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Privacy Policy

As a private transaction, this program is exempt from the US Securities Act of 1933, the US Securities Exchange Act of 1934 and the US Investment Company Act of 1940 and all other rules, regulations and amendments thereof. We are not FDIC insured. We are not a licensed bank or a security firm.

You agree that all information, communications, materials coming from are unsolicited and must be kept private, confidential and protected from any disclosure. Moreover, the information, communications and materials contained herein are not to be regarded as an offer, nor a solicitation for investments in any jurisdiction which deems non-public offers or solicitations unlawful, nor to any person to whom it will be unlawful to make such offer or solicitation.

All the data giving by a member to will be only privately used and not disclosed to any third parties. is not responsible or liable for any loss of data.

You agree to hold all principals and members harmless of any liability. You are investing at your own risk and you agree that a past performance is not an explicit guarantee for the same future performance. You agree that all information, communications and materials you will find on this site are intended to be regarded as an informational and educational matter and not an investment advice.

We reserve the right to change the rules, commissions and rates of the program at any time and at our sole discretion without notice, especially in order to respect the integrity and security of the members' interests. You agree that it is your sole responsibility to review the current terms.