1. INFORMATION WE COLLECT

Information You Provide Directly

When you apply, 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 identification details, the last four digits of your Social Security Number for identity verification, and entity name and EIN where applicable.

▪   Contact Information. Home address, mailing address, email address, and phone number.

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

▪   Financial Information. The payment details you use to pay the Approval Fee and the Funding Fee. Payments are processed through Melio, or by bank transfer. ORC does not store full payment 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, including type, version, and 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, in anonymized form.

Cookies

We use cookies and similar technologies to improve your experience on the Site. You may disable cookies in your browser settings, although some features of the Site may not function properly without them. We use functional cookies, which are necessary for the Site to operate, and analytics cookies. We do not use advertising or retargeting cookies 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 underwrite your funding request.

▪   Entity Formation. To form and administer the special purpose limited liability company that funds your transaction, and to assign its membership interest to you if you exercise your option.

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

▪   Transaction Management. To manage funded transactions, track due diligence deadlines, and coordinate with our escrow partner.

▪   Communications. To send confirmations, payment receipts, 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.

▪   Record Keeping. To maintain records of funded transactions as required by applicable law.

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 and Title Partner. We share transaction specific information with our designated title and escrow partner as necessary to place, manage, and return the funded deposit. Our escrow partner is subject to confidentiality obligations.

▪   Capital Partner. We share limited transaction information with our funding partner as necessary to fund the deposit. Our funding partner is subject to confidentiality obligations.

▪   Registered Agent and State Filing Offices. We form a limited liability company for each funded transaction. To do so, we share the information required for formation with our registered agent and with the applicable state filing office. If you exercise your option and the membership interest is assigned to you, your name or your entity's name may appear in entity records, and certain entity records are matters of public record.

▪   Payment Processors. Payment information is processed by Melio and by our financial institution, 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 personal information for as long as necessary to fulfill the purposes for which it was collected, and to comply with our legal obligations. Specifically:

▪   Funded transaction files, including all documents and correspondence: minimum 7 years from close or exit.

▪   Declined application files: minimum 3 years from the date of decline.

▪   OFAC screening records: minimum 5 years.

▪   Wire and payment records: minimum 7 years.

▪   Email correspondence: minimum 7 years, retained in Google Workspace Vault.

▪   Site analytics data: retained in accordance with Google Analytics and Microsoft Clarity default retention settings.

5. SECURITY

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

▪   Two factor authentication enforced on all ORC email and system accounts.

▪   Encrypted transmission of data via HTTPS and 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 third party providers that maintain their own security and compliance programs.

No method of transmission over the internet, and no method of electronic storage, is completely secure. While we work 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 record retention obligations under applicable law and under the transaction documents governing any funded transaction.

▪   Opt Out of Marketing. You may opt out of marketing communications by following the unsubscribe instructions in any email, or by contacting us directly. Transactional and deal related communications are necessary while a transaction is open and cannot be opted out of during that period.

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 and the California Privacy Rights Act, including the right to know what personal information is collected, the right to delete personal information, and the right to opt out of the sale of personal information. ORC does not sell personal information. To exercise these 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 it 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 may opt out 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 heat map 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 change constitutes 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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