Privacy Policy

At Headlands Capital Advisors, LLC ("Headlands"), your privacy is very important to us. This notice explains Headlands' practices pertaining to the online collection of personally identifiable information, and the way such information is collected and used ("Online Privacy Policy"). Links to this notice are available on our homepage and throughout our website in the lower right of each page.

This Online Privacy Policy is in addition to the privacy notice (the "Privacy Notice") applicable to investors in investment vehicles managed or advised by Headlands, a copy of which may be obtained by contacting or by telephone at (415) 263-7300.

This Online Privacy Policy is effective as of February 2014. Any changes we may make to this Online Privacy Policy in the future will be posted on this page.

What Information We Collect

This policy applies to information collected from, or which may be submitted to, the Headlands website. At the present time, we do not collect any personally identifiable information about visitors to the publicly available areas of our website, including any visitors' names, addresses, phone numbers, social security numbers, or email addresses. At times, visitors to our website may choose to email individuals at Headlands using links available on our site; in such instances, a visitor's email address may be collected as part of the process of sending the email to us in order to enable us to reply to those emails. We may, however, but have no obligation to, monitor and record other activity on our website for any reason or for no reason.

Our website may use "cookies" technology, through which small amounts of data are sent to your computer from our web server and stored on your computer's hard drive. This data identifies you as a unique user when visiting our website, facilitates your ongoing access to and use of our website, and helps us in the ongoing maintenance of our website. This technology does not provide us with any information about your name, address, phone number, or email address, or any other personally identifiable information. We may, however, log visitor IP addresses.

How We Use Information We May Collect

We do not share any information collected from the publicly available areas of our website with any parties outside of Headlands. Headlands reserves the right to disclose any such information we do collect to the extent required by law, regulation, or legal or judicial process, including pursuant to a request from a regulatory agency with competent jurisdiction over Headlands. In the event that a visitor submits its email address or any other personally identifiable information to us via our website while requesting information or sending any email to someone at Headlands, other than as described above or in the Privacy Notice, we will not use such information for any other purpose, and will not disclose such information to any outside party.

Access to Portfolio Company and Other Third Party Websites

Our website may contain links to websites controlled and maintained by third parties. We provide these links solely as a convenience for you. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites are used. This Online Privacy Policy does not govern the use of information collected on such third party websites.