1. INFORMATION WE COLLECT

Information You Provide Directly

When you submit an application, contact us, or use our services, we may collect the following categories of

personal information:

• Identity Information: Full legal name, date of birth, government-issued ID information, Social Security Number (last 4 digits for identity verification), and entity name and EIN if applicable.

• Contact Information: Home address, mailing address, email address, and phone number.

• Transaction Information: Property address, purchase price, requested EMD amount, due diligence period, investment strategy, exit plan, and related deal documentation including unsigned purchase agreements.

• Financial Information: Payment method details used to pay application and EMD fees (processed securely through Stripe and/or bank wire). We do not store full credit card numbers.

• Communications: Emails, messages, call notes, and other correspondence you send to ORC.

Information Collected Automatically

When you visit the Site, we may automatically collect:

• Device and browser information (type, version, operating system);

• IP address and general geographic location;

• Pages visited, time on page, referring URL, and other usage data via Google Analytics 4;

• Session recordings and heat-map data via Microsoft Clarity (anonymized).

Cookies

We use cookies and similar tracking technologies to improve your experience on the Site. You may disable cookies in your browser settings; however, some features of the Site may not function properly without them. We use functional cookies (necessary for site operation) and analytics cookies (Google Analytics). We do not use advertising or retargeting cookies on the Site at this time.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• Application Processing: To review, evaluate, and process your EMD funding application.

• Identity Verification: To verify your identity and screen against OFAC sanctions lists as required by applicable law.

• Transaction Management: To manage funded deals, track due diligence deadlines, and communicate with our escrow partner.

• Communications: To send application confirmations, payment receipts, deal status updates, and deadline alerts.

• Legal Compliance: To comply with applicable laws, regulations, and judicial or governmental orders.

• Fraud Prevention: To detect and prevent fraud, misrepresentation, and unauthorized use of our services.

• Site Improvement: To analyze usage patterns and improve the Site's functionality and user experience.

• Record Keeping: To maintain records of funded transactions as required by applicable financial regulations (minimum 7 years for funded deal files).

3. HOW WE SHARE YOUR INFORMATION

We do not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your information in the following limited circumstances:

• Escrow Partner: We share deal-specific information with our designated title and escrow partner as necessary to place and manage the funded deposit. Our escrow partner is subject to confidentiality obligations.

• Capital Partner: We share limited deal information with our funding partner as necessary to process deal funding. Our funding partner is subject to confidentiality obligations.

• Payment Processors: Payment information is processed by Stripe and Bank of America, subject to their respective privacy policies.

• Legal and Compliance: We may disclose information to comply with applicable law, respond to legal process, enforce our agreements, or protect the rights and safety of ORC and others.

• Professional Advisers: We may share information with our attorneys, accountants, and other professional advisers under obligations of confidentiality.

• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of ORC's assets, your information may be transferred as part of that transaction. We will notify you of any such transfer.

4. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations. Specifically:

• Funded deal files (all documents and correspondence): minimum 7 years from deal close or exit date;

• Declined application files: minimum 3 years from date of decline;

• OFAC screening records: minimum 5 years;

• Wire records and payment records: minimum 7 years;

• Email correspondence: minimum 7 years (retained in Google Workspace Vault;

• Site analytics data: retained per Google Analytics and Microsoft Clarity default retention settings.

5. SECURITY

We implement commercially reasonable security measures to protect your personal information from unauthorized access, use, or disclosure. These measures include:

• Two-factor authentication enforced on all ORC email and system accounts;

• Encrypted transmission of data via HTTPS/SSL on the Site;

• Access controls limiting employee and contractor access to personal information on a need-to-know basis;

• Secure document handling via DocuSign for all executed legal documents;

• Payment processing through PCI-compliant processor (Stripe).

No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you as required by applicable law

6. YOUR RIGHTS & CHOICES

Depending on your state of residence, you may have certain rights regarding your personal information:

• Access: You may request a copy of the personal information we hold about you.

• Correction: You may request that we correct inaccurate or incomplete personal information.

• Deletion: You may request deletion of your personal information, subject to our retention obligations under applicable law and our loan servicing agreements.

• Opt-Out of Communications: You may opt out of marketing communications by following the unsubscribe instructions in any email or by contacting us directly. Note: transactional and deal-related communications are necessary for active funded transactions and cannot be opted out of while a deal is open.

To exercise any of these rights, contact us at: legal@offerreadycapital.com. We will respond to verifiable

requests within 30 days.

7. CALIFORNIA RESIDENTS

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information is collected, to delete personal information, and to opt out of the sale of personal information. ORC does not sell personal information. To exercise your CCPA/CPRA rights, contact us at legal@offerreadycapital.com.

8. CHILDREN'S PRIVACY

The Site is not directed to children under the age of 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a child under 18, we will delete that information promptly.

9. THIRD-PARTY ANALYTICS

We use Google Analytics 4 to collect and analyze information about Site usage. Google Analytics collects data such as pages visited, time on site, and device type using cookies. This data is processed by Google LLC in accordance with Google's privacy policy. You can opt out of Google Analytics by installing the Google Analytics Opt-Out Browser Add-On available at tools.google.com/dlpage/gaoptout.

We also use Microsoft Clarity for session recording and heatmap analytics. Clarity collects anonymized behavioral data and does not collect personally identifiable information. For more information, see Microsoft's privacy policy at privacy.microsoft.com.

10. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Site with a new effective date. Your continued use of the Site after any changes constitutes your acceptance of the updated policy.

11. CONTACT US

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

Offer Ready Capital, LLC

Attn: Privacy Officer

400 Renaissance Center, Suite 2600

Detroit, MI 48243

legal@offerreadycapital.com

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