TERMS OF USE

The use of and access to this website (“Website”) is governed by these Terms of Use. Use of the Website constitutes an agreement by you, the user, that your use is governed by these Terms of Use. We may update or otherwise amend these Terms of Use at any time in our sole discretion. Your continued use of the Website after any such modifications shall constitute your acceptance of such updated or otherwise amended Terms of Use.

Please read this agreement carefully before you start to use the Website. If you do not agree to abide by these Terms of Use for any reason, you must not access or use the Website.

Ownership

The works of authorship contained in this Website, including but not limited to all design, text and images, are owned, except as otherwise expressly stated, by Comvest Private Equity (“Comvest”) or its affiliates or licensors, and shall remain the property of Comvest or its licensors. You acknowledge that the Website and its contents are protected by copyrights, trademarks, trade secrets, patents, or other proprietary rights, and that these worldwide rights are valid and protected in all forms, media, and technologies existing now and hereinafter developed.

You may not copy, reproduce, modify, use, republish, post, upload, distribute or transmit in any way material from this Website, without Comvest’s express written consent. You shall comply with all intellectual property laws and treaty provisions and you shall not encumber any interest in, or assert any rights to, the content. You may not modify, transmit, participate in the sale or transfer of, or create derivative works based on any content, in whole or in part.

“Comvest Private Equity” and all other trademarks, logos and service marks displayed on the Website are trademarks belonging to Comvest, its affiliated entities, or its licensors. Nothing on the Website should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademarks, logos or service marks displayed on the Website without Comvest’s prior written permission in each instance.

Disclaimer; No Warranties; Limitation of Liability

Comvest does not warrant or guarantee, either expressly or by implication, that any material or information on the Website is accurate, complete, reliable, or current. Comvest is not responsible for any errors or omissions on the Website, whether caused by the source of the information or Comvest. Comvest may change any material or information on the Website at any time without prior notice, but Comvest does not make any commitment to update or remove material or information on the Website. Your use of this Website and use or reliance upon any of the materials on it are solely at your own risk.

WITHOUT LIMITING THE FOREGOING OR ANYTHING ELSE SET FORTH IN THIS AGREEMENT, THE WEBSITE AND ALL OF ITS CONTENTS ARE MADE AVAILABLE BY COMVEST “AS IS” AND “AS AVAILABLE,” WITH ALL FAULTS, AND WITHOUT ANY WARRANTIES WHATSOEVER, EXPRESS OR IMPLIED. ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR PURPOSE, NON-INFRINGEMENT, TITLE, UNINTERRUPTED USE, QUIET ENJOYMENT, SYSTEM INTEGRATION, OR ACCURACY, SECURITY OF INFORMATION, OR RELIABILITY, ARE SPECIFICALLY EXCLUDED AND DISCLAIMED. COMVEST MAKES NO WARRANTY THAT THE WEBSITE, IN WHOLE OR IN PART, WILL MEET USERS’ REQUIREMENTS. USERS OF THE WEBSITE ASSUME ALL RISK AS TO THE QUALITY, ACCURACY, SUITABILITY, AVAILABILITY AND PERFORMANCE OF THE WEBSITE AND ITS CONTENTS AND ACKNOWLEDGE THAT THE WEBSITE AND ITS CONTENTS MAY BE REVISED, ALTERED AND CHANGED FROM TIME TO TIME IN THE SOLE DISCRETION OF COMVEST. COMVEST DOES NOT REPRESENT OR WARRANT THAT ANY WEBSITE CONTENT WILL OPERATE CONTINUOUSLY OR WILL BE UNINTERRUPTED OR ERROR-FREE, OR THAT ANY DEFECTS WILL BE CORRECTED, OR THAT THIS WEBSITE OR ANY WEBSITE REFERRED OR LINKED TO HEREIN IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. COMVEST ALSO ASSUMES NO RESPONSIBILITY, AND SHALL NOT BE LIABLE FOR, ANY DAMAGES TO, OR VIRUSES THAT MAY INFECT, YOUR COMPUTER EQUIPMENT OR OTHER PROPERTY ON ACCOUNT OF YOUR ACCESS TO, USE OF, OR BROWSING IN THE WEBSITE OR YOUR DOWNLOADING OR UPLOADING OF ANY MATERIALS, DATA, TEXT, OR CONTENTS FROM OR TO THE WEBSITE.

COMVEST ASSUMES NO LIABILITY FOR LOSS OR DAMAGE HOWSOEVER RESULTING FROM ANY USE OF OR RELIANCE UPON THE WEBSITE OR ITS CONTENTS. IN NO EVENT WILL COMVEST OR ANY OF ITS AFFILIATES BE LIABLE FOR ANY LOST PROFITS, LOST SAVINGS, LOST DATA, BUSINESS INTERRUPTION, OR OTHER DIRECT, INDIRECT, EXEMPLARY, PUNITIVE, SPECIAL, CONSEQUENTIAL OR INCIDENTAL DAMAGES OR CLAIMS (WHETHER IN CONTRACT, IN TORT, OR OTHERWISE) ARISING OUT OF OR RELATING TO THE WEBSITE, ITS CONTENTS, THE USE THEREOF, OR THE INABILITY TO USE THE WEBSITE, EVEN IF COMVEST HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH LOSS OR DAMAGE.

This Website is operated and controlled by Comvest in the United States. Comvest makes no warranties that materials on this Website are appropriate or available for use outside of the United States. If it is illegal or prohibited in your country of origin to access or use this Website, then you should not do so. You are responsible for compliance with all local laws and regulations applicable to your use of the Website.

Restrictions on Use

You agree not to interrupt, damage, disable, overburden or impair the Website or interfere with any other user’s use and enjoyment of the Website, such as sending mass unsolicited messages or “flooding” servers with requests. You agree not to violate or attempt to violate the security of the Website, including, without limitation, by (1) accessing data not intended for your viewing or logging into a server or account which you are not authorized to access, (2) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization or (3) attempting to interfere with service to any user, host or network. Violations of system or network security may result in civil or criminal liability. Comvest will investigate occurrences which may involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in such violations. Comvest will also comply with all court orders as well as all law enforcement and regulatory inquiries involving requests for such information.

No Offer or Advice

This Website is primarily designed to provide information on financing to potential portfolio companies. The information provided on this Website, including information regarding Comvest’s current and historical portfolio companies, is not intended to recommend any company or investment described herein and is not an offer or sale of any security or investment product or investment advice. In any event, past performance is not a guarantee of future results and it should not be assumed that results for portfolio investments will be achieved for other investments. Representative investments are not to be considered a complete list of all investments made or currently held by Comvest funds.

Comvest provides investment advisory services only to the privately offered Comvest funds. Comvest does not solicit or make its services available to the public or other advisory clients. References to “capital under management” refers to the aggregate capital committed to all private equity funds managed by Comvest.

Statements included on the Website may constitute “forward-looking statements,” which relate to future events or our future performance or financial condition. These statements are not guarantees of future performance, condition or results and involve a number of risks and uncertainties. Actual results and condition may differ materially from those in the forward-looking statements as a result of a number of factors. Comvest undertakes no duty to update any forward-looking statements made herein.

Links

The Website may include links to third party sites which are not related to or maintained by Comvest. Links to third party sites do not imply partnerships, relationships or affiliations with such third parties and Comvest takes no responsibility for the content therein, regardless of whether the link is provided by Comvest or a third party. No judgment or warranty is made with respect to the accuracy, timeliness, or suitability of the content of any website to which the Website may link, including information on such other website regarding Comvest. By providing access to other website, Comvest is not endorsing the products and services provided by any website’s sponsoring organization.

Other websites may include a link to this Website provided that Comvest has granted its express written consent. Third parties are expressly prohibited from framing Comvest’s content in any way or any other activity that may create a misimpression or confusion among users with respect to sponsorship or affiliation including, without limitation, hyperlinks or a form of link that disguises the URL and bypasses the homepage.

Submitted Materials

Unless specifically requested, we do not solicit, nor do we wish to receive, any confidential, secret or proprietary information or other material from you through the Website, by e-mail, through the “Contact Us” feature, or in any other way. Any information, proposals, requests, creative works, pictures, documents, demos, ideas, suggestions, concepts, methods, systems, designs, plans, techniques or other materials submitted or sent on or through the Website in any manner (collectively, “Submissions”) will be deemed not to be confidential or secret, and may be used by us in any manner consistent with this agreement and our privacy policy. By submitting Submissions on the Website, you: (1) represent and warrant that you have the necessary licenses, rights, consents and permissions to use such Submissions and submit them to the Website; and (2) you grant us (and our affiliates) a royalty-free, unrestricted, worldwide, perpetual, irrevocable, non-exclusive and fully transferable, assignable and sublicensable right and license to use such material (in whole or part) in any manner and/or to incorporate it (in whole or in part) in other works (including, without limitation, the Website), products or services in any form, media, or technology now known or later developed. We cannot be responsible for maintaining any Submitted Material that you provide to the Website, and we may delete or destroy any such Submitted Material at any time.

Privacy Statement

Comvest is committed to protecting your privacy online. To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used at the Website.

When you visit the Website, we may collect personally identifiable information, including name, address and email address. We also may collect certain non-personally identifiable information when you visit many of our pages, such as the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider.

We also collect certain information about you through the use of “cookies”, which are small pieces of information that are stored by your browser on your computer’s hard drive. We collect, retain and use information about you solely for the purpose of better understanding our users and their use of the Website. Comvest will not release information collected about you unless we receive your prior consent or we are required by law to release such information.

We use the non-personally identifiable information that we collect to improve the design and content of the Website and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze site usage. Information collected through the Website may be transferred to Comvest’s affiliated companies if it is necessary to do so in order to carry out the purpose of your submission. By submitting information through the Website, you consent to such transfer of information to Comvest’s affiliated companies. Comvest will not release information collected about you unless we receive your prior consent or we are required by law to release information to the recipient.

Text Messaging Policy

By providing your mobile phone number to Comvest and opting in to receiving text messages through our website, you consent to receive text messages from Comvest. Comvest will not utilize an automatic telephone dialing system to send text messages to you, nor will Comvest share your phone number with any third parties for the purpose of promotional text message communications. The frequency of messages may vary. Standard message and data rates may apply. You acknowledge that you are responsible for any message, data, or other charges incurred as a result of opting in to receiving text messages from Comvest. Please note that not all mobile devices, carriers, or handsets may be supported, and our messages may not be deliverable in all areas, such as outside of the United States.

You may opt out of receiving text messages at any time by texting STOP in response to any text message you receive. Upon receiving your opt-out request, we will confirm your opt-out status via text message and will not send you any further text messages unless you opt back in.

General Terms and Conditions

These Terms of Use are governed and interpreted pursuant to the laws of the State of Florida, United States of America, notwithstanding any principles of conflicts of law. If you take legal action relating to these terms, you agree to file such action only in the state and federal courts located in the State of Florida, County of Palm Beach. The parties hereby agree to exclude the application of the United Nations Convention on Contracts for the International Sale of Goods. If any part of these Terms of Use is unlawful, void or unenforceable, that part will be deemed severable and will not affect the validity and enforceability of remaining provisions. You are prohibited from any use of the Website that would constitute an illegal offense, give rise to liability or otherwise violate any applicable local, state, national or international law or regulation. All rights not expressly granted herein are reserved by Comvest. The Website may contain additional agreements and disclosures in electronic form. By assenting to this Agreement, you agree that a printed version of these Terms of Use and all other agreements entered into by you on the Website in electronic form shall be admissible in judicial or administrative proceedings to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

CALIFORNIA PRIVACY NOTICE

June 2025

This notice (the “California Privacy Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended, together with any implementing and successor legislation to the foregoing (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Privacy Notice is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this California Privacy Notice is otherwise set forth above in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect: We collect or have collected within the last twelve (12) months some or all of the following categories of personal information from individuals:

Category Examples Collected
A. Identifiers Name, contact details and address (including physical address and email address), and other identification (including social security number, passport number and driver’s license or state identification card number). YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

 

Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income, and assets). YES
C. Protected classification characteristics under California or federal law

 

Date of birth, citizenship, and birthplace. YES
D. Commercial information Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). YES
E. Biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. NO
F. Internet or other similar network activity Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries YES
G. Geolocation data

 

Physical location or movements. NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information

 

Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below) Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. YES, as to the following types of information: social security, driver’s license, state identification card, or passport numbers, account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

  • To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
  • As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
  • For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
  • To perform services on behalf of our business;
  • To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Purposes for Collecting Personal Information: We may process or disclose the personal information we collect about you for one or more of the following business or commercial purposes:

  • performing services to you, including, but not limited to:
    • the administrative processes (and related communication) in preparing for the admission of investors to the fund(s);
    • ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund;
    • the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
    • ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of (each) fund in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
    • keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
  • auditing and verifications related to investor interactions, including, but not limited to, verifying the quality and effectiveness of services and compliance;
  • detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity; and
  • complying with S., state, local and non-U.S. laws, rules and regulations.

We collect personal information from the sources set forth in “Sources of Information” in the Privacy Notice above. We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this California Privacy Notice only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.

Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

We disclose or, within the last twelve (12) months have disclosed, personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category Category of Third-Party Recipients
A. Identifiers Fund Managers, administrators, depositories, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Fund Managers, administrators, depositories, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law Fund Managers, administrators, depositories, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information Fund Managers, administrators, depositories, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information N/A
F. Internet or other similar network activity Fund Managers, administrators, depositories, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data N/A
H. Sensory data N/A
I. Professional or employment-related information N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) N/A
K. Inferences drawn from other personal information N/A
L. Sensitive Personal Information Fund Managers, administrators, depositories, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

Rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you over the last twelve (12) months. Such information includes:

  • The categories of personal information we collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting such personal information;
  • Categories of third parties to whom we disclose the personal information;
  • The specific pieces of personal information we have collected about you; and
  • Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this California Privacy Notice in an alternative format, please submit a request using any of the methods set forth below. If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number either (1) through the online form below or (2) by email at dataprivacy@comvest.com, and we will call you during business hours.

Submit a request online using the following online form: https://comvest.com/contact-us/.

Email us at the following address: dataprivacy@comvest.com.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request your investor portal access credentials in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact the Chief Administrative Officer of Comvest Private Equity at the email address above with any questions or concerns about this California Privacy Notice.