Website Privacy Statement

Bhatt Innovation Capital LLC ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.  This policy describes the types of information we may collect from you or that you may provide when you visit the websites maintained by the Company, which include http://pathfinderstratarb.com and http://bhattic.com (collectively, the "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

We do not require visitors to submit personal information to obtain general access to our Website.  Note that, in order to use our services, you must be at least 18 years of age or older, and we do not intentionally collect any personally identifiable information from any person under 18.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.

This policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time, and any updates to the privacy policy will be posted on our Website. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
• Any information you provide to use via e-mail or other forms of communication with us; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

•  Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways. It helps us to improve our Website and to deliver a better and more personalized service, including (among other things) by enabling us to estimate our audience size and usage patterns.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are required to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use pathfindersma.com/disclosures and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our clients, or others.

The Company does not process or respond to “do not track” signals or other similar signals whereby a visitor to the Website requests that it disable collection of information about the visitor’s online activities over time and across different websites.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, which include physical, technical, and operational controls.  Data security is achieved through technical safeguards that include a combination of a firewall, intrusion detection system, malware detection system, and data loss prevention system. The Company also conducts vulnerability scans of applications and systems periodically.

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

To ask questions or comment about this privacy policy and our privacy practices, contact us at info@bhattic.com.

The European Union’s General Data Protection Regulations (“GDPR”) provides individuals, called data subjects in the GDPR, with certain rights. This privacy statement is intended to inform you of your rights with respect to your personal data and to provide you with the information necessary to exercise those rights.

Individuals who reside in the European Union (“EU”) and whose personal data is collected and processed by the Company have the right to the following:

• To request access to your data;
• To rectify your data;
• To take your data (portability) to another service provider;
• To erase your personal data;
• To restrict or object to the processing of your personal data; and
• To lodge a complaint with a Member State Supervisory Authority.
• In addition, such individuals residing in the EU have the right to withdraw consent if consent was provided to collect and process the personal data. If you withdraw consent, that will not impact your personal data that was processed prior to withdrawal of the consent.

Please direct all inquiries, requests, or concerns relating to your Data Subject Rights to:

Bhatt Innovation Capital LLC

Attention: Chief Compliance Officer

hbhatt@bhattic.com