Website Privacy Policy

Working Hard to Keep Pace with very heigh Demand

How we handle your data The privacy practices of this Website Privacy Policy apply to our services available under the domain and subdomains of www.metzora.com (the "Website"). We recognize that privacy is important to our users, so we design and operate our Website with the protection of your privacy in mind. This Website Privacy Policy outlines the types of personal information we may gather when you visit our Website or use our services, as well as some of the steps we take to safeguard it. Please read this Website Privacy Policy to learn more about the ways in which we protect, use and disclose your personal information. By visiting the Website, you agree to be bound by the terms and conditions of this Website Privacy Policy. If you do not agree, please do not use or access the Website.

By accepting the Website Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Website Privacy Policy. This Website Privacy Policy is incorporated into and subject to the Terms of Use. This Website Privacy Policy is effective when accepted by new users, and is otherwise effective on December 1, 2014, for all users.

At Metzora Capital (“PA”) maintaining our customers’ trust and confidence is of paramount importance. We are committed to safeguarding your personal information and providing you with facts and options about how this information may be shared. Please read this notice to learn more about our privacy policies and the options available to you.

This notice replaces all previous statements of our website privacy policy, and may be amended at any time.

Metzora Capital maintains a separate Privacy Policy for non-website interactions which is available upon request. Those investors to which PA Capital provides investment advisory services will be provided with annual reminders of our non-website policies and with revised policies if there are any changes in how we handle the investor’s personal information. If an investor ends their relationship with PA, we will continue to adhere to the policies and practices described in our non-website Privacy Policy.

Information That We Collect. As part of providing you with our services, we obtain nonpublic personal information about you, which may include the following:

Information we receive from you on applications or other forms including name, address, social security number, assets and income. Information about your transactions with us or others.

Information That We Share & Why It Is Important. We use or share information in a limited and carefully controlled manner. We do not disclose any nonpublic information about our customers or former customers to anyone, except as permitted by law, unless authorized by you. Instances in which we may share your information with nonaffiliated third parties include:

Inclusion of certain names (institutional clients only) on a Representative Client List.

The Representative Client List is contained in our standard marketing material and examples of those who may receive the list include: existing clients, prospective clients, consultants for prospective clients and prospective hedge fund managers. The majority of PA’s assets under management are institutional assets. As a result, institutional assets in general are perceived as stable capital sources and hedge fund managers tend to be biased towards favoring these assets. As we meet with prospective hedge fund managers, we believe our Representative Client List gives PA an advantage when trying to gain access to funds that accept capital on a limited basis.

(NOTE: The Representative Client List includes language stating that the names on the list are not to be construed as an endorsement or recommendation of PA’s services.)

Disclosure to companies that provide services necessary to effect a transaction that you request or to service your account such as prime brokers, accountants, banks, attorneys or administrators. Disclosure to government agencies, courts, parties to lawsuits, or regulators in response to subpoenas. In such cases, we share only the information that we are required or authorized to share.

Collection of Information

In general, you can browse the non-password-protected sections of the Website without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users' demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Website or not), to which URL you next go (whether this URL is on the Website or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.

We also may use data collection devices such as "cookies" on certain pages of the Website to help analyze our web page flow, measure effectiveness, and promote trust and safety. "Cookies" are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a "cookie". Cookies can also help us provide information that is targeted to your interests. Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Website and you may be required to reenter your password more frequently during a session. We use cookies to better understand how people interact with us.

If you apply for a password to access password-restricted areas on this Website, you must provide to us with the following:

Your full name
Your mailing and email address
Your phone number
Your personal financial data
Your investment portfolio and other investment information

Use and Disclosure of Information

The security of your account information is important to us. Only those persons who need your information to perform their job have access to it. In addition, we maintain physical, electronic and procedural security measures that comply with federal regulations to protect your information. Our employees have limited access to your personal information based upon their responsibilities. All employees are instructed to protect the confidentiality of your personal information as described in these policies, which are strictly enforced.

We use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use. If you apply for a password, we use that data to determine whether you are an accredited investor and have sufficient sophistication, investment experience and wealth to receive information about certain investment options. We may use your information to send correspondence and perform services on your behalf in connection with investment related activities.

You agree that we may use personal information about you to analyze Website usage, improve our content and product offerings and customize the Website's content, layout, and services. These uses improve the Website and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Website.

In connection with providing our services, it also may be necessary for us to share information with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios. In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities. In those circumstances, we require such third parties to treat your private information with the same degree of confidentiality that we do. In some instances, the third-party service provider may collect information directly from you. In these cases, you will be notified of the involvement of the service provider, and all additional information you provide them and their additional uses will be strictly up to you. If you provide additional information to a service provider directly, their use of your personal information is governed by their applicable privacy policy.

We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.

We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not described in this Website Privacy Policy. For example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Website. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties (through our Representative Client List), you may “opt out” of those disclosures. This means that you may direct us not to include your name on our Representative Client List (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may call our Chief Compliance Officer at PA’s main number: (804) 289-6000. You may exercise this right to opt out at any time.

Control of Your Password and Personal Information

You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your user name or password to access or use any part of this Website. If your password has been compromised for any reason, you should contact us immediately for a new password.

You can review and change the information that you submit to us by contacting us at clientservices@pacapital.com. You can change your User ID, email address, contact information, financial information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate.

On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy.

We will retain in our files the personal information you have asked us to remove from our active databases to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and comply with legal requirements. Therefore, you should not expect that your personal information will be completely removed from our databases in response to your requests. However, such personal information will only be available to select employees, service providers and governmental persons or entities.

Security

Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, "firewalls" and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company. However, "perfect security" does not exist on the Internet.

Children

Persons under age 18 are not eligible to use the Website.

Conditions of Use

If you choose to visit the Website, your visit and any dispute over privacy is subject to this Website Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the Commonwealth of Virginia. If you have any concern about privacy, please send a thorough description

Changes to this policy

This Website Privacy Policy may change from time to time. We may amend this Website Privacy Policy at any time by posting the amended terms on the Website. All amended terms shall automatically be effective 30 days after they are initially posted on the Website.

If you have any questions about this Privacy Notice, you may call us at (778) 268-1148.

Metzora Capital

Your Rights

You have various rights with respect to our use of your personal data:

Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access will be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
Objection: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.
Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint to the applicable supervisory authority or to seek a remedy through the courts.

Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data.

When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

How long we keep your personal data

We will retain your personal data, whether or not your account is active, for as long as we believe it necessary or desirable to fulfil our business purposes and to comply with applicable law and regulation, audit requirements, regulatory requests or orders from competent courts.

Personal Data collected will be retained pursuant to our record retention policy, and in most instances will not be retained longer than nine (9) years from the date you cease to be an investor in a PA Capital fund or a separately managed account.

Changes to our privacy notice

Any changes we make to our Privacy Notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Notice.

Metzora FUNDS RISK FACTORS

Please note that the following are not all the risk factors associated with Digital Assets or the Funds. Refer to the Offering Memorandum of the applicable Fund for more risk factors.

Investment Risks Generally. An investment in the Fund, involves a high degree of risk, including the risk that the entire amount invested may be lost. A Fund will invest in directly or through other pooled investment vehicles (“Other Private Funds”) in Digital Assets (such as Bitcoin, Ethereum, other cryptocurrencies or blockchain based assets, including those that represent the Decentralized Finance (or DeFi) portion or sector of the digital assets market) using strategies and investment techniques with significant risk characteristics, including risks arising from the volatility of the global Digital Assets markets and the risk of loss from counterparty defaults. The Fund’s investment program may use investment techniques that involve substantial volatility and can, in certain circumstances, substantially increase the adverse impact to which the Fund may be subject. All investments made by the Fund will risk the loss of capital. No guarantee or representation is made that the Fund’s investment program will be successful, that the Fund will achieve its investment objective or that there will be any return of capital invested to investors in the Fund, and investment results may vary.

Different from Directly Owning Bitcoin, Ethereum or Other Digital Assets. The performance of the Fund will not reflect the specific return an investor would realize if the investor actually purchased a Digital Asset. Investors in the Fund will not have any rights that Digital Asset holders have.

No Guarantee of Return or Performance. The obligations or performance of the Fund or the returns on investments in the Fund are not guaranteed in any way. Any losses of the Fund will be borne solely by investors in the Fund. Ownership interests in the Fund are not insured by the Federal Deposit Insurance Corporation, and are not deposits, obligations of, or endorsed or guaranteed in any way, by any banking entity.

Regulation. Digital Assets, including Bitcoin, Ethereum and DeFi tokens, are loosely regulated. Ongoing and future regulatory actions may alter, perhaps to a materially adverse extent, the value of a Fund’s investment. If any Digital Asset is determined to be a “security” under U.S. federal or state securities laws or a Digital Asset exchange is determined to be operating illegally, it may have material adverse consequences for Digital Assets due to negative publicity or a decline in the general acceptance of Digital Assets. As such, any determination Digital Asset exchanges are operating illegally or that any Digital Asset is a security under U.S. federal or state securities laws may adversely affect the value of a particular Digital Asset or Digital Assets generally and, as a result, the value of a Fund’s investment.

Exchanges. Exchanges may suffer from operational issues, such as delayed execution, that could have an adverse effect on the Fund. Digital Asset exchanges have been closed due to fraud, failure or security breaches. Any of the Fund’s funds that reside on an exchange that shuts down or suffers a breach may be lost.

Value. Several factors may affect the price of Digital Assets, including Bitcoin, Ethereum and DeFi tokens, including, but not limited to: supply and demand, investors’ expectations with respect to the rate of inflation, interest rates, currency exchange rates or future regulatory measures (if any) that restrict the trading of a Digital Asset or the use of a Digital Asset as a form of payment. There is no assurance that a Digital Asset will maintain its long-term value in terms of purchasing power in the future, or that acceptance of bitcoin payments by mainstream retail merchants and commercial businesses will continue to grow.

Protocol. Many Digital Asset networks, including Bitcoin, Ethereum and DeFi tokens, operate on open-source protocols maintained by groups of core developers. The open-source structure of these network protocols means that certain core developers and other contributors may not be compensated, either directly or indirectly, for their contributions in maintaining and developing the network protocol. Lack of incentives to, or a failure to properly, monitor and upgrade network protocol could damage a Digital Asset network. It is possible that a Digital Asset protocol has undiscovered flaws that could result in the loss of some or all assets held by the Fund. There may also be network-scale attacks against a Digital Asset protocol, which could result in the loss of some or all of assets held by the Fund. Advancements in quantum computing could break a Digital Asset’s cryptographic rules. The Fund makes no guarantees about the reliability of the cryptography used to create, issue, or transmit Digital Assets held by the Fund.

Volatility & Supply. Values of Digital Assets have historically been highly volatile, experiencing periods of rapid price increase as well as decline. For instance, there were steep increases in the value of certain Digital Assets, including Bitcoin, over the course of 2017, and multiple market observers asserted that digital assets were experiencing a “bubble.” These increases were followed by steep drawdowns. During the period from December 17, 2017 to February 5, 2018, Bitcoin experienced a decline of roughly 60%. More recently, during the period from February 13, 2020, until March 16, 2020, the value of Bitcoin fell by over 50%. Bitcoin had a strong start to 2021, hitting an all time high of nearly$65k in April. But, it closed H1 2021 down 47% from its record. Supply of Digital Assets is determined by computer code, not by a central bank. For example, uncertainty related to the effects of Bitcoin’s recent and future “halving” could contribute to volatility in the Bitcoin markets. The value of the Bitcoin or other Digital Assets held by a Fund could decline rapidly in future periods, including to zero.

Decentralized Finance (DeFi) Risks. Decentralized Finance (or DeFi) refers to a variety of blockchain-based applications or protocols that provide for peer-to-peer financial services using smart contracts and other technology rather than such services being offered by central intermediaries. Common DeFi applications include borrowing/lending Digital Assets and providing liquidity or market making in Digital Assets. Because DeFi applications rely on smart contracts, any errors, bugs, or vulnerabilities in smart contracts used in connection with DeFi activities may adversely affect such activities. DeFi lending is subject to counterparty risk and credit risk, but because lending is automated through the DeFi protocol, rather than individual decisions made by a portfolio manager on behalf of a Fund, such risks may be exacerbated, particularly if there are flaws in DeFi protocol’s code or operation. DeFi applications may involve regulated financial products or regulated activities, however because of their decentralized nature, there is generally no entity subject to regulatory supervision. Accordingly, DeFi applications may be subject to more risks than engaging in similar activities through regulated financial intermediaries. In addition, in certain decentralized protocols, it may be difficult or impossible to verify the identity of a transaction counterparty necessary to comply with any applicable anti-money laundering, countering the financing of terrorism, or sanctions regulations or controls. All of these risks could cause the value of DeFi tokens held by a Fund to decline, including to zero.

Fund of Funds Risks. A Metzora Vision Hill Fund’s approach to investment in Other Private Funds subjects the Fund to risks and expenses of the Other Private Funds. Such risk encompasses the possibility of loss due to the Other Private Funds’ fraud, intentional or inadvertent deviations from a predefined investment strategy (including excessive concentration, directional investing outside of predefined ranges, excessive leverage, or new capital markets), or simply poor judgment. The returns of the Other Private Funds are impacted by the ability of the Other Private Funds and their general partners or investment managers, in their capacity as the investment manager to the Other Private Funds, to successfully apply their investment techniques to generate profits for the Other Private Funds. The volatility of the Other Private Funds will depend on the nature of their exposure to investments and on each general partner or investment manager, in their capacity as the investment manager to the Other Private Funds, ability to reduce risk by trading and hedging techniques. There can be no assurance that the Other Private Funds will achieve their objectives or avoid substantial losses During the lifetime of the Fund, there could be material changes in the Other Private Funds The effect of such changes of the Other Private Funds cannot be predicted but could be material and adverse Under certain circumstances, the Fund may not be able to exit an underlying investment in the Other Private Fund or alter its portfolio allocation in response to any such changes, which may result in substantial losses from investing in the Other Private Funds. All of these risks could cause the value of the Other Private Funds held by the Fund to decline, including to zero. The fund of funds structure also exposes investors to multiple layers of expenses and fees. Fund investors will incur management, performance, advisory, sponsorship or other fees and expenses due to the Fund’s investing in or allocating assets to Other Private Funds. Further, the Other Private Funds investments will subject the Fund to normal operating fees and expenses, including exchange commissions or other fees and costs associated with their investments. Performance fees will be calculated separately for each Other Private Fund, so the Fund could bear substantial performance fees in respect of Other Private Funds whose trading is profitable even when the Fund as a whole has a loss. The fees and expenses of the Other Private Funds are in addition to those incurred by investors through an investment in the Fund itself. Such layers of fees could be substantial and have a material adverse effect on performance of an investment in the Fund.

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