Privacy Policy

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Bramble Run, LLC, together with its affiliate Lucerne Capital Management, L.P. (collectively, “Bramble Run,” “Lucerne,” “we,” “our,” or “us”), is committed to protecting the privacy and confidentiality of personal data obtained through www.bramblerun.com and any related password-protected, investor-only, or restricted areas of the site (collectively, the “Website”).

This Privacy Policy describes how we collect, use, disclose, transfer, retain, and safeguard personal data in connection with the Website. This Website is intended primarily for institutional investors, consultants, counterparties, and other persons acting in a professional or business capacity. If you are an existing or prospective investor in any Bramble Run or Lucerne-sponsored or managed vehicle, additional privacy notices contained in offering, subscription, investor, or administrative materials may also apply and will govern to the extent they are more specific than this Privacy Policy.

1. PERSONAL DATA WE COLLECT

We may collect personal data that you provide directly to us, including your name, company or organization, title, business email address, telephone number, mailing or business address, login credentials, and the contents of any communication, contact form, request for information, request for access, or other submission you send to us through the Website.

We may also collect information relevant to prospective or existing investor, consultant, counterparty, or other business relationships, including information regarding your professional background, institutional affiliation, investment interests, and eligibility or suitability, to the extent such information is voluntarily provided.

In addition, we may automatically collect certain technical and usage information when you use the Website, including your IP address, browser type, device type, operating system, approximate geographic location based on IP address, pages viewed, timestamps, referring URLs, cookie identifiers, and audit, authentication, or security log information.

We may receive personal data from affiliates, service providers, professional advisers, introduction sources, publicly available sources, or third parties acting on your behalf.

2. HOW WE USE PERSONAL DATA

We may use personal data to respond to your inquiries and communicate with you; provide access to requested materials, reports, and investor-related content; administer user accounts and restricted access areas; review and process requests for access to investor-only materials; evaluate prospective investor, consultant, counterparty, or business relationships; operate, maintain, monitor, and improve the Website; analyze Website traffic and usage patterns; prevent, detect, and investigate fraud, cybersecurity incidents, or unauthorized activity; comply with applicable legal, regulatory, tax, recordkeeping, and compliance obligations; protect our rights and the rights of our affiliates, funds, personnel, service providers, and investors; and send updates or communications where permitted by law.

3. COOKIES, ANALYTICS, AND SIMILAR TECHNOLOGIES

We may use cookies, web beacons, similar technologies, and server logs to support Website functionality, remember user preferences, maintain secure sessions, improve performance, and understand how the Website is used.

Some cookies may be necessary for the Website to function properly. Others may be used for analytics, preference management, or security purposes. Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.

You may control cookies through your browser settings or through any cookie preference tools made available on the Website. Please note that disabling certain cookies may affect Website functionality.

4. HOW WE DISCLOSE PERSONAL DATA

We may disclose personal data to Lucerne Capital Management, L.P. and other affiliated entities; to funds, vehicles, or related entities associated with the relevant relationship or inquiry; to third-party service providers that assist with Website hosting, cloud infrastructure, cybersecurity, analytics, authentication, communications, investor relations, document sharing, or virtual data room services; to professional advisers, auditors, insurers, administrators, and compliance providers; to regulators, law enforcement authorities, courts, tax authorities, or other governmental bodies when required or permitted by law; to transaction counterparties or successor entities in connection with a financing, merger, acquisition, restructuring, sale, or other business transaction; and to other parties with your consent or at your direction.

We do not sell personal data.

5. LEGAL BASES FOR PROCESSING

Where applicable law requires a legal basis for processing personal data, we may rely on one or more of the following: your consent; the performance of a contract or steps taken at your request before entering into a contract; compliance with legal or regulatory obligations; our legitimate interests, including investor communications, Website administration, cybersecurity, fraud prevention, governance, and protection of our legal rights; and the establishment, exercise, or defense of legal claims.

6. INTERNATIONAL TRANSFERS

We are based in the United States. Personal data may be processed, stored, or accessed in the United States or other jurisdictions where we, our affiliates, or our service providers operate.

As a result, your personal data may be transferred to jurisdictions that may not provide the same level of data protection as your home jurisdiction. Where required by applicable law, we will implement appropriate safeguards for international transfers of personal data.

7. DATA RETENTION

We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to manage our relationships, provide requested information, maintain business and compliance records, comply with legal and regulatory obligations, resolve disputes, preserve evidence, and enforce our rights and agreements.

Retention periods may vary depending on the nature of the information and the purpose for which it was collected.

8. DATA SECURITY

We maintain administrative, technical, and physical safeguards designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, access, or use.

These safeguards may include access controls, authentication procedures, password protections, logging, vendor oversight, and other risk-based security measures appropriate to the nature of the information and the context in which it is processed.

However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

9. YOUR RIGHTS AND CHOICES

Subject to applicable law, you may have the right to request access to personal data we hold about you, request correction of inaccurate or incomplete personal data, request deletion of personal data in certain circumstances, object to certain processing activities, request restriction of processing, request portability of certain personal data, and withdraw consent where processing is based on consent.

You may also opt out of promotional communications by using any unsubscribe mechanism included in those communications or by contacting us directly. We may take reasonable steps to verify your identity before responding to a request.

10. ADDITIONAL NOTICE FOR EU AND EEA INDIVIDUALS

This section applies to individuals located in the European Union or the European Economic Area.

Depending on the nature of your interaction with us, the relevant controller of your personal data may be Bramble Run, LLC and/or Lucerne Capital Management, L.P.

If you are located in the EU or EEA, and subject to applicable law, you may have the right to access your personal data, correct inaccurate or incomplete personal data, request erasure of your personal data in certain circumstances, restrict processing, object to processing based on legitimate interests, receive a copy of certain personal data in a portable format, and withdraw consent at any time where processing is based on consent.

You may also lodge a complaint with the data protection authority in your country of residence, place of work, or the place of the alleged infringement.

Where we transfer personal data outside the EU or EEA, we will do so using lawful transfer mechanisms as required by applicable law.

11. THIRD-PARTY LINKS

The Website may contain links to third-party websites, portals, or services. We are not responsible for the privacy, security, or content practices of those third parties, and this Privacy Policy does not apply to them.

12. CHILDREN

The Website is not directed to children, and we do not knowingly collect personal data from anyone under the age of 16 through the Website.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised Effective Date.

14. CONTACT INFORMATION

If you have questions about this Privacy Policy or wish to exercise any rights that may be available to you, please contact:

Bramble Run, LLC

and Lucerne Capital Management, L.P.

Attn: Chief Compliance Officer

pm@lucernecap.com

DISCLAIMER & IMPORTANT DISCLOSURES

The information contained on this Website is provided by Bramble Run, LLC together with its affiliate Lucerne Capital Management, L.P. (collectively, the “Firm”) for informational purposes only.

Under no circumstances should the content of this Website be used or considered as an offer to sell or a solicitation of an offer to buy securities, including any interest in any investment fund or other investment vehicle. Any such offer or solicitation can and will be made only by means of the appropriate offering materials, only in jurisdictions in which such an offer would be lawful, and only to persons who meet the investor eligibility, suitability, and sophistication requirements set forth in such materials. Access to such materials is similarly limited to persons who meet the applicable investor eligibility, suitability, and sophistication requirements.

1. INFORMATIONAL PURPOSES ONLY

This Website is provided solely for general informational purposes. It does not constitute investment advice, legal advice, tax advice, accounting advice, regulatory advice, or any other form of professional advice.

You should not rely on the contents of this Website as the basis for making any investment or other decision. You should consult your own advisers before making any such decision.

2. FOR INSTITUTIONAL AND OTHER ELIGIBLE PERSONS ONLY

This Website is intended solely for institutional investors, family offices, consultants, counterparties, and other sophisticated or professional contacts. This Website is not intended for retail investors or the general public.

3. NO ADVISORY OR FIDUCIARY RELATIONSHIP

Access to this Website, or receipt of information from it, does not create an investment advisory, fiduciary, advisory, or client relationship with the Firm. No such relationship shall exist unless and until formal written agreements have been executed.

4. OFFERING MATERIALS CONTROL

Any investment opportunity referred to on this Website is available only through formal confidential offering materials. To the extent this Website refers to any fund, investment vehicle, strategy, or opportunity, such description is qualified in its entirety by the applicable offering materials and governing documents.

In the event of any inconsistency between this Website and any offering memorandum, limited partnership agreement, subscription document, side letter, managed account agreement, or other governing document, the applicable governing document shall control.

5. FORWARD-LOOKING STATEMENTS

This Website may contain statements regarding future expectations, objectives, plans, market views, opportunities, projections, estimates, pipeline matters, or other forward-looking information.

Forward-looking statements are inherently uncertain and subject to risks, assumptions, and contingencies, many of which are beyond the Firm’s control. Actual results may differ materially from those expressed or implied.

6. PERFORMANCE DISCLOSURE

Any references to past performance, targeted returns, projected performance, expected outcomes, or investment case studies are provided for illustrative purposes only unless otherwise expressly stated.

Past performance is not indicative of future results. There can be no assurance that any investment strategy, fund, or opportunity will achieve its objectives or avoid losses.

7. RISK FACTORS

Investments in farmland, agriculture-related assets, private funds, and other real assets involve substantial risk, including the possible loss of all or a substantial portion of invested capital.

Such risks may include illiquidity, leverage, valuation uncertainty, market volatility, commodity price fluctuations, interest rate changes, operational risk, management risk, environmental risk, climate and weather variability, water availability and water regulation, crop disease and biological risks, labor shortages, supply chain disruptions, tax changes, regulatory changes, and counterparty risk.

These investments may be speculative and are not suitable for all investors.

8. NO WARRANTY

The information on this Website is provided “as is” and “as available.” The Firm makes no representation or warranty, express or implied, regarding the accuracy, completeness, timeliness, reliability, or fitness for a particular purpose of any information contained on this Website.

The Firm assumes no obligation to update any information on this Website.

9. THIRD-PARTY CONTENT AND LINKS

This Website may contain links to or references to third-party content, portals, media coverage, service providers, or virtual data room platforms. Such links and references are provided solely as a convenience. The Firm does not endorse, control, or assume responsibility for any third-party content, services, security, privacy practices, or availability.

10. RESTRICTED ACCESS AND CONFIDENTIAL MATERIALS

Certain portions of this Website may be restricted to approved users and may contain confidential, proprietary, or investor-only materials.

Access to such materials may be subject to additional terms, confidentiality obligations, and eligibility requirements. Unauthorized access, use, copying, or distribution is prohibited.

11. JURISDICTIONAL LIMITATIONS

This Website is not intended for distribution to, or use by, any person or entity in any jurisdiction where such distribution or use would be contrary to applicable law or regulation.

Persons who access this Website from outside the United States do so on their own initiative and are responsible for compliance with applicable local laws and regulations.

12. EU AND EEA NOTICE

In the European Union and European Economic Area, this Website is directed only at persons to whom it may lawfully be communicated under applicable law and is not directed at retail investors.

Nothing on this Website is intended to constitute a public offer of securities or interests in any fund in the European Union or European Economic Area. Any investment opportunity will be made available only through lawful channels and only to eligible persons.

13. REGULATORY STATUS

Nothing on this Website should be interpreted as indicating that any regulator has approved the merits of any investment opportunity, strategy, fund, or service described on this Website or has passed on the adequacy of the information contained herein.

14. INTELLECTUAL PROPERTY

Unless otherwise indicated, all content on this Website, including text, graphics, design, logos, downloads, and other materials, is owned by the Firm or its licensors and may not be copied, reproduced, republished, transmitted, distributed, or modified without prior written permission, except for limited internal and non-commercial review.

15. CHANGES TO THIS DISCLAIMER

We may revise this Disclaimer from time to time. Any revised version will be posted on this Website with an updated Effective Date.

16. CONTACT INFORMATION

Questions regarding this Disclaimer may be directed to:

Bramble Run, LLC

and Lucerne Capital Management, L.P.

Attn: Chief Compliance Officer

pm@lucernecap.com