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This Privacy Policy governs this website (the “Site”) of Jay Virk Holdings and its affiliates (together, “JVH,” “we” or “us”). We respect your privacy as a user of the Site. This Privacy Policy describes whether and how we collect and use information about you when you visit the Site.

Your visit to the Site is subject to this Privacy Policy. By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time and constitutes a legal agreement between you and JVH. We will post any updates to this Privacy Policy here, and any updates will be effective upon posting. You should consult the Privacy Policy on this Site each time you visit the Site. If you do not agree with its terms, please do not use the Site.

This Privacy Policy does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you are comfortable with their terms.  Further, this Privacy Policy does not govern information that you submit to JVH in your role as an investor in JVH or in funds that we sponsor or manage. We address these practices in separate notices.  Finally, it does not apply to information we collect from our employees, applicants for employment, contractors, or business contacts. 

When we use the term “personal information” in this Privacy Policy, we mean information that relates to an identified or identifiable natural person.


1. The Types of Information We Collect About You

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect through technology.

Information You Provide to Us.  To obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to identify you personally, including your name, e-mail address, company name, and title. Additionally, we may collect and retain a record of all communications with you.

Information We Collect Through Technology. We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.

The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send to our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails.

We use software tools such as Google Analytics to measure and collect session information about your Site visits, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

We may use the information described to understand better how our visitors use the Site, research our visitors’ demographics, interests, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may combine this information with personal information. We may use this information in any manner permitted by law, but any disclosure that identifies you personally will be governed by Section 3. 

2. Cookies and How We Use Them

Cookies are small text files that may be placed on your browser when you visit our Site. Cookies are used primarily for administrative purposes, to improve your experience with our Site. For instance, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are. uses cookies primarily to capture anonymous analytics to improve your experience with the Site and its performance. This includes compiling statistical information concerning, among other things, the frequency of use of our site, the pages visited, and the length of each visit, as well as information about your computer, operating system, browser, language, and country.

Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s Help menu to learn the correct way to modify your cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of our Site smoother, and some of our services may not function properly. You may at any time delete any cookies set by us by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to If you continue without changing your settings, we’ll assume that you accept receipt of all cookies on the Site.

As mentioned above, we use Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at By using the Site with your browser set to accepting cookies, you consent to our and Google Analytics’ use of cookies on the Site.

3. How We Use and Disclose Your Personal Information for a Business Purpose

JVH does not use or disclose any personal information about its Site users to any nonaffiliated third party, except as set forth below.

We may use or disclose for a business purpose certain personal information we collect about you when you visit and browse the Site as part of our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site.

We may also store your personal information and share it among our affiliates. We may use or disclose this information for marketing, research and other business purposes, and we may associate your personal information with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties.

We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your personal information, as needed to perform their functions, but may not use it for another purpose.

We will use or disclose personal information when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request. For example it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We may also do so to help enforce our Terms of Use or to protect the safety or security of our websites and other assets, our users (including you) and their property and the rights of third parties. Also, in the event that JVH or any of its assets or businesses are acquired or merged with another entity, whether an affiliate or a third party, user information (including personal information) may be one of the transferred assets.

We do not sell your personal information.

4. Do Not Track Signals

JVH does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

5. Children

Although this Site is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. We do not knowingly collect personal information from children under the age of 13, nor do we disclose such information to third parties. However, if a child under the age of 13 provides personal information to us through the Site, a parent or guardian may inform us at the address for legal notices below, and we will allow the parent or guardian to review the information and will delete it from our database, subject to applicable law.

6. International Use

Our databases are located in the United States, and your data is stored in the United States. If you access this website from outside the United States, you do so at your own risk and are responsible for compliance with local laws, rules and regulations. 

By sending us your data, you consent to its transfer to and storage within the United States.

7. Governing Law and Forum

The laws of the State of California govern this Privacy Policy. Any dispute relating to this Privacy Policy or your use of the Site shall be resolved solely in the state or federal courts located in San Francisco County, California. You agree to waive trial by jury in any such action.

8. Data Subject Rights

We are committed to providing individuals with reasonable and appropriate access to their personal information.  If you believe that we are processing personal information about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as where the request is manifestly unfounded or excessive.  We are happy to correct inaccurate data or delete information that is not appropriate to retain. Please also let us know if you have any questions, concerns, disputes, or issues.

Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights.  These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format.  Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority.  You can exercise these rights by contacting us at  We will review your requests and respond accordingly.  The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

We do not discriminate against you, for example, by offering a different level of service, for exercising any of these rights.

If you make a request related to personal data about you, we will need to verify your identity.  To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.  If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request.  For requests related to particularly sensitive information, we may require additional proof of identification.  If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.  We will process your request within the time provided by applicable law.


9. Miscellaneous

If any provision of this Privacy Policy is deemed unlawful, void, or for any reason unenforceable, that provision will be deemed severable from this Privacy Policy and will not affect the validity or enforceability of the remaining provisions.


10. How to Contact Us

If you have any questions or comments about this Privacy Policy, you can email us at, call us at 559-917-3207, or write to us at Jay Virk Holdings. 1050 Shaw Ave., Ste. 1053 Clovis, CA 93612.


Last updated: March 2020

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