Terms of Use

Updated: July 7, 2025

Payment information

Credit and Debit card information will be securely stored in compliance with payment card industry data security standards (PCI DSS). By accepting these terms, you authorize that your card on file will be used in processing future payments to the Manager of My Alts Data, which is First Oregon LLC. Within the My Alts Data platform, we use PayPal, which is fully PCI compliant, so the processing, storing, and transmitting of User card data for subscriptions will meet or exceed PCI standards

Performance

During the Term of this Agreement, First Oregon LLC (First Oregon) through its My Alts Data platform, will perform data archiving, data processing, market intelligence, development, and/or maintenance and support services on a time and materials basis, or as otherwise provided in an individual Statement of Work (as defined below).

Statements of Work

First Oregon shall perform the services provided in the signed Pricing Statement of Work(s) (“SOWs”) in any other SOW which the parties may enter from time to time (the “Services” provided in the “SOWs”). Any SOW shall be considered to be incorporated by reference as a part of this User Agreement. In general, a SOW shall be subject to the terms and conditions provided in this Agreement, but in case of any inconsistency between a SOW and the terms of this User Agreement, including but not limited to cost, timing, and service levels, the terms of the SOW shall govern.

As a Subscriber to the My Alts Data Platform, you may open a Data Account and become a User, subject to the following Term of Use:

AS USED HEREIN, THE TERMS “YOU”, “SUBSCRIBER” AND “USER” SHALL MEAN ANY USER OF THE “MY ALTS DATA” PLATFORM.

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY. BY ACCESSING THIS WEBSITE AND OPENING AN ACCOUNT YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS BELOW. THESE TERMS AND CONDITIONS ARE SUBJECT TO CHANGE WITHOUT NOTICE, FROM TIME TO TIME IN OUR SOLE DISCRETION. WE WILL NOTIFY YOU OF AMENDMENTS TO THESE TERMS AND CONDITIONS BY POSTING THEM TO THIS WEBSITE. IF YOU DO NOT AGREE WITH THESE TERMS AND CONDITIONS, PLEASE DO NOT ACCESS THIS WEBSITE.

Our website located at www.MyAltsData.com ( the “Website”) is a copyrighted work containing software systems and data belonging to First Oregon LLC ( the ”Company,” “us” and “we”).

You are strictly prohibited from unauthorized use of our systems and data, reverse engineering or copying our software or any features of this Website, including but not limited to unauthorized entry into our systems, misuse of passwords, or misuse of any information posted to this Website.

You understand that the Website contains the My Alts Data Platform (the “Platform”) strictly designed for receiving, storing and communicating data (“Fund Data”) about privately offered funds, products and similar alternative investments (“Private Funds”) in and through My Alts Data Accounts (“Data Accounts”) maintained on the Platform.

No custodial or customer securities account purchase and sale functions are performed. No investment advice, recommendations or discretionary management services are provided by First Oregon LLC or pursuant to these Terms of Use.

My Alts Data Accounts

The Platform allows you as a User to open a Data Account as one of four User types:

Client: a person or entity that has invested in one or more Private Funds;
Advisor: a registered investment advisor or other trusted person advising one or more Investors (See Advisor Supplement);
Private Fund: Sponsors and Managers of a private fund, involving third party Investors (See Private Fund Supplement); and
Compliance: a registered person supervising financial advisors or the activities of private fund sponsor and their communications with investors and other financial advisors.

Each User by opening a Data Account becomes subject to these Terms of Use, which when updated, will be available when signing in as a User to the My Alts Data platform.

In order to use certain features and services of the Platform, you must open a Data Account and provide certain information about yourself as prompted by the Account Registration Form. You represent and warrant that: (a) all required registration information you submit is truthful and accurate; (b) you will maintain the factual accuracy of such information. You may delete your Account at any time, for any reason, by following the instructions on the Website. The Company may suspend or terminate your Account in accordance with this Agreement. You are responsible for maintaining the confidentiality of your Account login and other information and are fully responsible for all activities that occur in and pursuant to your Account. You agree to immediately notify the Company of any unauthorized use or suspected unauthorized use of your Account or any other breach of security. The Company cannot and will not be liable for any loss or damage arising from your failure to comply with the above requirements

Data Input

Opening a Data Account enables you as a User to enter, view and modify selected Data about one or more Private Funds (“Fund Data”) in which you and one or more Investors hold positions. Fund Data shall be factual in nature and presented in a uniform format ( the “Fund Data Screen”) established by us. We retain absolute discretion as to the form and type of content on your Fund Data Screen for each Fund and may require addition or deletion, position and accessibility of Fund Data on your Fund Data Screen at any time and for any reason.

Users who are Investors or advisors may enter Fund Data on their individual Account Fund Data Screens. That Fund Data is the password protected property of the individual User and not any other User, whether or not a Private Fund or an Adviser.

A Private Fund may also open an Account containing Data Screens which carry Fund Data posted by that Fund. Fund Data posted on a Fund Data account is the exclusive property of the Fund and cannot be altered without Fund permission. Should a Fund desire to make its Data generally available to all User Accounts or modify existing available data the Platform will automatically notify User Accounts tracking that Fund to add or replace Data specific to that Fund to keep its data accurate and current. Fund Data Account Users must, in addition, agree to the attached Private Fund Supplement.

Data Priority Hierarchy

Advisors to one or more Clients may also open Data Accounts on which they may maintain Fund Data. Clients and Advisors may enter in their own Accounts Fund Data for Private und(s) that they own for tracking purposes. However, once the Client invites an Advisor to view Fund positions in the Client Account, that Advisor may edit details about a particular Fund for additional accuracy, providing the Client is informed of these changes. Any changes made to a fund’s details, will be updated in the Client’s account view in real time, and a Client will receive a push notification by email or text of such an update.

Private Fund Sponsors who have a subscription to My Alts Data will have ultimate account privileges as to inputting private Fund Data, reflected in any Account that holds that particular fund position, and cannot be overwritten by a client or Advisor. Any changes made to a fund’s details, will be updated in the Client’s account view in real time, and a client will receive a push notification by email or text of such an update.

The accuracy, completeness and timeliness of all Fund Data placed in the Fund Data Account and any other Account is the sole responsibility of the User who placed it there. First Oregon, LLC shall have responsibility only for maintaining User access to the Fund Data Screens and the format and operation of the Screens. First Oregon shall have absolutely no responsibility or liability for the accuracy, completeness or timeliness of any Fund Data or the right of any User to make any modification. We retain absolute discretion to monitor, accept or reject the addition or removal of any Fund Data, the time schedule of updates and the authority of any User to make changes. We may impose restrictions and other conditions on data presentation, access, use and reproduction. We may, in our sole discretion, remove any or all Fund Data and terminate any Screen or access at any time.

User should be cautioned that the values and other data entered into the My Alts Data Platform may constitute estimates only and may not accurately represent the facts.

This is due to various factors, such as:

Data Collection Methods: The data might be derived from a variety of sources with varying levels of accuracy and reliability.
Private Fund Market Volatility: Market values can fluctuate rapidly, making any Data outdated.
Lack of Real-Time Updates: The platform might not have up-to-the-minute Data, leading to potential inaccuracies.
Assumptions and Models: Data might be based on certain assumptions or models that could prove to be factually incorrect .

The Platform and all worldwide intellectual property rights in the My Alts Data system, code and software are the exclusive property of the Company. All rights not expressly granted to Users in this Agreement are reserved by the Company. Except as expressly set forth herein, no express or implied license or right of any kind is granted to any User.

You acknowledge that we may disclose and transfer any information that you provide through this Website to (i) a Fund in which you may own an interest, (ii) an Advisor or Client you choose to advise or communicate with respect to a Fund, (iii) First Oregon LLC, the platform administrator, its affiliates, agents or information providers; (iv) to any other person or entity with your consent; or (v) if we have a right or duty to disclose or are permitted or compelled to disclose such information by law. You consent to the transmission, transfer or processing of such information to, or through, any country in the world, as we deem necessary or appropriate, and by using and providing information through this Website you agree to such transfers.

Use of this Website and the My Alts Data Platform may be monitored, tracked and recorded. Anyone using this Website expressly consents to such monitoring, tracking and recording. You are responsible for being familiar with the current version of these Terms and Conditions posted on the Website during each session.

You agree that (i) you will not engage in any activities related to this Website that are contrary to applicable law, regulation or the terms of any agreements you have with us, and (ii) in circumstances where locations of this Website require identification for access, you will establish commercially reasonable security procedures and controls to limit access to your password or other identifying information to authorized individuals. You agree that you will not use any robot, spider, other automatic device or manual process to monitor or copy our web pages, data or the content contained herein or for any other unauthorized purpose without our prior expressed written permission.

User Fees

By accessing this Website subscribers become Users who agree to a monthly subscription containing these Terms of Use, for User subscription fees set forth below:

Client $29.95
Advisor: $49.95
Fund Sponsor: $99.95
Compliance $49.95

Monthly User Fees may be waived or increased at any time. This monthly fee is paid via debit or with credit card only. Monthly subscriptions renew automatically unless cancelled prior to the renewal date. Any User may cancel its Subscription at any time.

Suitability and Appropriateness

First Oregon LLC is not a registered adviser and does not provide investment advice. Securities mentioned in the Website may not be suitable or appropriate for all investors. Your individual needs, investment objectives and financial situation were not taken into account in the preparation of this Website and the materials contained herein.

You must make your own independent decisions regarding any securities or financial instruments mentioned herein. You should consider whether an investment strategy or the purchase or sale of any product is appropriate for you in the light of your particular investment needs, objectives and financial circumstances.

Potential Disruption of Service

You shall be responsible for obtaining and maintaining all telephone, computer hardware, software, and other equipment needed to access and use this Website. Access to this Website may from time to time be unavailable, delayed, limited or slowed due to, among other things:

hardware failure, including among other things, failures of computers (including your own computer), servers, networks, telecommunication lines and connections, and other electronic and mechanical equipment;
software failure, including among other things, bugs, errors, viruses, configuration problems, incompatibility of systems, utilities or applications, the operation of firewalls or screening programs, unreadable codes, or irregularities within particular documents or other content;
overload of system capacities;
damage caused by severe weather, earthquakes, wars, insurrection, riots, terrorism, civil commotion, act of God, accident, fire, water damage, explosion, mechanical breakdown or natural disasters;
interruption (whether partial or total) of power supplies or other utility of service;
strike or other stoppage (whether partial or total) of labor;
governmental or regulatory restrictions, exchange rulings, court or tribunal orders or other human intervention; or
any other cause (whether similar or dissimilar to any of the foregoing) whatsoever beyond our control.

If access to this Website is unavailable, delayed or limited, or if this Website does not operate quickly and efficiently, you may be unable to view, edit or input private fund data promptly or you may be unable to retrieve information on a timely basis. If your operations are dependent on such communications with us, and such communications are disrupted or delayed, you may experience delays. First Oregon will not be liable for any such delays.

Website content and materials

Data on this Website is for information purposes only. No transaction orders or instructions to custodians are permitted or included on this Website. Its use for those purposes is grounds for immediate termination. Data is believed to be reliable, but we do not warrant its completeness, timeliness or accuracy. User accesses, uses, and relies upon such content at User’s own risk. Please seek the advice of professionals as necessary regarding the evaluation of any content on this Website. The information on this Website is not intended as an offer or solicitation for the purchase of any security or any financial instrument or to provide any investment service or investment advice in any jurisdiction.

Loss of User Data

Users are responsible for maintaining backup data to be able to recreate or duplicate the data furnished to the My Alts Data platform. If any data, programs, or other material furnished by a User is lost or damaged in transit, First Oregon’s liability, and User's exclusive remedy, shall be limited to the furnishing of disks, tapes or other media of the type furnished by the User, but First Oregon shall not be liable for the loss of data on such material.

Limitation of Liability

BECAUSE OF THE POSSIBILITY OF HUMAN AND MECHANICAL ERROR AS WELL AS OTHER FACTORS, THE WEBSITE (INCLUDING ALL INFORMATION AND MATERIALS CONTAINED ON THE WEBSITE) IS PROVIDED “AS IS” AND “AS AVAILABLE.” WE, OUR AFFILIATES, AND ANY THIRD PARTY DATA PROVIDERS:

ARE NOT PROVIDING ANY WARRANTIES AND REPRESENTATIONS REGARDING THE WEBSITE;
DISCLAIM ALL WARRANTIES AND REPRESENTATIONS OF ANY KIND WITH REGARD TO THE WEBSITE, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF THIRD PARTY RIGHTS, FREEDOM FROM VIRUSES OR OTHER HARMFUL CODE, OR FITNESS FOR A PARTICULAR PURPOSE;
DO NOT WARRANT THE ACCURACY, ADEQUACY, OR COMPLETENESS OF THE INFORMATION AND MATERIALS CONTAINED ON THE WEBSITE AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS OR OMISSIONS IN THE MATERIALS AND INFORMATION; AND
WILL NOT BE LIABLE FOR ANY DELAY, DIFFICULTY IN USE, COMPUTER VIRUSES, MALICIOUS CODE OR OTHER DEFECT IN THIS WEBSITE, ANY INCOMPATIBILITY BETWEEN THE WEBSITE AND THE USER’S FILES AND THE USER’S BROWSER OR OTHER SITE ACCESSING PROGRAM, OR ANY OTHER PROBLEMS EXPERIENCED BY THE USER DUE TO CAUSES BEYOND OUR CONTROL.

NO LICENSE TO THE USER IS IMPLIED IN THESE DISCLAIMERS. NOTHING HEREIN SHALL BE CONSTRUED AS LIMITING OR REDUCING OUR RESPONSIBILITIES AND OBLIGATIONS TO CLIENTS IN ACCORDANCE WITH APPLICABLE LAWS AND REGULATIONS.

UNDER NO CIRCUMSTANCES WILL WE BE LIABLE FOR ANY LOST PROFITS, LOST OPPORTUNITY OR ANY INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF ANY USE OF OR INABILITY TO USE THE WEBSITE OR ANY PORTION THEREOF, REGARDLESS OF WHETHER WE HAVE BEEN APPRISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING AND REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR OTHERWISE.

Legal entity disclosure

My Alts Data is a private fund data platform created and managed by First Oregon LLC. This Website has been designed for access to the United States only. The products and services offered depend upon the website or platform being accessed and may not be available in all jurisdictions.

Copyright Notice

The information, software, products and services included in or available through this Website may include content, advice or information owned by First Oregon LLC.

Trademark Notices

First Oregon LLC and My Alts Data are both registered trademarks of First Oregon LLC.

Patent Pending Notice

There is a United States patent pending for the My Alts Data platform and its technology.

Enforceability and Governing Law

In the event any of the terms or provisions of these Terms and Conditions shall be held to be unenforceable, the remaining terms and provisions shall be unimpaired and the unenforceable term or provision shall be replaced by such enforceable term or provision as comes closest to the intention underlying the unenforceable term or provision. These Terms and Conditions shall be subject to any other agreements you have entered with First Oregon. The user’s access to and use of the Website, and the terms of this disclaimer are governed by the laws of the State of Oregon without regard to conflict of laws provisions.

Fee Dispute

In the event a User disputes the amount of a given invoice, it shall promptly notify First Oregon of such dispute and attempt to resolve such dispute promptly and amicably. Such disputes shall only be made in good faith. In the event no resolution occurs,the parties hereby agree to submit to binding arbitration pursuant as outlined below.

Exclusive Agreement

This Agreement sets forth the entire agreement and understanding of the parties and their respective affiliates and subsidiaries with respect to the subject matter hereof and supersedes any prior or contemporaneous written or oral agreements, undertakings, promises, warranties, or covenants not specifically referred to, attached hereto, or contained herein.

Governing Law

This Agreement shall be construed under and in accordance with the laws of the State of Oregon without regard to its conflict of law provisions (exclusive of any provision that would result in the application of the laws of any other state or jurisdiction). Both parties hereby consent to the jurisdiction of the state and federal courts, located in the City of Lake Oswego, Oregon.

Successors and Assigns

This Agreement shall not be assignable by either First Oregon or User without the prior written consent of the other party, which consent shall not be unreasonably withheld, delayed, or conditioned. Any attempted assignment or change of control without such prior written consent shall be void.

Good Faith

Each party shall act in good faith in connection with its performance of its respective obligations contemplated by this Agreement by, among other things, making available, as reasonably requested by the other party, such facilities, management decisions, personnel, information, approvals, authorizations, and acceptances as may be necessary so that the Services provided by First Oregon under this Agreement may be accomplished in a proper, timely, and efficient manner.

Public Announcements

Neither party may disclose the terms of this Agreement or use the other party’s trade name, trademark, logo or any other identifiable indicia without the prior written consent and approval of that party.

Severability

If any provision of this Agreement shall be held invalid or unenforceable by law, the remaining provisions shall remain in full force and effect.

Relationship of the Parties

The relationship established between First Oregon and User under this Agreement is that of independent contractors, and nothing herein shall be deemed to create a merger or joint venture between First Oregon and User. Neither party shall have the authority to bind or attempt to bind the other to any agreement or obligation without the prior written approval of the other party.

No Lease

This Agreement is a Services agreement and is not intended to and will not constitute a lease of or tenancy or other interest in User’s equipment, data or any other real or personal property.

Warranties

First Oregon warrants to User that the Services to be provided will be performed or delivered, as applicable, by First Oregon in a good, efficient, timely, professional and workmanlike manner, without damage to User’s property or data, by qualified persons fully familiar with the requirements for the Services. The Services and any other work performed by or on behalf of First Oregon under a SOW and/or this Agreement will be its own work, and will not infringe upon any Intellectual Property Rights of any third party.

Disclaimer

First Oregon shall employ commercially reasonable measures to prevent the transference of malicious code (including without limitation, viruses and Trojan horses) and provide the User with the services referenced herein in good working order. With the exception of the provisions of this agreement, First Oregon makes no warranties, express or implied, including but not limited to any implied warranties of merchantability or fitness for a particular purpose. Notwithstanding anything contained herein to the contrary, First Oregon assumes no liability under this agreement for any failure of the services to conform to any specifications or other form of instruction provided to First Oregon, unless attributable to First Oregon’s fraud, willful misconduct or gross negligence.

Limited Liability, Exclusive Remedy. If First Oregon is liable for any loss, damage, claim or expense suffered or incurred by User, the maximum aggregate liability of First Oregon shall be limited to the lesser of the average monthly billing (exclusive of postage and other disbursements) of First Oregon with User during the term of this Agreement or one hundred dollars ($100).

The User's sole and exclusive remedy against First Oregon for any breach of this Agreement or other liability arising hereunder shall be to assert a claim for money damages not in excess of the foregoing limited maximum liability. In no event shall First Oregon be liable to User or any other person for consequential or incidental damages arising from or related to any breach of this Agreement, any service or product furnished by First Oregon, or otherwise.

Modifications

Please note that these Terms of Use are subject to change by the Company in its sole discretion at any time. When changes are made, the Company will make a new copy of the Terms of Use Agreement available at the Website. The Company will also update the “Last Updated” date at the top of the Terms of Use Agreement. If the Company makes any material changes, and you have registered with us to create an Account we will also send an e-mail to you at the last e-mail address you provided to us pursuant to the Agreement. Any changes to the Agreement will be effective immediately for new users of the Website and/or Services and will be effective thirty (30) days after posting notice of such changes on the Website for existing users, provided that any material changes shall be effective for existing users who have an Account with us upon the earlier of thirty (30) days after posting notice of such changes on the Website or thirty (30) days after dispatch of an e-mail notice of such changes to existing users. The Company may require you to provide consent to the updated Agreement in a specified manner before further use of the Website and/or the Services is permitted. If you do not agree to any change(s) after receiving a notice of such change(s), you shall stop using the Website and/or the Services. Otherwise, your continued use of the Website and/or Services constitutes your acceptance of such change(s).

Indemnification
‍You agree to indemnify and hold Company (and its affiliates, officers, employees, contractors, licensors, suppliers and agents) harmless from any losses, costs, liabilities and expenses (including reasonable attorneys’ fees) relating to or arising out of (a) your use of, or inability to use, the Platform; (b) Your Data; (c) any arrangements you make based on information obtained on or through the Company; (c) your violation of this Agreement; or (d) your violation of applicable laws, rules or regulations. This provision does not require you to indemnify any of the above parties for any unconscionable commercial practice by such party or for such party’s fraud, deception, false promise, misrepresentation or concealment, or suppression or omission of any material fact in connection with the Website or any Services provided hereunder. You agree that the provisions in this section will survive any termination of your Account, the Agreement and/or your access to the Platform.

Confidentiality
‍You acknowledge and agree that the software and any related documentation provided to you as part of the service may contain proprietary and confidential information that is protected by applicable intellectual property and other laws. You agree to use such proprietary information only for the purposes of using the service as permitted in the Terms of Use and not to disclose such proprietary information to any third party without the express written consent of the company. You also agree to take reasonable precautions to prevent any unauthorized disclosure of the software and related documentation. This includes, but is not limited to, keeping the software and related documentation in a secure location and not sharing login credentials or access to the software with any unauthorized individuals. The company will not be held responsible for any unauthorized use or disclosure of the software or related documentation due to your failure to maintain the confidentiality of such information.

Security
The Company is committed to protecting the security of the service and your personal information. The Company has implemented appropriate technical and organizational measures to protect the service and your personal information from unauthorized access, use, or disclosure. However, the Company cannot guarantee that the service or your personal information will always be secure. You acknowledge that there are inherent risks in using the internet and electronic communications, and you agree to assume the risk of any unauthorized access to or use of your personal information. You agree to promptly notify the company if you become aware of any security breach or other unauthorized access to or use of the service or your personal information.

Availability
‍The Company will make reasonable efforts to ensure that the service is available at all times but cannot guarantee that the service will be uninterrupted or error-free. There may be periods of scheduled downtime for maintenance or upgrades, and the company will make reasonable efforts to inform you in advance of such downtime. The Company will not be liable for any losses or damages resulting from any periods of downtime or unavailability of the service. You acknowledge that the service may be subject to limitations, delays, and other problems inherent in the use of the internet and electronic communications. The company is not responsible for any delays, delivery failures, or other damages resulting from such problems.

Term

Subject to this Section, this Agreement will remain in full force and effect while you use the Platform. The Company may suspend or terminate your rights to use the Platform (including your Account in whole or in part, at any time for any reason at our sole discretion, including for any violation of this Agreement. Upon termination of your rights under this Agreement, your Account and right to access and use the Platform will terminate immediately. You understand that any termination of your Account may involve deletion of your Data associated with your Account from our live databases. The Company will not have any liability whatsoever to you for any termination of your rights under this Agreement, including for termination of your Account or deletion of your Data.

‍Dispute Resolution

You agree that any dispute, claim, or request for relief relating in any way to your access or use of the Platform, to any products sold or distributed through the Platform, or to any aspect of your relationship with Company, will be resolved by binding arbitration under the Commercial Arbitration Rules of the American Arbitration Association rather than in court, at a time and place in Oregon to be agreed upon by the parties. The arbitration award may be enforced in any court of applicable jurisdiction.

Confidential Information

The Parties to the Agreement shall not use any Confidential Information (which term includes Archived Data and Personal Data) of the other party for its own benefit or for any purpose other than to fulfill its respective obligations under the Agreement. Each party agrees to receive and preserve such Confidential Information as proprietary and confidential information, exercising the same degree of care a reasonable and careful person would exercise with it’s own confidential information, and in no case will it use less than commercially reasonable efforts consistent with the standards of practice in the industry to prevent unauthorized access to and disclosure of the other party’s Confidential Information. The parties further agree that neither will make Confidential Information of the other party available in any form to, or for the use or benefit of, any Person except as provided in the Service Agreement, and that neither will use any Confidential Information of the other, or the Services, to compete with the other party in its business.

Data Privacy

The parties acknowledge and agree that each of First Oregon’s My Alt Data Users may have certain responsibilities prescribed by applicable Data Protection Laws in connection with the safeguarding and privacy of certain Personal Data and Personally Identifiable Information. First Oregon hereby acknowledges such responsibilities to the extent required thereby as the archive service provider or Processor of the Archived Data. First Oregon agrees, and will cause its Employees to agree, that any personal data related to any User shall be treated as User’s Confidential Information hereunder. User agrees, and will cause User Employees to agree, that any personal data related to First Oregon shall be treated as First Oregon’s Confidential Information hereunder.

Assignment

The Agreement, and your rights and obligations hereunder, may not be assigned, subcontracted, delegated or otherwise transferred by you without the Company’s prior written consent, and any attempted assignment, subcontract, delegation, or transfer in violation of the foregoing will be null and void.

‍Force Majeure

The Company shall not be liable for any delay or failure to perform resulting from causes outside its reasonable control, including, but not limited to, acts of God, war, terrorism, riots, embargos, acts of civil or military authorities, fire, floods, accidents, strikes or shortages of transportation facilities, fuel, energy, labor or materials.

Market Intelligence

The My Alts Data platform will host Private Fund Marketplace intelligence of private Regulation D type Offerings that are organized under Rule 506C of Regulation D, where an exemption from registration is granted under the Securities Act of 1933, allowing Fund Sponsors (issuers) to offer securities through general solicitation and advertising to accredited investors. The key requirement is that Fund Sponsors (issuers) must take reasonable steps to verify that all purchasers are accredited investors.

Any listing of such a private fund offering on the My Alts Data website is provided as marketplace intelligence only and not a recommendation. First Oregon nor the My Alts Data recommends one private fund or sponsor above another. We do not conduct any risk analysis for investors nor conduct due diligence on fund strategies, offering documents, the adequacy of risk disclosures nor the on backgrounds or competencies of management.

All market intelligence is provided as a courtesy to help accredited investors and financial advisors gauge the marketplace of current market activity. All information on each listing has been provided by the Fund Sponsor. We have not verified its accuracy nor have we conducted due diligence on the management or have verified the accuracy of the data entered by a private fund sponsor.

We have not charged any fees to a Fund Sponsor to enter this information nor to accredited investors to view this marketplace intelligence. Accredited Investors are urged to consult with a Financial Advisor to discuss the suitability and fund risks to determine if an investment is appropriate for their personal risk profile, financial objectives and liquidity needs.

ADVISER SUPPLEMENT

By opening an Account on the My Alts Data Platform as an Adviser you agree to these additional Terms of Use:

1, You take full responsibility for the control, accuracy, completeness and display of the Data placed in your Account.

2. The advisory services you provide and the Data placed in your Account are provided in compliance with all applicable laws and regulations governing content and manner of presentation and do not omit Data necessary to make the Data presented not misleading.

3. You agree that Data placed in your Account and/or provided to other Accounts regarding any Private Fund shall be carefully checked against, and not inconsistent with, Data available directly from the Fund and using Data Screens provided by us. Data is required to be factual in content. Data presented as projections should be clearly identified as such. The Platform is not to be used as an electronic venue for the sale of securities or investment advisory services or included in any webinars, chat rooms or other forms of widespread communication. Material such as analyses, reports and commentary should not be labeled or used as offering material without our prior consent.

4. Investment advice and management services with respect to individual User Accounts on the Platform through the use of Platform communication and display applications is provided exclusively by you and not by First Oregon. You acknowledge that First Oregon does not provide investment advice or management services nor take on any fiduciary duties to individual client account holders with respect to their securities, its responsibility being limited solely to the recording, storage and display of data.

5. You acknowledge that while First Oregon may encourage common use by Account holders of data posted by you on our platform that First Oregon is not engaged in, or compensated for, soliciting advisory services or purchase of securities, including interests in any Fund or Funds.

PRIVATE FUND SUPPLEMENT

By opening an Account on the My Alts Data Platform as a Fund you agree to these additional Terms of Use:

1. You take full responsibility for the control, accuracy, completeness and display of the Data placed in your Account.

2. Data placed in your Account is provided in compliance with all applicable laws and regulations governing content and manner of presentation and does not omit Data necessary to make the Data presented not misleading.

3. You agree that Data placed in your Account and/or provided to other Accounts regarding any Private Fund shall be carefully checked against, and not inconsistent with, other Data available directly from the Fund and using Data Screens provided by us. Data presented as projections should be clearly identified as such. The Platform is not to be used as an electronic venue for the sale of securities or investment advisory services or included in any webinars, chat rooms or other forms of widespread communication. Material such as analyses, reports and commentary should not be labeled or used as offering material without our prior consent.

4. You acknowledge that First Oregon does not provide investment advice or management services nor take on any fiduciary duties to individual client account holders with respect to their securities, its responsibility being limited solely to the recording, storage and display of Data.

5. You acknowledge that while First Oregon may encourage common use by Account holders of data posted by you on our platform that First Oregon is not engaged in, or compensated or, soliciting advisory services or purchase of securities, including interests in your Fund or Funds.

Last updated: July 7, 2025