Data Protection & Cookie Notice

This Notice aims to give you information on how we collect and process your personal data through your use of our Site. California residents should refer to Section 8 of this notice for the Privacy Notice for California Residents. It is important that you read this Notice together with any other fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements other notices and is not intended to override them. 1. THE DATA WE COLLECT ABOUT YOU 2. USE & LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA 3. DISCLOSURES OF YOUR PERSONAL DATA 4. DATA RETENTION 5. YOUR LEGAL RIGHTS 6. HOW TO CONTACT US 7. CHANGES TO THIS NOTICE 8. CALIFORNIA ADDENDUM 1. THE DATA WE COLLECT ABOUT YOU We may collect and otherwise process different types of personal data from multiple sources, including: (i) collecting personal data directly from you; (ii) personal data that is automatically generated about you; and (iii) personal data that we receive about you from other. Your personal data that we may collect includes: Contact information: including your name, email, phone number, company name, company website. We collect this information directly from you. Services data: including your usernames and passwords, details about payments to and from you, other details of services you have obtained from us or we have obtained from you, transaction information, and your interest, feedback and survey responses; Professional information: including your job title, email address, phone number, addresses, employment status, employer name, previous positions, and professional experience; and Usage data: including IP address, website usage and other technical data such as details of your visit to our websites, or information collected through cookies and other tracking technologies (please refer to our Cookie Notice for more details); and Publicly available information: including information from public registers of individuals; public registers of companies, charities, law firms, chartered accountant, stock or commodities exchange participants, mutual and other entities; public registers of sanctioned persons and entities; other public sources. Cookie information: As you interact with our website we will automatically collect certain information via cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following types of cookies: (a) Essential cookies. These are cookies that are strictly necessary for the operation of our website. They include, for example, cookies used for security reasons and to login. (b) Analytical cookies. These (b) allow us to recognize and count the number of visitors and to distinguish users. (c) Functionality cookies. These are used to record your cookie preference. 2. USE & LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA Under certain data protection laws, we can only use your personal data if we have a valid reason. With respect to the processing of your personal data in the context of the Site, this is generally because: 1. you have given consent (“Consent”); 2. to comply with our legal and regulatory obligations (“Legal Obligations”); 3. it is necessary for the performance of a contract with you or to take steps at your request before entering into a contract (“Performance of a Contract”); or 4. it is in our legitimate interests or those of a third party (“Legitimate Interests”). A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. We do not conduct any processing activities relating to your personal data that involves any automated decision-making (including profiling). 3. DISCLOSURES OF YOUR PERSONAL DATA We may share your personal data within HPA Exchange, LLC and or it’s affiliates and any other investment fund managed by HPA Exchange, LLC and or it’s affiliates Asset Management LP and/or its affiliates. In addition, we may have to share your personal data with the parties set out above for the purposes for the purposes as set out. Some of our external third parties may be based or process personal data internationally. In case of international transfers of personal data, the laws of certain jurisdictions may provide a lower level of protection with respect to your personal data relative to the laws of your home country. We will protect your personal data in such international jurisdictions in accordance with applicable law. Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: • We will transfer your personal data to a country that has been deemed to provide an adequate level of protection for personal data by the ICO and/or relevant data supervisory authorities. • We may use specific contracts approved by the relevant authorities which give your personal data the same protection it has in the UK/EEA. Please use the contact details below to find out more about the transfer mechanisms relied upon to share personal data. 4. DATA RETENTION We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 5. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to request us to: (a) provide access to personal data we hold about you; (b) rectify any inaccuracies in your personal data that we hold; (c) delete any of your personal data that we no longer have a legitimate interest to process; (d) where we process your personal data based on your consent, withdraw your consent so that we stop that particular processing; (e) port your personal data and to request the transmission of such data to another organization; (f) object to any processing of your personal data based on our "legitimate interests" unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; (g) object to any processing of your personal data for direct marketing purposes (including any profiling activities in connection with direct marketing) (h) restrict how we process your personal data whilst a data protection complaint is being investigated. If you wish to exercise any of the rights set out above, please contact us using the details below. Turning Off Cookies In addition to using the options in the cookie banner, if you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our Site. [To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout ] Complaints You also may have the right to make a complaint to applicable data supervisory authorities for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach such authorities so please contact us in the first instance using the contact details at the end of this Notice. 6. HOW TO CONTACT US You can contact us about any query or concern or complaint in relation to this Notice by emailing  optout@hpaxchange.com

and or it’s affiliates.com . 7. CHANGES TO THIS NOTICE We may update this Notice to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our Notice. 8. ADDENDUM: PRIVACY NOTICE FOR CALIFORNIA RESIDENTS This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the HPA Exchange, LLC and or it’s affiliates Asset Management LP (“HPA Exchange, LLC and or it’s affiliates” or “we” or “us” or “our”) Privacy Policy and applies solely to all visitors and users who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, “CCPA”), and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements. Information We Collect We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include: • Publicly available information from government records. • Deidentified or aggregated consumer information. • Information excluded from the CCPA’s scope, such as: o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Use of Personal Information We do not sell your personal information. We may use or disclose the personal information we collect for one or more of the following purposes: • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to provide that service to you. We may also save your information to facilitate future communications and services. • To provide, support, personalize, and develop our Site, products, and services. • To create, maintain, customize, and secure your account with us. • To process your requests, transactions, and payments and prevent transactional fraud. • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. • To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business. • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. • As described to you when collecting your personal information or as otherwise set forth in the CCPA. • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Sharing Personal Information We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we make efforts to ensure that the recipient will both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties: • Affiliates. • Firms that provide assistance in servicing HPA Exchange, LLC and or it’s affiliates and that have a need for such information, such as CRMs or other service providers. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: • The categories of personal information we collected about you. • The categories of sources for the personal information we collected about you. • Our business or commercial purpose for collecting or selling that personal information. • The categories of third parties with whom we share that personal information. • The specific pieces of personal information we collected about you (also called a data portability request). • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: o sales, identifying the personal information categories that each category of recipient purchased; and o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Deletion Request Rights You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: • Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you. • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. • Exercise another right provided for by law. • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. • Comply with a legal obligation. • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. Sensitive Personal Information Under CCPA, California residents have the right to restrict the processing of sensitive personal information under certain circumstances. We collect and process the following categories of sensitive personal information in compliance with California law and this Privacy Policy: • Personal information that reveals a consumer's: social security, driver's license, state identification card, or passport number; 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; or genetic data. If you would like to request that we restrict the processing of your sensitive personal data, please email us at info@HPA Exchange, LLC and or it’s affiliates.com. Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: • Calling us at 212-847-3500 • Emailing us at info@HPA Exchange, LLC and or it’s affiliates.com Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: o An email address that operates as a user log-in with HPA Exchange, LLC and or it’s affiliates, name, and date of birth. o Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Right to Correct If your personal information which process is inaccurate, you have to right to request correction. To exercise this right, please email us at info@HPA Exchange, LLC and or it’s affiliates.com “California Right to Correct” in the subject line and the specific pieces of information you would like corrected and the particular inaccuracy. Response Timing and Format We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Changes to Our Privacy Notice We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Site and update the Notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes. Contact Information If you have any questions or comments about this Notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or you wish to exercise your rights under California law, please do not hesitate to contact us at: Email: info 

@HPA Exchange, LLC and or it’s affiliates.com