Privacy Policy

PRIVACY POLICY

Fenix Holdings, LLC and our affiliate andsubsidiary companies (collectively, we, our, or us)are committed to privacy and to transparency in our information practices. Inthis Privacy Policy (the Policy), we describe how we may collect, use,disclose, and otherwise process personal information related to our websites(each, a Website) and mobile applications (each, an App) that display orlink to this Policy and our other services, products, and technology solutions(collectively, the Services).

Overview of Our Collection and Use of Personal Information
While the actual information we collect and ouruse of such personal information varies depending upon the nature of ourrelationship and interactions with an individual, the table below provides ageneral overview of the categories of personal information we collect and thepurposes for which we use such information. Where required by law, we obtainyour consent to collect certain categories of personal information. To learn more,please see the table in Section 15 below.

Categories ofpersonal information We Collect

Name, contact information and other identifiers: such as name, contact information, IP address and online identifiers,Social Security number and other government identifiers.

Customer records: paper andelectronic records containing personal information, including withoutlimitation, name, signature, photo, contact information, education andemployment history, Social Security number and other government identifiers,insurance policy number, financial or payment information, medical information,or health insurance information.

Protected classifications:characteristics of protected classifications under applicable state or federallaw, such as race, color, sex, age, religion, national origin, disability,citizenship status, and genetic information.

Commercial Information: includingrecords of real property, products or services purchased, obtained, orconsidered, or other purchasing or use histories or tendencies.

Biometric Information:  physiological, biological or behavioral characteristics that can be used alone or in combination with each other toestablish individual identity, including fingerprints (in accordance with applicable laws.

Usage data: internet or other electronic network activity Information including without limitation browsing history, search history, and informationregarding an individuals interaction with our Services or an advertisement.

Geolocationdata: precise location information about a particularindividual or device.

Audio, video,and other electronic data: such as, video footage, photographs, call recordings, and other audio,electronic, visual, or similar information.

Employmenthistory: professionalor employment-related information.

Educationinformation: educationinformation and records.

Profiles andinferences: inferencesdrawn from any of the above used to create a profile reflecting an individualspreferences, behaviors or other characteristics.

Individualrights. Please see YourRights and Choices in Section 10 below for a description of the choices weprovide and the rights you have regarding your personal information. If you are aCalifornia resident, please be sure to review Section 15 below titled AdditionalInformation for Residents in Certain Jurisdictions for important informationabout the categories of personal information we collect and disclose and yourrights under California privacy laws.

Use ofpersonal information

• Providing support and services
• Analyzing and improving our business
• Personalizing content and experiences
• Advertising, marketing, and promotional purposes
• Securing and protecting our business
• Defending our legal rights
• Auditing, reporting, corporate governance, and internal operations
• Complying with legal obligations

1. SCOPE OF OUR PRIVACY NOTICE

This privacy notice applies to our collection,use, disclosure, and other processing of personal information related to:

• the use of our Services that display or link to this Policy;
• former, current, and prospective clients, brokers, independent agents, and customers; and
• other individuals who use our Services, whose personal information we receive related to the Services, or who otherwise interact or communicate with us related to our Services

Our collection, use, disclosure, andprocessing of personal information about individuals will vary depending uponthe circumstances. This privacy notice is intended to describe our overallprivacy and data protection practices. In some cases, different or additional noticesabout our data collection and processing practices may be provided and apply toour processing of certain personal information

Personal information. In this privacy notice, our use of the termpersonal information includes other similar terms under applicable privacylawssuch as personal data and personally identifiable information. Ingeneral, personal information includes any information that identifies, relatesto, describes, or is reasonably capable of being associated, linked, orlinkable with a particular individual.

Not covered by this notice. This privacy notice does not apply to jobapplicants and candidates who apply for employment with us, or to our employeesand non-employee workers.

2. OUR COLLECTION OF PERSONAL INFORMATION

Generally, we collect your personalinformation on a voluntary basis. However, if you decline to provide certainpersonal information that is marked mandatory, you may not be able to accesscertain Services or we may be unable to fully respond to your inquiry.

Sources of personal information we collect. The personal information that we collect andprocess will vary depending upon the circumstances. We collect personalinformation directly from individuals, automatically related to the use of theServices, and in some cases, from third parties (such as social networks,platform providers, payment processors, data providers, and operators ofcertain third party services that we use). For example, some of the ways wecollect information are as follows:

Information we collect directly. We collect information that you provide to us,such as

• when you create an account, provide contact information, and send other personal information to us;
• when you complete or submit a form through our Services, for example, "Contact Us" or More Information forms;
• when you participate in surveys or contests, submit orders or requests, or register for or use our Services, or otherwise contact us;
• information you submit or provide such as real estate searches and preferences, whether you plan on buying or selling real estate, home search criteria, information about financing for the purchase of real estate, and other information related to the purchase or sale of real estate.

Information we collect from third parties. We may collect personal information about you and your propertyfrom third party sources, such as public databases, joint marketing partners,social media platforms (including from people with whom you are friends orotherwise connected), from brokers and independent agents of Fenix Holdings,LLC brands, and from other third parties. For example, without limitation:

• Social media. If you choose to link, create, or log in to your Services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the Services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.

• Real estate professionals. Information that may include, among other things, your name and email address, that you may have given to an independent real estate professional with whom you have a pre-existing relationship. The professional may collect such personal information from you with the sole purpose of pre-populating an account for the Services on your behalf and with your consent. You may choose not to finalize the creation of an account and may opt-out of certain future communications from us by following the instructions in the account creation notification or by contacting us at the email address in this Policy.

• Property records. We may collect information about individuals and real estate property through public databases, such as property ownership and tax records maintained by state, local and county agencies.

3. LEGAL BASES FOR OUR PROCESSING OF PERSONALINFORMATION

Certain laws, including the EU General DataProtection Regulation (GDPR), requires that we inform applicable individualsof the legal bases for our use and other processing of personal information.Pursuant to the GDPR (and other relevant laws), we process personal informationfor the following legal bases:

• Performance of contract: as necessary to enter into or carry out the performance of our contract with you.

• Compliance with laws: for compliance with legal obligations and/or defense against legal claims, including those in the area of labor and employment law, social security, and data protection, tax, and corporate compliance laws.

• Our legitimate interests: in furtherance of our legitimate business interests including:
• Performance of contracts with franchisees and other parties
• Implementation and operation of global support (e.g., IT) services for our business operations
• Customer relationship management and improving our Services, including marketing and analytics
• Fraud prevention, including misuse of company IT systems or money laundering
• Physical, IT, and network perimeter security
• Internal investigations
• Mergers, acquisitions, and reorganization, and other business transactions

• With your consent: where we have your consent (the GDPR (where it applies)) and other applicable laws give you the right to withdraw your consent, which you can do this at any time by contacting us using the details at the end of this privacy notice. In some jurisdictions, your use of the Services may be taken as implied consent to the collection and processing of personal information as outlined in this privacy notice.

In addition, we may process your personalinformation where necessary to protect the vital interests of any individual.

4. USE OF PERSONAL INFORMATION

While the purposes for which we may processpersonal information will vary depending upon the circumstances, in general weuse personal information for the purposes set forth below. Where GDPR or otherrelevant laws apply, we have set forth the legal bases for suchprocessing in parenthesis (see above for further explanationof our legal bases).

• Providing support and services: including, for example, to send or facilitate communications among you, independent real estate professionals and their affiliated entities, and other users of the Services, provide products and services you request (and send related information), operate our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your requests and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and our legitimate interests)

• Analyzing and improving our business: including to better understand how users access and use our Services, to evaluate and improve our Services and business operations, and to develop new features, offerings, and services; to conduct surveys, and other evaluations, such as customer satisfaction surveys; and for other research and analytical purposes. (Legal basis: our legitimate interests)

• Personalizing content and experiences: including to provide or recommend features, content, social connections, and referrals; tailor content we send or display on our Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. (Legal basis: our legitimate interests and/or with your consent)

• Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. (Legal basis: our legitimate interests and/or with your consent)

• Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct. (Legal basis: our legitimate interests and/or compliance with laws)

• Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. (Legal basis: our legitimate interests and/or compliance with laws)

• Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business. (Legal basis: our legitimate interests and/or compliance with laws)

• Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests. (Legal basis: our legitimate interests and/or compliance with laws)

Aggregate and de-identified information. We may de-identify personal information andcreate anonymous and aggregated data sets and reports in order to assess,improve and develop our business, products and services, prepare benchmarkingreports on our industry and for other research, marketing and analyticspurposes.

5. DISCLOSURE OF PERSONAL INFORMATION

We may disclose the personal information thatwe collect about you as set forth below or as otherwise described at the timeof collection or sharing.

• Service providers: We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, and customer service and support providers.
• Subsidiaries and Affiliates: We may share your personal information with our affiliated companies (i.e., companies under common ownership, control or management with us) - use will be subject to this privacy notice.
• Third Parties. We may disclose personal information to third parties in order to provide our Services, facilitate your requests, or with your acknowledgement and consent, including with:
• independent real estate professionals and owners and operators of real estate brokerage companies to enable them to provide services you request through the Services.
• third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us.
• the public if you submit to a public part of the Services, such as comments, social media posts, or other features viewable by the public or generally by registered users of the Services.
• third parties with whom you choose to let us share information, for example other apps or websites that integrate with the Services, or those with Services with which we integrate.
• third parties we work with to provide you with more personalized content and ads, and to track the effectiveness of campaigns.
• Business transfers: We may disclose or transfer personal information as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
• Legally required: We may disclose personal information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
• Protect our rights: We may disclose personal information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of us, our clients and customers or others.

Anonymized and Aggregated Data. We may share aggregate or de-identifiedinformation with third parties for research, marketing, advertising, analytics,and other purposes.

Cookies, Tracking, and Analytics

Our Services may use first party andthird-party cookies, pixel tags, plugins, and other tools to gather device,usage and browsing information when users visit our Services. For instance,when you visit our Services, our server may record your IP address (andassociated location information) and other information such as the type of yourinternet browser, your Media Access Control (MAC) address, computer type (Windowsor Macintosh), screen resolution, operating system name and version, devicemanufacturer and model, language, and the pages you view and links you selecton the Services, as well as date and time stamps associates with youractivities on our Services.

We use the information for security purposes,to facilitate navigation, to personalize and improve your experience whileusing the Services, to improve and measure our advertising campaigns and tobetter reach users with relevant advertising both on our Services and on thirdparty websites. We also gather statistical information about use of theServices in order to continually improve their design and functionality,understand how they are used and assist us with resolving questions regardingthem.

Cookies. Cookies are small text files that a website transfers toyour hard drive to store and sometimes collect information about your usage ofwebsites, such as time spent on the websites, pages visited, languagepreferences, and other anonymous traffic data. You can control the way in whichcookies are used by altering your browser settings. You may refuse to acceptcookies by activating the setting on your browser that allows you to rejectcookies. However, if you select such a setting, this may affect the functioningof our Services. Unless you have adjusted your browser setting so that it willrefuse cookies, our system will issue cookies when you access or log on to ourService.

Essential cookies are essential, as they enable you tomove around the Service and use its features. Without these cookies we couldnot, for example, authenticate your login or remember that you are logged-in asyou move through the Service.

Functionality cookies allow us to remember choices you make(such as the region you're in) and tailor the Service to provide enhancedfeatures and content for you. For instance, they can be used to remember yourlogin details or remember your nickname when you next login. They may also beused to provide services you've requested, for example leaving a comment on theService.

Analytics & performances cookies collect information about how theService is used, for example which pages users visit most often and if anyerror messages are displayed on certain pages. Information collected usingthese cookies is used to monitor activity on the Service and understand how itis being used.

If you have disabled one or more cookies, wemay still use information collected from cookies before your disabledpreference was set. However, we will stop using the disabled cookie to collectany further information.

To find out more about cookies, including howto see what cookies have been set and how to manage and delete them,visit www.aboutcookies.org or www.allaboutcookies.org.

Pixel tags and other similar technologies. Pixel tags (also known as web beaconsand clear GIFs) may be used in connection with some Websites to, among otherthings, track the actions of users of the Websites (including emailrecipients), measure the success of our marketing campaigns and compilestatistics about usage of the Websites and response rates. We and our serviceproviders may also use pixel tags in HTML emails to our customers, to help ustrack email response rates, identify when our emails are viewed, track whetherour emails are forwarded, and conduct analytics.

Log files. Most browsers collect certain information, such as your IPaddress, device type, screen resolution, operating system version and internetbrowser type and version. This information is gathered automatically and storedin log files.

Third party analytics tools. Our Websites use automated devices andapplications operated by third parties, such as Google Analytics, which uses cookiesand similar technologies to collect and analyze information about use of theWebsites and report on activities and trends. This service may also collectinformation regarding the use of other websites, apps and online resources. Youcan learn about Google's practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloadingthe Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track signals. Please note that our Websites do notrecognize or respond to any signal which your browser might transmit throughthe so-called 'Do Not Track' feature your browser might have. If you wish todisable cookies on our Websites, you should not rely on any 'Do Not Track'feature your browser might have. For more information about do-not-tracksignals, please click here.

Interest-based Advertising
On some of our Websites, we may work with third-party ad networks, analyticscompanies, measurement services and others (third-party ad companies) todisplay advertising on our Services and to manage our advertising on third-partysites, mobile apps and online services. We and these third-party ad companiesmay use cookies, pixels tags and other tools to collect information on ourWebsites (and on third-party sites and services), such as browsing history, IPaddress, device ID, cookie and advertising IDs, and other identifiers, generallocation information and, with your consent, your devices geolocationinformation; we and these third-party ad companies use this information toprovide you more relevant ads and content and to evaluate the success of suchads and content.

For more information or to opt out of thirdparty advertising cookies and tags on our Websites, go to www.privacyrights.info/.

You may also obtain more information abouttargeted or interest-based advertising and opt-out of many ad networks at theindustry websites below:

• Canada: www.youradchoices.ca
• EU: www.youronlinechoices.eu
• U.S.: www.aboutads.info

6. SOCIAL FEATURES AND THIRD PARTY PLUG INS

The Services may integrate with social sharingfeatures and other related tools which let you log in to the Services or shareactions you take on the Services. Your use of such features enables the sharingof information with your friends or the public, depending on the settings youestablish with the social sharing service. Please refer to the privacy policiesof those social sharing services for more information about how they handle thedata you provide to or share through them. We do not receive or store passwordsto your third-party social media accounts in this context.

7. INTERNATIONAL TRANSFERS OF PERSONALINFORMATION

The Services are hosted on servers located inthe United States. Note that some countries may not provide the same level ofdata protection as your home country. If you are located, for example, inEuropean Economic Area or Switzerland (collectively, EEA), your personalinformation will be transferred to the United States and possibly to otherjurisdictions (e.g., to the location of a property for which you have requestedinformation), which may not provide the same level of protection under yourlocal data protection laws. In such cases, we rely on suitable personalinformation transfer safeguards. You may have the right to request a copy orinformation about those safeguards by contacting us as detailed below.

8. SECURITY

We use technical, administrative, and physicalcontrols in place to help protect Personal information from unauthorizedaccess, use, and disclosure. Even so, despite our reasonable efforts, nosecurity measure is ever perfect or impenetrable. In the event that thesecurity of your account has been compromised, please immediately notify us inaccordance with Section 14 below (Contact Us).

9. DATA RETENTION

Generally, we will retain your personalinformation for the period necessary to fulfill the purposes outlined in thisprivacy notice or as set out in our contracts, unless a longer retention periodis required or permitted by law. We may also retain personal information forlonger where required by our legal and regulatory obligations, professionalindemnity obligations, or where we believe it is necessary to establish, defendor protect our legal rights and interests or those of others.

10. YOUR RIGHTS AND CHOICES

Marketing. You may opt out from receiving marketing-related communicationsfrom us on a going-forward basis by contacting us or by using the unsubscribemechanism contained in each email. We will try to comply with your request(s)as soon as reasonably practicable. Please note that if you opt out of receivingmarketing-related emails from us, we may still send you important administrativemessages, from which you cannot opt out.

Third party advertising and analytics. Our Websites include third party tags andcookies, which allow third parties to collect IP address and other identifier,browsing information and other personal information for advertising andanalytics purposes as explained above; to opt of these on ourWebsites, or for more information, go to www.privacyrights.info/. You may also review your browser or devicesettings for certain cookies and see above to exercise certain choicesregarding cookies.

Access, amendment and deletion. Under applicable privacy laws, you mayhave the right to request to review, make amendments, have deleted or otherwiseexercise your rights over your personal information that we hold, subject tocertain legal limitations and requirements. If you are subject to such aprivacy law, you may submit a request to us related to your personalinformation:

• By submitting a request to us at contact@fenixholdings.com
• By contacting us at (856) 988-8900

We follow applicable law to take steps to keepyour personal information accurate, complete and up-to-date. In your requestthat is covered by an applicable privacy law, please make clear what personalinformation you would like to have changed, whether you would like to have yourpersonal information suppressed from our database or otherwise let us know whatlimitations you would like to put on our use of your personal information. Wemay only implement requests (a) where required by applicable law and (b) withrespect to the personal information associated with the particular emailaddress that you use to send us your request, and we may need to verify youridentity before implementing your request. We will try to comply with yourrequest as soon as reasonably practicable.

As outlined below, if you are a Californiaresident or if you are in the European Union / European Economic Area, you mayhave additional rights.

Deactivation. You can deactivate your account at any timeby contacting us at the email address at the bottom of this page. However, youwill not be able to access many of the services to deactivate your account.Please note that even if you request deactivation of your account, it may takesome time to fulfill this request.

Responding to Requests. Please note that we may need to retain certaininformation for recordkeeping purposes and/or to complete any transactions thatyou began prior to requesting a change or deletion. There may also be residualinformation that will remain within our databases and other records, which willnot be removed. We may not always be able to fully address your request, forexample if it would impact the duty of confidentiality we owe to others, or ifwe are legally entitled to deal with the request in a different way.

Additional information for certainjurisdictions. We are committed torespecting the privacy rights of individuals under all privacy laws applicableto us. Some privacy laws require that we provide specific information aboutindividual rights to applicable consumers, which we have set forth at the endof this privacy notice:

• California: if you are a California resident, you may have certain rights, under California privacy laws, regarding your personal information as set forth in Section 15 below.

• EU/EEA: if you are in the European Union / European Economic Area, we provide further details about your rights under the GDPR in Section 15 below.

11. CHILDREN

The Services are not intended or directed tochildren under the age of 16, and we do not knowingly collect any personalinformation, or knowingly track the use of our Services, from children. If wehave actual knowledge that personal information about a child under 16 yearsold has been collected, then we will take appropriate steps to try and deletesuch personal information.

12. THIRD-PARTY WEBSITES

The Services may contain links to third-partyservices. We do not own, operate, or control the websites of third-parties,including those of independently owned and operated franchisees. Accordingly,this Policy does not apply to any services maintained or operated bythird-parties. When you click on those links, you will go to a third-partywebsite where you will be subject to that services privacy policy or similarstatement and terms of use, and we encourage you to read that policy statement.We are not responsible for the privacy practices of other services, and weexpressly disclaim any liability for their actions, including actions relatedto the use and disclosure of personal information by those third parties.

13. CHANGES TO THIS POLICY

We may amend this Policy at any time. If wemake any material change in how we collect, use, disclose, or otherwise processpersonal information, we will prominently post a notice regarding such changeon the Services. Any material changes to this Policy will be effective 10 daysafter our posting of the updated Policy or as otherwise required by applicablelaw. Where required to do so by law, we may seek your prior consent to any materialchanges we make to this Policy.

14. CONTACT US

If you have any questions or concerns aboutthis Policy, please use the following contact information:

Email: contact@fenixholdings.com
Mailing address: 11 Eves Dr. Suite 150, Marlton, NJ 08053  Attn: Fenix Holdings, LLC
Phone number: (856) 988-8900

15. ADDITIONAL INFORMATION FOR RESIDENTS INCERTAIN JURISDICTIONS

California Residents.

In this section, we provide information forCalifornia residents, as required under California privacy laws, including theCalifornia Consumer Privacy Act (CCPA), which requires that we provideCalifornia residents certain specific information about how we handle theirpersonal information, whether collected online or offline. This section doesnot address or apply to our handling of publicly available information madelawfully available by state or federal governments or other personalinformation that is subject to an exemption under the CCPA.

Categories of personal information that wecollect and disclose. Our collection, use and disclosure of personal information abouta California resident will vary depending upon the circumstances and nature ofour interactions or relationship with such resident. The table below sets outgenerally the categories of personal information (as defined by the CCPA) aboutCalifornia residents that we collect, sell, and disclose to others for abusiness purpose. We collect these categories of personal information from thesources described in the Information We Collect section above, and for thepurposes described in the Disclosure of Personal Information sectionabove.

Categories of Personal Information Sold. The CCPA defines a sale as disclosing ormaking available to a third-party personal information in exchange for monetaryor other valuable consideration. We do not disclose personal information to thirdparties in exchange for monetary or other valuable consideration.

Rights of California residents. California law grantsCalifornia residents certain rights and imposes restrictions on particularbusiness practices as set forth below.

• Do-Not-Sell: California residents have the right to opt-out of the sale of their personal information. Opt-out rights may be exercised by clicking on the Do Not Sell My Personal Information (or similar link) on a businesss Internet webpage. We do not disclose personal information to third parties in exchange for monetary or other valuable consideration.

• Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

• Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.

• Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:

• categories of personal information collected;
• categories of sources of personal information;
• business and/or commercial purposes for collecting and selling their personal information;
• categories of third parties/with whom we have disclosed or shared their personal information;
• categories of personal information that we have disclosed or shared with a third party for a business purpose;
• categories of personal information collected; and
• categories of third parties to whom the residents personal information has been sold and the specific categories of personal information sold to each category of third party.

California residents may make a Request toKnow up to twice every 12 months. We will respond to verifiable requestsreceived from California residents as required by law.

• Right to non-discrimination:The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents data.

• Financial incentives: A business may offer financial incentives for the collection, sale or deletion of California residents personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.

Submitting Requests. You may submit requests as follows:

• Submitting a request to us by email at contact@fenixholdings.com
• Contacting us by phone at (856) 988-8900

We will respond to verifiable requestsreceived from California residents as required by law. For more informationabout our privacy practices, contact us as set forth in the Contact Ussection above.

Rights Under California Shine the Lightlaw. California residentsmay request from businesses with whom they have an established businessrelationship (1) a list of categories of personal information, such as name,address, e-mail address, and the type of services provided to the customer,that a business has disclosed to third parties during the immediately precedingcalendar year for the third parties' direct marketing purposes and (2) thenames and addresses of all such third parties. To request the above informationplease contact us by writing to us under the Contact Us section above. Wewill respond to such requests within 30 days of receipt. We may change thisPolicy and will provide notice of changes through the Services or by email.Your continued use of the Services after notice constitutes your consent to thechange.

European Union / European Economic Area

Individuals in the European Union (EU) and theEuropean Economic Area (EEA) have the following rights, under the GDPR,regarding their personal information:

Right of access: You have the right to obtain from usconfirmation as to whether or not personal information concerning you is beingprocessed, and where that is the case, to request access to the personalinformation. The accessed information includes among others - the purposes ofthe processing, the categories of personal information concerned, and therecipients or categories of recipient to whom the personal information have beenor will be disclosed. You have the right to obtain a copy of the personalinformation undergoing processing. For further copies requested by you, we maycharge a reasonable fee based on administrative costs.

Right to rectify and complete personalinformation: you can request the rectification ofinaccurate data and the completion of incomplete data. We will inform relevantthird parties to whom we have transferred your data about the rectification andcompletion if we are legally obliged to do so.

Right to erasure (right to be forgotten): You have the right to obtain from us theerasure of personal information concerning you in limited circumstances where:

• it is no longer needed for the purposes for which it was collected; or
• you have withdrawn your consent (where the data processing was based on consent); or
• following a successful right to object; or
• it has been processed unlawfully; or
• the data has to be erased in order to comply with a legal obligation to which we are subject.

We are not required to comply with yourrequest to erase personal information if the processing of your personalinformation is necessary for:

• compliance with a legal obligation; or
• the establishment, exercise or defense of legal claims.

Right to restriction of processing: You have the right to obtain from usrestriction of processing your personal information. In this case, therespective data will be marked and only be processed by us for certainpurposes. This right can only be exercised where:

• the accuracy of your personal information is contested, to allow us verify its accuracy; or
• the processing is unlawful, but you do not want the personal information erased; or
• it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personalinformation following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

Right to data portability: You have the right to receive the personalinformation concerning you, which you have provided to us, in a structured,commonly used and machine-readable format and you have the right to transmitthose data to another entity without hindrance from us, but in each case onlywhere the processing is (a) based on your consent or on the performance of acontract with you, and (b) also carried out by automated means.

Right to object: You have the right to object at any time toany processing of your personal information which has our legitimate interestsas its legal basis. You may exercise this right without incurring any costs. Ifyou raise an objection, we have an opportunity to demonstrate that we havecompelling legitimate interests which override your rights and freedoms. Theright to object does not exist, in particular, if the processing of yourpersonal information is necessary to take steps prior to entering into acontract or to perform a contract already concluded.

Right to object to our useof yourpersonal information for direct marketing purposes: You can request that we change the manner inwhich we contact you for marketing purposes. You can request that we nottransfer your personal information to unaffiliated third parties for thepurposes of direct marketing or any other purposes.

Right to withdraw consent: if you have given us your consent for theprocessing of your personal information, you have the right to withdraw yourconsent at any time, without affecting the lawfulness of processing based onconsent before its withdrawal.

Right to obtain a copy of safeguards: you can ask to obtain a copy of, orreference to, the safeguards under which your personal information istransferred outside the EU/EEA. We may redact data transfer agreements toprotect commercial terms.

Right to lodge a complaint with your localsupervisory authority:You have a right to lodge a complaint with your local supervisory authority ifyou have concerns about how we are processing your personal information. We askthat you please attempt to resolve any issue with us first, although you have aright to contact your supervisory authority at any time.