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EXI Investment Partners Privacy Policy

Effective Date: November 20, 2024

Introduction

At EXI Investment Management LLC (“EXI,” “we,” “us,” or “our”), we are committed to protecting your privacy. This Privacy Policy outlines our practices regarding the collection, use, and disclosure of information that you may provide to us through our website www.exipartners.com (the “Site”).

This policy applies to information we collect:

  • On this Site.

  • In email, text, and other electronic messages between you and this Site.

This policy does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by EXI or any third party; or

  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Site. By accessing or using this Site, you agree to this privacy policy. This policy may change from time to time (See Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those change, so please check the policy periodically for updates.

Information We Collect and How We Collect It

We collect several types of information from and about users of our Site, including information:

  • By which you may be personally identified, such as name, e-mail address, or telephone number (“personal information”);

  • That is about you but individually does not identify you, such as company name; and

  • Any other information you voluntarily provide

We collect this information:

  • Directly from you when you provide it to us. This includes information that you provide by filling in forms on our Site, such as information provided at the time of registering to use our Site, subscribing to our newsletter, filling out webforms or submitting search queries, requesting further services, or interacting with us in other ways. We may also ask you for information when you report a problem with our Site.

Third-Party Use of Cookies

Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How Your Information Is Used and Disclosed.

How We Use Your Information

We may use the personal information we collect for various purposes, including:We may use the personal information we collect for various purposes, including:

  • To present our Site and its contents to you.

  • To improve customer service and respond to your inquiries.

  • To personalize your experience on our Site.

  • To send periodic emails regarding our services or other products.

  • To manage our investment activities and communicate with investors.

  • To fulfill any other purpose for which you provide it.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To contractors, service providers, and other third parties we use to support our business.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EXI’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by EXI about our Site users is among the assets transferred.

  • To fulfill the purpose for which you provide it.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our Site Terms of Use and other agreements to which EXI is a party, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EXI, our customers, or others.

Choices About How Your Information Is Used and Disclosed

We strive to provide you with choices regarding the personal information you provide to us. The following mechanisms are available to provide you with the following control over your information:

  • Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.

  • Targeted Advertising: We do not control third parties’ collection or use of your information to serve interest based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted advertisements from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information

You can review and change your personal information by sending us an email at info@exipartners.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request if we believe the request would violate any law, legal requirement, this policy, or our Terms of Use or if it would cause the information to be incorrect.

State Privacy Laws

We do not meet the conditions as outlined in Section 1798.140 of the California Consumer Privacy Act of 2018 (the “CCPA”) and therefore are not subject to CCPA requirements. We also do not meet the eligibility conditions outlined in the Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Montana Consumer Data Privacy Act, the Florida Digital Bill of Rights, the Nebraska Data Privacy Act, the New Hampshire SB 255, the Delaware Personal Data Privacy Act, or the New Jersey Data Privacy Act, and are therefore not subject to the requirements of these laws. For specific information related to your ability to access and control your personal information, see Accessing and Correcting Your Information above.

Security of Your Information

We implement a variety of security measures to maintain the safety of your personal information. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Links to Third-Party Websites

Our Site may contain links to third-party websites that are no affiliated with us. We do not control these websites and are not responsible for their content or privacy practices. Once you have used these links to leave our Site, any information you provide to such third parties is not covered by this policy. We encourage you to review the privacy policies of any third-party sites you visit.

Children Under the Age of 13

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on this Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site, register on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification or parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@exipartners.com.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account or by placing a prominent notice on our Site. The date the privacy policy was last revised is at the top of this page. Your continued use of the Site after such modifications will constitute your acknowledgment of the modifications and your consent to abide by and be bound by the modified policy.

Contact Us

If you have any questions about this Privacy Policy, the practices of our Site, or your dealings with us, please contact us at:

EXI Investment Management LLC

info@exipartners.com.

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