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Privacy Policy

Specialty Capital, LLC understands the importance of your personal privacy. Therefore, we have created this Privacy Policy so that you know how we use and disclose your information when you make it available to us. The Privacy Policy below discloses our practices regarding information collection and usage of our website located at specialtycapital.com, the related mobile website, and the mobile application (collectively, the “websites”) and the service provided thereon (the “service”).

By using or accessing the websites and the service, you signify your agreement to be bound by this Privacy Policy.

Information We Collect and How We Collect It personal information about you from the following sources: – Information we receive from you on your client agreements, account opening forms, subscription agreements, or other forms. This information includes, but not limited to: your name(s), demographic information, address(es), email address(es), other contact information, social security number and/or other government issued identifiers, professional, educational, or employment-related information transactions, assets and income, and other financial information. – Information we collect based on your use of our website and services; this information may include but not limited to: how you use or visit our website, how you use our services and products, how you interact with us, Cookie and tracking information such as IP address, device identifier, geolocation data, browser type and language, access times, other unique identifiers and other technical data that may uniquely identify your device, system or browser, and browse history information about the websites you visit.

224 W 35th Street, Suite 500 Unit 583, New York, NY 10001 - info@specialtycapital.com

– Information we receive from third party sources and our business partners. This information includes but not limited to: credit history, credit scores and credit references to investigate your credit in connection with your application with us.

How We Use Your Information We use information that we collect about you or that you provide us, to present the website and its contents to you, to provide you with our services and for the following purposes: – Verify your identity. – Process your credit or financing request in connection with our services. – Deliver and maintain our information, products, and services. – Process your application and transactions, including the investigation of your credit in connection with any application filled with us. – Measure credit and payment risk. – Contact you regarding matters you requested to discuss, or any matter that might require your attention. – Maintain regular communications with you as may be necessary to fulfil our obligations to you or to execute requested transactions.

– Help us improve and personalize our products and/or services. – In any other way we may describe when you provide the information, and for any other purpose with your express consent. – To comply with applicable laws. – To help improve the safety of our website, products, and services, including preventing any fraud that might harm you or Specialty Capital. – Meet our legal obligations.

Sharing Your Information – We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

224 W 35th Street, Suite 500 Unit 583, New York, NY 10001 - info@specialtycapital.com

– We may share your information with providers of hosting services for the Site, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, funds transfer, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, custody, or escrow services and more. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services. Our partners are legally required to keep your information private and secure. – We may share your information with law enforcement or other government agencies as required by law or for the purpose(s) of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the site or our services, or to protect the rights, property or personal safety of Specialty Capital, its users, issuers, or others. – We may also share your information with 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 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 website users is among the assets transferred. Should this situation arise, we will notify you in advance and give you a chance to continue or close your account.

Cookies When visiting the website, Specialty Capital may collect data collectively known as cookies to ensure a more user-friendly web experience. This data allows (a) the user to avoid having to re-enter information and to aid in navigation between pages of the service; (b) the service to remember what kinds of information you have shown interest

224 W 35th Street, Suite 500 Unit 583, New York, NY 10001 - info@specialtycapital.com

in while on the service; and (c) the service to obtain analytical data on guest navigation behavior for evaluation purposes. No personal information is stored in the cookies. You have the option of disabling cookies by changing your browser settings, but the service functionality and ease of use may be compromised as a result.

Google Analytics. We may use third party services such as Google Analytics that collect, monitor and analyze information such as Internet Protocol (“IP”) address, browser type, browser version, the pages visited, the time and date of use, the time spent on pages and other statistics order to increase the website's functionality. This may also include Google's User-ID feature, which assigns to you a unique, persistent, and non-personally identifiable ID to help us recognize you across sessions and devices. While you cannot opt out of such collection you have the choice to close your account. Google also has its own policies addressing how they use such information and how you may opt out.

Security The security of your personally identifiable information is very important to us. When we collect your personally identifiable information online, we use reasonable efforts to protect it from unauthorized access. However, due to the inherent open nature of the internet, we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties such as hackers. By using our service, you acknowledge assumption of risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personally identifiable information.

Links to other sites

224 W 35th Street, Suite 500 Unit 583, New York, NY 10001 - info@specialtycapital.com

As a convenience to you, we may provide links to third-party services from within our website. We are not responsible for the privacy practices or content of these third-party sites. When you link away from our service, you do so at your own risk.

Changes to this Privacy Policy This privacy policy may be revised at our own sole discretion at any time, without prior notice. You are responsible to review the privacy policy periodically. Your continued access and/or use of the website and/ or our services following any change constitutes your agreement to any such changes.

Dispute Resolution This privacy policy is governed by and shall be construed in accordance with the laws of New York, U.S.A., without reference to its conflict-of-law provisions. You agree to submit to the personal and exclusive jurisdiction in Delaware, U.S.A. for any disputes with Specialty Capital arising out of this privacy policy. You agree that if a dispute arises, parties will attempt to resolve the dispute with mediation in Delaware, U.S.A. or an online mediation service that is mutually agreed upon by all parties. The parties agree that their good faith participation in mediation is a condition precedent to pursuing other legal remedies. The successful party to any dispute resolution will be entitled to reasonable costs and fees incurred in resolving or settling the dispute, in addition to any other relief to which the party may be entitled.

California Privacy Rights Act (CPRA) Compliance Statement

Specialty Capital values your privacy and is committed to protecting your personal information. Although we are not subject to the California Privacy Rights Act (CPRA) as we do not derive fifty percent or more of our annual revenue from selling or sharing consumers' personal information, we respect your rights and strive to provide transparency and control over your data.

224 W 35th Street, Suite 500 Unit 583, New York, NY 10001 - info@specialtycapital.com

As a user or visitor of our platform and services, you may have certain rights under the CPRA, such as the right to:

1. Know what personal information is collected and how it is used. 2. Opt-out of the sale or sharing of your personal information, if applicable. 3. Request access to or deletion of your personal information. 4. Correct or update your personal information.

Please note that although we are not obligated by law to comply with the CPRA, we are committed to providing you with the same level of privacy protection and rights. We have implemented reasonable security measures to safeguard your personal information and maintain its confidentiality.

If you have any questions or wish to exercise your rights under the CPRA or any other applicable privacy laws, please contact us using the information provided at the end of this privacy policy.

Please be aware that this privacy policy applies solely to our platform and services and does not extend to any third-party websites or services linked to or from our platform. We encourage you to review the privacy policies of those third parties for their respective practices.

By using our services, you acknowledge that you have read and understood the provisions of this privacy policy, including the CPRA compliance statement.

If you have any questions about our privacy policy, please feel free to contact us.

224 W 35th Street, Suite 500 Unit 583, New York, NY 10001 - info@specialtycapital.com

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