Privacy Policy &
Terms and Conditions

Section One

Privacy Policy

Effective Date: July 22, 2026 · Last Updated: July 22, 2026

HarborPE, LLC ("HarborPE," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at harborpe.com (the "Site") or contact us directly. Please read this policy carefully. If you disagree with its terms, please discontinue use of the Site.

1.1 Information We Collect

We may collect information about you in the following ways:

• Information you provide directly. When you contact us via email, inquiry form, or any other method, we collect the information you voluntarily share — including your name, email address, company name, and any details about your business or investment interest.
• Information collected automatically. When you visit our Site, certain information may be collected automatically, including your IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of your visits. This information is collected through standard web server logs and, where applicable, cookies or similar tracking technologies.
• Information from third parties. We do not purchase or acquire personal information from third-party data brokers. We may receive information about you through professional referrals or public sources such as LinkedIn.

1.2 How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your inquiries and communicate with you about potential investment or partnership opportunities
• To evaluate whether a business or investment relationship may be appropriate
• To improve the content and functionality of our Site
• To comply with applicable legal obligations
• To protect the rights, property, and safety of HarborPE and others

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

1.3 Disclosure of Your Information

We may share your information in the following limited circumstances:

• Service providers. We may share information with third-party vendors who assist us in operating our website or conducting our business (such as email hosting or web analytics providers), subject to confidentiality obligations.
• Legal requirements. We may disclose information when required by law, regulation, legal process, or governmental request.
• Business transfers. In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
• Protection of rights. We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of this policy.

1.4 Cookies and Tracking Technologies

Our Site may use cookies — small text files stored on your device — to enhance your experience and gather usage data. You may disable cookies through your browser settings; however, doing so may affect the functionality of certain areas of the Site. We do not use cookies for targeted advertising.

1.5 Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required by law. Inquiry and correspondence records are typically retained for a period of three years from the date of last contact.

1.6 Security

We implement reasonable administrative, technical, and physical safeguards to protect your information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

1.7 Third-Party Links

Our Site may contain links to third-party websites, including the websites of companies in our portfolio. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies separately.

1.8 Children's Privacy

Our Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected such information, please contact us and we will promptly delete it.

1.9 Your Rights and Choices

Depending on your location, you may have certain rights with respect to your personal information, including the right to access, correct, or request deletion of your data. To exercise any of these rights, please contact us at the address below. We will respond to verified requests within a reasonable timeframe and in accordance with applicable law.

1.10 Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this section. We encourage you to review this policy periodically. Your continued use of the Site following any changes constitutes your acceptance of the updated policy.

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Section Two

Terms and Conditions

Effective Date: July 22, 2026 · Last Updated: July 22, 2026

These Terms and Conditions ("Terms") govern your access to and use of the HarborPE website at harborpe.com (the "Site") and any content, information, or communications provided through the Site. By accessing or using the Site, you agree to be bound by these Terms. If you do not agree, please do not use the Site.

2.1 Nature of the Site and Its Content

The Site is operated by HarborPE, LLC, a private investment firm based in Minnetonka, Minnesota. The content on this Site is provided for general informational purposes only. Nothing on this Site constitutes an offer to sell, a solicitation of an offer to buy, or a recommendation with respect to any security, investment, or business opportunity.

HarborPE does not operate as a registered investment adviser, broker-dealer, or investment company under applicable U.S. federal or state securities laws. Communications through this Site do not create an investment advisory or client relationship of any kind.

2.2 No Investment Advice

The information provided on this Site, including descriptions of our investment approach, portfolio companies, track record, and market perspectives, is provided solely for informational and illustrative purposes. It should not be relied upon as investment, financial, legal, or tax advice. Past performance referenced on this Site does not guarantee future results. You should consult with qualified advisers before making any investment decisions.

2.3 Forward-Looking Statements

Certain statements on this Site may constitute forward-looking statements, including statements about our investment strategy, market outlook, and portfolio company prospects. These statements involve known and unknown risks and uncertainties, and actual results may differ materially from those expressed or implied. HarborPE undertakes no obligation to update forward-looking statements.

2.4 Intellectual Property

All content on this Site — including text, graphics, logos, images, and the overall design and layout — is the property of HarborPE, LLC or its licensors and is protected by applicable copyright, trademark, and other intellectual property laws. You may not reproduce, distribute, modify, or create derivative works from any content on this Site without our prior written permission.

2.5 Acceptable Use

You agree to use this Site only for lawful purposes and in a manner that does not infringe the rights of others or restrict or inhibit their use of the Site. You may not:

• Use the Site in any way that violates applicable local, state, national, or international law or regulation
• Transmit any unsolicited or unauthorized advertising or promotional material
• Attempt to gain unauthorized access to any portion of the Site or its related systems
• Use automated means to scrape, harvest, or collect information from the Site
• Impersonate HarborPE or any of its principals, employees, or affiliates

2.6 Disclaimer of Warranties

The Site and its content are provided on an "as is" and "as available" basis without warranties of any kind, either express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, or non-infringement. HarborPE does not warrant that the Site will be uninterrupted, error-free, or free of viruses or other harmful components.

2.7 Limitation of Liability

To the fullest extent permitted by applicable law, HarborPE, LLC and its members, managers, employees, and agents shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from or related to your use of or inability to use the Site, even if advised of the possibility of such damages. Our total liability to you for any claims arising from your use of the Site shall not exceed one hundred dollars ($100).

2.8 Indemnification

You agree to indemnify, defend, and hold harmless HarborPE, LLC and its members, managers, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable attorneys' fees) arising out of or in any way connected with your access to or use of the Site, your violation of these Terms, or your infringement of any third-party rights.

2.9 Third-Party Links and Content

This Site may contain links to third-party websites, including the websites of our portfolio companies and external resources. These links are provided for convenience only. HarborPE does not control, endorse, or assume responsibility for the content, privacy practices, or terms of any third-party websites. Your access to and use of linked sites is at your own risk.

2.10 Governing Law and Dispute Resolution

These Terms are governed by and construed in accordance with the laws of the State of Minnesota, without regard to its conflict of law provisions. Any dispute arising out of or relating to these Terms or your use of the Site shall be resolved exclusively in the state or federal courts located in Hennepin County, Minnesota, and you consent to the personal jurisdiction of those courts.

2.11 Changes to These Terms

We reserve the right to modify these Terms at any time. When we do, we will update the "Last Updated" date above. Your continued use of the Site following any modifications constitutes your acceptance of the revised Terms. We encourage you to review these Terms periodically.

2.12 Entire Agreement

These Terms, together with our Privacy Policy, constitute the entire agreement between you and HarborPE with respect to your use of the Site and supersede all prior agreements, representations, and understandings.

2.13 Contact

Questions about these Terms should be directed to: