Terms of Use
Effective October 28, 2026
These terms govern your use of ponderatocapital.com (the “site”), which is operated by Ponderato Capital Management LLC (“Ponderato,” “we”). By using the site, you agree to them. If you do not agree, please do not use the site.
Not an offer
Nothing on this site is an offer to sell, or a solicitation of an offer to buy, any security or any investment advisory service. Any offer of interests in a fund managed by Ponderato will be made only through that fund’s confidential offering documents, and only to investors who meet the eligibility requirements set out in them.
No advice
The site provides general information about Ponderato. It is not investment, legal, tax or accounting advice, and it is not a recommendation to buy or sell any security. Do not rely on it in making an investment decision; consult your own advisers.
Information on the site
We work to keep the site accurate, but its content speaks only as of the date it was written, may change without notice and may not be complete. We are not obligated to update it. Investing involves risk, including the possible loss of the amount invested, and past performance is not indicative of future results.
Investor portal and other sites
Access to any investor portal reached from this site is limited to authorized users and is governed by the terms and privacy notice of the portal’s operator. The site may also link to sites run by others. We do not control those sites and are not responsible for their content, terms or privacy practices.
Contacting us
Sending us an email or a call request does not create a client or advisory relationship, and we cannot accept instructions or orders that way. Please do not send account numbers, identification numbers or other confidential information by email or through the site.
Ownership of content
The site’s text, design, logos and other content belong to Ponderato or its licensors. You may view and print pages for your own personal, non-commercial use. Any other use, including copying, distributing or modifying the content, requires our written permission.
Disclaimer and limitation of liability
The site is provided “as is” and “as available,” without warranties of any kind, express or implied. To the fullest extent the law allows, Ponderato and its members, managers, employees and agents are not liable for any loss or damage arising from your use of, or inability to use, the site or its content.
Privacy
Our Privacy Notice explains how we handle information collected through the site.
Changes to these terms
We may update these terms by posting a new version on this page with a new effective date. Your continued use of the site after a change means you accept the updated terms.
Governing law
These terms are governed by the laws of the State of California, without regard to its conflict of laws rules.
Contact
Ponderato Capital Management LLC
San Diego, California
info@ponderatocapital.com