Last Revised: June 20, 2023
We know that your privacy is important to you, and we work hard to earn and keep your trust. Portage Technologies Inc. (collectively with its subsidiaries, the “Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”). The words “you” and “your” refer to you as a user of our Website (defined below), either as a visitor of the General Website (defined below) or a registered member of 10 East (a “Member”) or investor in a 10 East offering (an “Investor”).
This policy describes:
The types of information we collect from you or that you may provide when you visit our website available at: https://10east.co/, any websites or blogs directly owned by the Company where this Policy is linked (collectively, our “General Website”), and when you create an account on our website to become a Member or Investor in order to access our services (the “Services”, and such Member/Investor website, together with the General Website, our “Website”).
This Policy applies to information we collect on this Website or in emails and other electronic messages between you and this Website, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.
This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Company or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Third-party Websites”).
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
When using the General Website, this Policy should be read in conjunction with our Website Terms of Use, into which this Policy is incorporated by reference. However, if you create an account for our Services in your capacity as a Member or Investor, this Policy should be read in conjunction with our General Terms of Use Agreement, which is only applicable to the Services.
To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). The personal information that we may receive and collect depends on what you do when you visit our website.
Information we may collect on the website from visitors.
If you are a visitor of our General Website and do not create an account for our Services, you may have the opportunity to provide the following Personal Information:
Information we may collect on the website from members and investors.
If you create an account for our services and become a member or investor, you may have the opportunity to provide the following personal information:
We may collect the following information:
Example
A first and last name, email address, telephone, postal address, unique personal identifier, online identifier, Internet Protocol address, account name.
Example
Citizenship and marital status.
Example
Investment profile, including, without limitation, investor accreditation and/or other investor qualification status representations and information, income level, return expectations, net worth, source of wealth, risk tolerance, investment experience, desired investment terms, and areas of investment interest.
Example
Social Security number, W-9 form information, driver's license, state identification card, passport number, financial account, debit card, credit card number with security, or access code or password, certain other legal, compliance, tax and/or regulatory representations, documentation and information.
Example
Current or past job history.
Example
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We do not collect the following information:
Example
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Example
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Example
Physical location or movements.
Example
Audio, electronic, visual, thermal, olfactory, or similar information.
Example
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Sources of personal information.
We obtain the categories of personal information listed above from the following categories of sources:
Free-text boxes.
The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.
Username and password; other sources.
Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us.
Recording use of the website.
We partner with trusted third-party vendors to analyze performance and traffic of our Website. This may include things like buttons you click, mouse movements and other behavior on the Website, date and time of access, pages visited, web beacons, and cookie or pixel tag information. Please see our Automatic Information Collection section below to learn more about cookies, pixels tags, and analytic technologies.
In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:
Cookies.
A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:
We may use the following categories of cookies on our Website.
Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested cannot be provided.
Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.
Google Analytics. The Website sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance. For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.
Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:
Duration
The length of time the Company intends to retain Personal Information, including sensitive information, if any, is for as long as reasonably necessary to carry out the Company’s intended business purpose for such information.
We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose, including, but not limited to, the following categories of third parties:
Our affiliates. We may share the information collected through the Website with our affiliates in order to provide our products, services and customer support.
Third-party service providers. We disclose Personal Information collected through the Website with third-party Service Providers who act for or on behalf of the Company. These third parties may need information about you to perform their functions. “Service Providers” may include suppliers, dealers, distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order fulfillment, information technology, related infrastructure support, customer service, email delivery, and auditing.
With other carefully selected business partners. From time to time, we may disclose your Personal Information with selected third parties (other than our service providers). For example, 10 East’s arrangements with various parties, including, without limitation, investment partners, sponsors, co-investors and investment advisers with which Registered Users are able to invest via 10 East invest and/or contemplate investing, in each case directly or indirectly (including the partners, agents and service providers of those parties), employees, shareholders, partners, agents, active and/or prospective service providers, accountants, auditors, administrators, CRM providers, analytics and data firms, payment processors, electronic signature providers, banks, law firms, and legal, compliance, regulatory, tax, technology and/or financial advisers are expected to require and/or request it to provide certain visitors’ and/or Registered Users' information in 10 East’s possession, including personal information, directly to such party(ies). 10 East also expects to provide such information, including personal information, to one or more such party (ies) for purposes of monitoring and/or confirming compliance with the Company's Terms of Use Agreement, Non-Disclosure Agreement and other obligations of visitors and/or Registered Users.
Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:
Legal Reasons.
Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.
We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
We may send you email newsletters and marketing emails. You may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us.You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.
Any such communications you receive from us will be administered in accordance with your preferences and this Policy.
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.
Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.
We do not intentionally seek to gather information from individuals under the age of sixteen (16). We do not target the Website to minors, and would not expect them to be engaging with our Website or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.
Your Personal Information will always be processed by the Company in accordance with this Policy unless otherwise agreed to in writing. Nonetheless, it is important to advise you that certain privacy laws do not apply to the Website or our services.
We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through this Website are available to others who visit this Website. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through this Website. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our Terms of Use or other applicable agreements. All terms and conditions of our Terms of Use apply to Submissions on or through this Website. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.
This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services. For example, if you click on an advertisement on this Website, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.
California
WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION.
Your Consumer Rights
Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you are a consumer in a state that provides consumer rights, please be advised that the Company is not a “business” or “controller” as that term is defined under applicable state laws and therefore does not necessarily afford consumers these rights with respect to their Personal Information. Regardless, all Personal Information will be processed in accordance with this Policy.
We do not warrant or represent that this Policy or the Website’s use of your Personal Information complies with the laws of every jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.
Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., “UK GDPR”) as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively “International Data Protection Laws”) individuals have specific rights with respect to their Personal Information, or “personal data” as defined under the International Data Protection Laws. For the purposes of this Policy, the Company operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.
Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.
The Data Controller is:
Name:
Portage Technologies Inc.
Address:
10 East 53rd Street, 28th Floor New York, NY 10022
Email:
contact@10east.co
You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:
Access. You may email us at contact@10east.coto request a copy of the personal data our Website databases currently contain.
Automated Processing and Decision-Making. You may email us at contact@10east.co to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at contact@10east.co to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to contact@10east.co. In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to contact@10east.co. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to contact@10east.co. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at contact@10east.co. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at contact@10east.co. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.
This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the products and services we offer through this Website. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at contact@10east.co.
Copyright 2025 Portage Technologies Inc. — All Rights Reserved
There can be no assurance that 10 East will be able to identify investments that are positioned to benefit from its investment approach or that the investments identified will be able to realize, in whole or in part, the opportunities identified in any investment approach. Investing in alternative investments, including through 10 East, is inherently risky and illiquid. It involves a high degree of risk (including of significant and/or complete loss) and is suitable only for sophisticated and qualified investors. There is no guarantee that you will be able to sell, transfer or otherwise exit your investments or that you can do so at a specific price. Any historical, projected or expected returns presented herein are not guaranteed and may not reflect actual performance. No offer or sale of any securities or other investment instrument(s) will occur without the delivery of offering and other definitive documentation, and nothing herein shall otherwise constitute an offer to sell or constitute a solicitation of an offer (or recommendation) to buy, sell or hold any security (or other financial instrument), make any investment, or adopt any investment strategy, or constitute investment, legal, tax, accounting, regulatory or financial advice. 10 East members must seek their own such, and other, professional advice. No sale will constitute a binding agreement unless and until such documentation is finalized and, where applicable, fully executed. 10 East Partners LLC is an SEC-registered investment adviser. Neither Portage Technologies Inc. nor 10 East is a registered broker-dealer.
Certain information herein contains “forward-looking” information under applicable laws and otherwise (“forward-looking statements”). Such forward-looking statements may include, without limitation, expectations, projections (including in each case with respect to investment performance and/or investment term(s)) and anticipated business developments, among others. Forward-looking statements are not guarantees of future activities, performance or otherwise and should not be relied on in any respect. Forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time, and 10 East assumes no duty to and does not undertake to update forward-looking statements. Actual results could differ materially from those anticipated in forward-looking statements.
10 East employees, principals, directors, partners and/or advisors (including each of their respective affiliates) invest, if at all, in 10 East offerings in amounts to be determined by such investors at the time of the applicable commitment(s) or investment(s), and have done so, and may continue to do so, directly with the underlying investment sponsor, where applicable, or otherwise outside of the investing entities in which 10 East members will directly invest. In connection with such investments, such investors are not expected to pay management fees or carried interest to 10 East or its affiliates, or bear expenses charged at the level of the investing entities in which 10 East members will directly invest (or will pay reduced rates). To the extent such investors do invest in a 10 East offering via the 10 East investing entities in which 10 East members invest, such investors will not typically pay management fees or carried interest to 10 East or its affiliates.
Past performance is not indicative or a guarantee of future results