receiving similar information in the future. By accessing and using this website, you consent to the use of your personal information by Townsend in the manner specified in this Privacy Policy.

Update Information: If you have given Townsend information in the past and now wish to change such information, please contact us at (216) 781-9090. Although Townsend will make reasonable efforts to make the changes you have requested, we may be unable to update other types of information provided to us, such as aggregate or cookie information, or information that has been stored in our system.

Delete Information: If at any time you wish to stop receiving information that we think you will find valuable, you can elect to do so by contacting us at (216) 781-9090. You can also choose to delete your profile from our active database by either using the online system or by e-mailing us at the same address. Unfortunately, Townsend may not be able to delete other types of information, such as aggregate or stored information.


No Offer of Securities – Disclosure of Interests

Under no circumstances should any material at this site be used or considered as an offer to sell or a solicitation of any offer to buy an interest in any security, investment fund, real estate or other real asset. The material on this website does not constitute, and may not be used in connection with, an offer or solicitation by anyone in any jurisdiction in which such offer or solicitation is not permitted by law or in which the person making such offer or solicitation is not qualified to do so or to any person to whom it is unlawful to make such offer or solicitation. Access to information about any accounts is limited to investors who, among other requirements, either qualify as accredited investors within the meaning of the Securities Act of 1933, as amended, or those investors who generally are sophisticated in financial matters, such that they are capable of evaluating the merits and risks of prospective investments.


The information contained herein is not investment advice. Any specific investments listed or discussed do not represent any or all investments purchased, sold or recommended for advisory clients since inception. One should not assume that all investments identified are or will be profitable.


Privacy and security is important to us all. We pursue a full-disclosure approach to responsibly care for the information you have entrusted with us, and we depend on information sharing as our principal means to best serve you. This is why we are committed to building a trusting relationship with you. We will continually monitor customer feedback and seek to improve our services to meet your needs. If you have any questions about this Privacy Policy, the practices of this website, or your dealings with this website, or would like to provide comments, please contact us at (216) 781-9090.