Terms of Use

Effective Date: September 21, 2025

Thank you for visiting this website, which is provided to you solely for informational purposes by Gradatim Capital, LLC (“Gradatim Capital” or "GC").

These terms and conditions (“Terms of Use”) are a contract between users (“you”) and Gradatim Capital and apply to the website located at gradatimcapital.com, its content and any other webpages owned and/or operated by us that link back to, or otherwise display, these Terms of Use, including any password-protected areas of this site (the “Website”).

By using the Website, you agree to abide by these Terms of Use. If you do not agree to abide by these Terms of Use, your sole and exclusive remedy is to discontinue using the Website. Your compliance with these Terms of Use is a condition to your right to access the Website. This document affects your legal rights, including limiting your damages if you sue us, so please read it carefully.

We reserve the right, in our sole discretion, to change, modify, add or remove any portion of the Website, including the Terms of Use, in whole or in part, at any time, without prior notice to you. Changes to these Terms of Use will be effective when posted. For this reason, we encourage you to visit and review this page regularly to ensure that you are familiar with the then-current Terms of Use that apply to your use of the Website. The date of the last revision or update appears at the top of the Terms of Use under the title next to Effective Date.

Acceptable Use of the Website

All materials, including but not limited to images, text, data, illustrations, designs, icons, photographs, programs, downloads, videos, services and content (“Content”) that are part of the Website are intended solely for personal, non-commercial use. We authorize you to view and access a single copy of the Content available on the Website for your own use. You agree to only use the Website and the Content for the purposes for which it has been designed. You further agree to comply with these Terms of Use and all applicable local, state, national, and international laws, rules, and regulations. Please be advised that we may record certain usage information, such as the number and frequency of visitors to the Website.

Restrictions on Use

As a condition of your use of the Website, you agree that you will not, under any circumstances:

Reproduce, publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of or exploit in any way, in whole or in part, any Content;
Use the Website in any manner that could damage, disable, overburden, or impair the Website or interfere with proper functioning of the Website, including making automated use of the Website or taking any action that we deem to impose or potentially impose an unreasonable or disproportionately large load on our servers or network infrastructure;
Use the Website for any unlawful purpose or for the promotion of illegal activities;
Interfere with or disrupt or attempt to interfere with or disrupt the Website or servers or networks connected to the Website, or disobey any requirements, procedures, policies, or regulations of networks connected to the Website, including bypassing any measure we take to restrict access to the Website;
Use any software, technology or device to scrape, spider, or crawl the Website or harvest or manipulate data on the Website;
Reverse engineer, decompile, disassemble, or otherwise attempt to extract or discover the source code of the Website or any part thereof, except and only to the extent that such activity is expressly permitted by applicable law notwithstanding this limitation; or
Use another’s user ID and password to access the Website without permission.

If we believe you are using or attempting to use the Website in breach of any one or more of these restrictions, we reserve the right to suspend or terminate your ability to use the Website (or any portion thereof).

Linked Sites and Other Third-Party Content

The Website may provide links to websites operated by other people or entities. These links are provided strictly for your convenience. In addition, with or without our consent, third-party sites may be linked to the Website and third parties may repost outside of the Website information shared by Gradatim Capital on the Website. We make no warranty or representation regarding, do not endorse, and do not accept any responsibility for, any websites linked to or from the Website or the information appearing thereon or any of the products or services described thereon. You acknowledge and agree that use of third-party websites is strictly at your own risk. You may not link a part of the Website to another website without our express permission. We make no warranty or representation regarding, do not endorse, and do not accept any responsibility for, any information that is reposted from the Website without Gradatim Capital’s express permission.

Additionally, the Website may show news released by, and other content prepared by, organizations other than Gradatim Capital (such news and other content, “Third-Party Content”). We make no warranty or representation regarding, do not endorse, and do not accept any responsibility for, any Third-Party Content shown on the Website. The Social Media Sites may also show comments or reactions (including likes and emojis) (collectively, “Comments”) from third parties and Gradatim Capital employees. We make no warranty or representation regarding, do not endorse, and do not accept any responsibility for, any Comments.

The Website may otherwise make references to other entities, including displaying logos or symbols of such entities (each such reference, “Third-Party Reference”). We make no warranty or representation regarding, and do not accept any responsibility for, any such Third-Party Reference. Additionally, no Third-Party Reference indicates, and no Third-Party Reference should be viewed as, an endorsement, either by Gradatim Capital of such entity or by such entity of Gradatim Capital.

Gradatim Capital Invests in Publicly Traded Securities

Gradatim Capital invests in publicly traded securities around the world. As a result, Gradatim Capital does not want to receive material, non-public information about publicly traded companies or their securities. Gradatim Capital thus does not wish to receive material, non-public information or otherwise confidential information about a public company from any source.

Intellectual Property

The Website and its Content are the exclusive property of and owned by Gradatim Capital. The Website contains and is protected by intellectual property rights, including copyrights, tradenames, trademarks, logos, and service marks (whether registered or not, and wherever in the world those rights may exist) owned by Gradatim Capital or third parties that have licensed their materials or provided services to Gradatim Capital.Access to or viewing materials posted to the Website does not confer any license under any of our or any third party’s intellectual property rights or otherwise authorize you to use any trademark, logo, service mark, copyright, or other intellectual property, except as explicitly provided herein, agreed to by Gradatim Capital or permitted under applicable law. The Content of the Website may not be reproduced or redistributed in whole or in part, in any format, without the express written approval of Gradatim Capital.

No Offers of Securities or Investment Advisory Services

The Content provided on the Website is for informational purposes only, and the Website and its Content are intended solely to provide general information about Gradatim Capital, its people, and its services to individuals, advisors, and institutions. The Website is not directed towards any existing or prospective investor in any fund or investment vehicle managed by Gradatim Capital.

Gradatim Capital is not utilizing the Website to offer securities or its investment advisory services and the Website and its Content should not be construed as an offer to sell or a solicitation of an offer to buy an interest in any fund, investment vehicle, or account managed by Gradatim Capital. Any such offer or solicitation will be made only through a final private placement memorandum, subscription agreement, prospectus, or other related document with respect to a particular investment opportunity (each, an “Offering Document” and, collectively, the “Offering Documents”) and will be subject to the terms and conditions in such documents, including the qualifications necessary to become an investor. The information on the Website is superseded by, and is qualified in its entirely by reference to, the Offering Documents. None of the information contained on the Website has been filed with the U.S. Securities and Exchange Commission, any securities administrator under any state securities laws or any other governmental or self-regulatory authority. No governmental authority has passed on the merits of the offering of interests in any fund, investment vehicle, or account managed by Gradatim Capital or the adequacy of the information contained on the Website. Any representation to the contrary is unlawful. Any decision to invest or take any other action with respect to the securities or investments shown or discussed on the Website may involve risks not discussed herein and no such decisions should be made based on the information contained on the Website.

It should not be assumed that any securities or investments shown or discussed on the Website will increase in value. You are solely responsible for evaluating the risks and merits regarding use of the Website and should obtain relevant and specific professional advice, including tax advice, from your legal, financial, personal and other advisers, before making any investment or financial decision or purchasing any financial, securities or investment-related service or product.

No Investment Advice or Recommendations

Furthermore, Gradatim Capital is not utilizing the Website to provide investment or other advice, and nothing on the Website should be interpreted, used in any manner as, or deemed investment advice or a means to make or communicate investment or other decisions. To obtain such advice, you should consult with your own professional advisor.

In addition, nothing contained on the Website shall constitute a recommendation or endorsement of any securities and any references to any securities or portfolio companies should not be used as the basis for making any decision about purchasing, holding or selling any securities or investments.

Any discussions of securities and portfolio companies on the Website is intended to be illustrative and is not intended to be used as an indication of the current or future performance of any securities, funds or portfolio companies. Any transactions described on the Website as having been engaged in by us are included for illustrative purposes only and are not necessarily reflective of overall performance of all transactions or any of our businesses or funds.

Gradatim Capital and its clients trade in public securities and have made and/or may make investments in or investment decisions relating to the companies referenced on the Website or its Content. Gradatim Capital and its clients reserve the right to make investment decisions or engage in trading activity that would be (or could be construed as) consistent and/or inconsistent with the views expressed on the Website or its Content.

No endorsement, guarantee or representation regarding the performance of any security, strategy, fund, portfolio company or investment is being made hereby, including regarding the suitability of any investment or investment strategy.

No Guarantee

No representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided. Market and economic conditions in the future may vary. In addition, not all investments held by Gradatim Capital had performance that equaled the performance of the companies shown or discussed on the Website. In addition, individual performance experienced by an investor may vary depending on the structure of a particular investor’s investment.

PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS. ANY INVESTMENT INVOLVES SIGNIFICANT RISKS, INCLUDING LOSS OF THE ENTIRE INVESTMENT.

No Warranty as to Third-Party Sources

Certain information contained on the Website has been obtained from published and non-published sources. Such information has not been independently verified by Gradatim Capital, and the Website, and the information and materials herein, are provided “as is” and without warranties or representations of any kind either express or implied. Gradatim Capital and its affiliates disclaim all warranties, express or implied, including but not limited to, implied warranties of merchantability and fitness for a particular purpose. Gradatim Capital does not warrant the accuracy, completeness or reliability of any information on the Website or that the Website will operate “error free.”

Historical Information

Except where otherwise indicated on the Website, the information provided on the Website is based on matters as they exist as of the date of the Website or the date indicated therein and not as of any future date, and may not be updated or otherwise revised to reflect information that subsequently becomes available or changes in circumstances occurring after such date.

Forward-Looking Statements

Certain information on the Website may contain forward-looking statements, which can be identified by the use of terms such as “may,” “should,” “believe,” “expect,” “anticipate,” “project,” “target,” “estimate,” “optimistic,” “intend,” “aim,” “seek,” “will,” “continue” (or the negatives thereof) or other variations thereof. Examples of forward-looking statements include statements relating to macroeconomic conditions, expectations regarding future growth, including future revenue and earnings increases, margins, free cash flow projections and annual growth rates of any company. These statements are not guarantees of future performance and involve certain risks, uncertainties and assumptions that are difficult to predict with regard to timing, extent, likelihood and degree of occurrence. Therefore, actual results and outcomes may materially differ from what may be expressed or forecasted in such forward-looking statements. Furthermore, Gradatim Capital undertakes no obligation to update, amend or clarify forward-looking statements,, which only speak as of the date they are made, and there is no guarantee that these opinions or predictions will ultimately be realized. As a result, investors should not rely on such forward-looking statements in making their investment decisions. Any projection of the performance or targets discussed by Gradatim Capital is highly speculative and represents Gradatim Capital’s opinion, which may change. Gradatim Capital undertakes no obligation to update publicly or revise any statements contained on the Website, whether as a result of new information, future developments or otherwise.

No Regulatory Approval

The Content has not been reviewed, passed on, or approved by any regulatory authority and has been prepared without regard to the individual financial circumstances or objectives of persons who may receive it. The appropriateness of a particular investment or strategy will depend on an investor’s individual circumstances and objectives. No representation is being made as to the suitability of any investment.

Compliance with Applicable Law

Unless otherwise expressly set forth herein, we make no representation that materials on the Website are appropriate or available for use in any particular location. If it is illegal or prohibited in your country of origin to access or use the Website or any of its Content, including any Social Media Site, then you agree not to do so. Those who choose to access the Website do so on their own initiative and are responsible for compliance with local laws.

Password and Security Notification

Certain additional information and services available on the Website may be accessible to you only if you have been provided with a username and password (“Password User”). Use of such additional information and services may be subject to additional terms and conditions. You may not attempt to access any password protected areas of the Website without authorization. All information that we provide to Password Users is confidential and intended solely for the information of its intended recipient and/or such recipient’s financial, legal or tax advisors, provided that such advisors agree not to disclose any information that is confidential. You, as a Password User, are solely responsible for (i) maintaining the confidentiality of the password and user ID and (ii) all activities that occur under your user ID. If, in the process of obtaining a user ID and password, you provide us with any information that is untrue, inaccurate, not current, or incomplete, or if we have reason to suspect that such information is untrue, inaccurate, not current, or incomplete, we have the right to suspend or terminate your user ID and password and refuse any and all current or future use of the Website (or any portion thereof). The Password User shall immediately notify us of any loss or theft of the password, or if the confidentiality of the password has otherwise been compromised in any way. We will not be responsible or liable for any loss, expense or damage arising in any way from use of the password and user ID and/or the accessing of information or materials therewith.

Disclaimer and Indemnity

Views expressed are those of Gradatim Capital. The Website and the information and materials on the Website are provided “as is” and without warranties or representations of any kind either expressed or implied and we and our affiliates disclaim all warranties, expressed or implied, including but not limited to, implied warranties of merchantability and fitness for a particular purpose. We do not warrant the accuracy, completeness, reliability, security, suitability, availability at any or all times or timeliness of any information on the Website or that the Website will operate “error free.” In no event shall we be responsible for any damages, liabilities or injury, including indirect, incidental, special, punitive, multiple, consequential or other damages, however caused or arising out of your use of (or inability to use) the Website. If your use of the Website gives rise to any third party complaint, charge, claim, loss, expense, damage, cost, liability or demand, including attorneys’ fees (collectively, a “Claim”), against you or Gradatim Capital, you agree to (i) indemnify and hold harmless Gradatim Capital with respect to any such Claim, (ii) release Gradatim Capital from any such Claim and (iii) waive all laws that may limit the efficacy of such release.

Limitation of Liability

To the maximum extent permitted by law, we disclaim all liability arising out of your use of the Website and its Content, even if we have been advised of the possibility of the damages, liability or injury that you suffer, including any damages, liability or injury caused by any incorrectness or incompleteness of information contained herein, any failure of performance, error, omission, defect, interruption, delay in operation, computer virus, line failure or other computer malfunction, whether caused by negligence or otherwise. constitutes your acceptance of the updated Terms.