Privacy Policy

Last Updated: June 23, 2022

RQR Capital, LLC ("RQR," "we," or "us") respects your privacy and is committed to protecting personal information. This Privacy Policy (the "Policy") explains our practices collecting information through our website located at https://www.rqrcapital.com (the "Website"), and describes how we collect, use, and share such information, and certain rights and options website visitors may have regarding their information. Use of our Website is also subject to our Terms and Conditions, which are available here https://www.rqrcapital.com/terms.

We reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.

By providing us with personal information or using our website, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use our website or provide us with your information.

Information We Receive

1. Personal Information

For the purposes of this Policy, "personal information" is any information that identifies, relates to, or can be used to contact a particular individual. The types of personal information we may collect through this Website can be grouped as follows:

• Contact information - First name, last name, email address (business or personal), position, name and mailing address of your organization, billing address, and telephone number (business or personal).
• Marketing information - Details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
• Communication information - Copies of communications and inquiries, including intake application questionnaire responses you have submitted to us, including through email, calls, and features available on our Website.
• Technical support information - Details about any issues you are experiencing that require technical support that you submit to us through our contact portals or provide in response to us following up on your request for assistance.
• Device and usage information - Details regarding how and when you use our Website, including the device used to connect to our Website, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our Website, and information about your interaction with our Website.

We collect this information when you visit or navigate our Website, fill in forms on our Website, apply for services via our Website, request information on our Website, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered "personal information."" We may also collect information about you from third-party sources and information about you that is publicly available.

2. Automatically Collected Usage and Device Information

Like most websites, our Website uses various technologies to automatically collect information about visitors. Those technologies include:

• Cookies. Cookies are small text files that a website transfers to a visitor's device for recordkeeping purposes. We use cookies to personalize visitors' experiences on our Website, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our Website traffic. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. Please note that if cookies are disabled, you may not be able to enjoy certain features of our Website.
• Log Files and Device Identifiers. We use log files to track actions occurring on the Website and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
• Web beacons and other technologies. Our Website may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users. Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
• Analytics. Our Website may also use third-party analytics tools, such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google's privacy policy here.

The information collected through these technologies may be combined with personal information or aggregated with other information from Website visits. We may share information about your use of our Website with our advertising and analytics partners, who may combine it with other information that you previously provided to them.

3. Information from Other Sources

We may obtain both personal and non-personal information about you from business partners, vendor partners, contractors, suppliers, and other third parties and add it to other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Website, with information obtained from other sources. This helps us improve the information's overall accuracy and completeness, and also helps us better tailor our interactions with you.

4. Social Media

If you interact with us on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (b) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from RQR and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.

How We Use Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

• Negotiating, entering into, and managing our relationship and agreements with you or your company, including providing our services and processing payments to or from you or your company.
• Providing and optimizing your experience on our Website and ensuring that our content is presented to you in the most effective manner.
• Responding to your inquiries and communicating with you, including regarding our services, our agreements with you or your company, and other issues.
• Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
• Managing customer service issues, including issues relating to the performance of our Website, technical concerns, and related feedback.
• Developing, updating, and improving our services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding potential investments or those who partner with us for our services.
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Website or the use of our services.
• Enforcing our agreements, complying with our legal or regulatory obligations, and defending or advancing legal claims.
• Notifying you about changes to our Website, services, or material changes to this Policy.
• Providing you with surveys or otherwise soliciting feedback from you.
• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see "Choices About the Collection and Use of Personal Information" below.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other announcements relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.

Disclosure of Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

In addition, we may share your information with the following types of entities:

• Business partners, service providers, investment partners, and third-party vendors necessary for the performance of any contract we enter into with you. For example, your information may be shared with our payment processing providers, accountants, outside counsel, consultants, or other providers of professional services.
• Service providers we use to facilitate our business operations and administration. These third parties have access to your personal information to perform specific tasks on our behalf. For example, our service providers include (i) IT and system administration providers, and (ii) data storage providers.
• Marketing and advertising vendors that may assist with lead generation, hosting information relating to investment partners and potential users of our services, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
• Analytics vendors in order to understand our Website traffic and usage patterns, optimize our Website, and identify potential new investors or users of our services.
• Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
• Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
• Other parties for any purpose we disclose at the time you provide the information.

Protection of Personal Information

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Your Choices About Personal Information

We respect your right to make choices about the ways we collect, use, and disclose your information. We try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following.

• Marketing Emails - As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the "opt out" link in any such promotional emails and following the instructions provided.
• Cookies - Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Website.
• Google Analytics - As discussed above, we use Google Analytics in connection with the Website. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use. You can find more information on how Google uses information it collects here.
• Declining to Provide Information - You can choose not to provide us with information we may request through our Website, but that may result in you being unable to use certain features of our Website, request information about our services, or initiate other transactions with us.
• Do Not Track Mechanisms - Please note that our Website does not honor "Do Not Track" signals, and such signals will not impact the operation of this Website.
• Jurisdiction-specific Choices - Choices relating to data transfers from the EU, UK, and Switzerland are described in the "Rights Under the GDPR" section below.

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Rights Under the GDPR (EU / UK Residents)

The European Union's General Data Protection Regulation and the United Kingdom's version of the same (collectively, the "GDPR") afford certain rights to individuals in the European Economic Area ("EEA"). If you are in the EEA or UK, you have the following rights. Note, however, that not all rights apply in all circumstances.

• Right of access: Subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you
• Right to rectify your personal information: If you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
• Right to be forgotten: You may ask us to delete information we hold about you in certain circumstances. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
• Right to restrict processing: In some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
• Right to object to processing: You may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
• Right to data portability: You have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.

With regard to the personal information we collect from users of our Website, we are typically the "data controller" for such information under the GDPR. As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to privacy@rqrcapital.com. This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond. Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months. Please note that we may need to request specific information from you to help us confirm your identity. If you are located in the EEA or UK and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA or UK.

1. Lawful Basis under GDPR

We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so. We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.

Purpose/Activity	Type of Information	Basis of Processing
To enter into and subsequently to manage our business relationship with you including: Negotiating, entering into, and performing agreements with your company Responding to inquiries and providing customer support and service Notifying you about changes to our website, business terms, or this Policy Communicating with you and responding to your inquiries regarding our services, agreements with your company, and other issues	Contact Information Communications Information	Necessary for our legitimate interests (to manage our business relationships and administer our operations including through the keeping of appropriate records) Performance of a contract with you Necessary to comply with legal obligations
To administer and protect our business and website including: Maintaining business records for legal purposes and to comply with tax requirements Defending and advancing legal claims Enforcing our rights under any agreements Ensuring effective security for our services and website Conducting website maintenance Identify and address security risks and unlawful activity	Contact Information Communications Information Device and Usage Information	Necessary for our legitimate interests (running our business, facilitating administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) Necessary to comply with legal obligations
To make decisions about how best to deliver relevant website content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing efforts	Marketing Information Communications Information Device and Usage Information	Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site)
To advance and promote our business interests including contacting you regarding services or promotions that may be of interest, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our services, customer service, and marketing efforts	Contact Information Marketing Information Device and Usage Information	Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business)

2. Transfers from the EEA, Switzerland, or UK

If we transfer personal information from the EEA, Switzerland, or UK to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR's requirements. For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor.

Rights Afforded to California Residents

California Civil Code § 1798.83 (California's Shine the Light Act) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

International Transfers

RQR is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located the United States. You understand and consent that information you provide may be transferred to the United States. You also understand that the data protection laws in the United States may be different from those of the country where you reside. When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.

Data Storage and Retention

RQR will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. At the end of the period, RQR will determine the appropriate retention period in accordance with our data retention policies. The criteria we use to determine the appropriate retention period includes consideration of the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.

Links to Third-Party Websites

Our Website may contain links to third-party websites. For example, our Website may link out to an article on a third-party news source or publisher website. Such websites have separate privacy policies that you should review. We do not control these third-party websites and are not responsible for the content of linked websites or those companies' data-handling practices.

Children's Privacy

Our Website is a general audience site and is not directed at, or intended for use by, children under the age of 16 years. Accordingly, we do not knowingly collect personal information from children under age 16. Should we discover that a child under the appropriate age provided their personal information, we will use that information only to respond to that child and inform them that we must have parental consent before receiving such information.

Changes to this Policy

Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the "Last Updated" date at the top of this document. Continued use of this Website after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.

How to Contact Us

For questions or more information about our privacy practices, please contact us by e-mail at privacy@rqrcapital.com