This Privacy Policy explains how Exit 156 Capital LLC, a Delaware limited liability company and its subsidiaries and affiliates (“Exit 156,” “we” or “us”) collects, uses, and discloses information about you when you access or use our website and other online products and services (collectively, the “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services (like send a message through the Services), fill out an application, investor questionnaire, subscription agreement or another form, make an investment, apply for a job, communicate with us via third party social media sites (such as LinkedIn), request customer support, or otherwise communicate with us. The types of information we may collect when you access or use our Services as a non-investor include your contact information (name, email address, postal address, phone number) and educational information (post-secondary education level, postsecondary institution of attendance), as well as any other information you choose to provide. If you are an investor, we will collect the above-listed information in addition to other information including additional identifiers (your social security number), financial information (bank account and routing information, other payment information, wire transfer instructions, information in support of your accredited investor status, transaction history, other payment information, income sources, net worth, investment preferences), employment information (current and former employers, job titles, duration of employment), and any other information you choose to provide.

Other Information We Collect When You Use our Services

When you access or use our Services, transact business with us or engage with us at events, we automatically collect information about you, including:

• Usage Information: We collect information about your use of the Services as more fully described below.
• Transactional Information: When you make an investment, we collect information about the investment, such as fund details, investment vehicle, investment amount, and date of the investment.
• Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Location Information: We may derive the approximate location of your device from your IP address. In accordance with your device permissions, we may also collect information about the precise location of your device. You have the ability to stop the collection of precise location information at any time (see Your Choices below for details).
• Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us to: improve our Services and your experience, see which areas and features of our Services are popular, count visits, email you recommendations, and share data with advertisers, such as location, search history, YouTube history, and data from sites partnering with our service providers, so that the ads you see are more relevant to you. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices below.

Information We Collect from Other Sources

We may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers, publicly available sources, customer feedback, financial services providers, and marketing service providers. Additionally, if you create or log into your account through a social media site, such as LinkedIn, we will have access to certain information from that site, such as your name, account information, and friends lists, in accordance with the authorization procedures determined by such social media site.

Information We Derive

We may derive information or draw inferences about you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address, or your eligibility for certain types of private investment based on your personal and/or financial information.

Use of information

We use the information we collect for our everyday business and commercial purposes, such as to process your transactions, maintain your accounts, and provide you with tax-related information, and for our marketing purposes, such as to offer investment opportunities to you, notify you of events, and customize your experience with us. We also use the information we collect to:

• Comply with legal, regulatory, and audit requirements;
  • Facilitate payment processing and investment account management;
  • Provide, maintain and improve our products and services;
  • Send you notices, updates, alerts, and respond to inquiries;
  • Communicate with you about products, services, and events offered by Exit 156;
  • Monitor and analyze usage patterns;
  • Personalize your online experience;
  • Detect fraud and enhance security;
  • Conduct internal research and development;
  • Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We will not share data except in the following circumstances:

• With vendors, service providers, and consultants that perform services for us, including providers who assist us with operating and supporting the Services and with other investment processing functions, financial institutions, such as your bank to fund your investments, third-party custodians including third- party IRA custodians if you choose to invest through an IRA, and our analytics, marketing and consulting service providers assisting us with the preparation and circulation of our business and marketing communications and event planning;
• With our affiliates, such as subsequently-formed Exit 156 Capital-managed funds, that may use eligibility information about you to make marketing solicitations; if you do not wish to receive solicitations, please email us at info@exit156.com or call us at 605-961-2281 to opt out;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Exit 156 or others;
• With our attorneys, accountants, and/or auditors;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Exit 156 and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction.
• We may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, such as LinkedIn, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Exit 156 and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.

Transfer of Information to the U.S. and Other Countries

Exit 156 is based in the United States and we process and store information primarily in the U.S. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

Your Choices

Account Information

You may update and correct certain account information you provide to us at any time by logging into your account, emailing us at info@exit156.com or calling us at 605-961-2281. If you would like to delete or deactivate your account, please contact your assigned Exit 156 representative or email us at info@exit156.com. Once you no longer invest with us, please note we may retain certain information as required or permitted by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Promotional Communications

You may opt out of receiving promotional emails or text messages from Exit 156 Capital by following the instructions in those emails or text messages or by emailing us at info@exit156.com or calling us at 605-961-2281. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Your California Privacy Rights

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83). This section applies only to California residents.

California Consumer Privacy Act

Additional Disclosures Related to the Collection, Use, and Disclosure of Personal Information

Collection and Use of Personal Information: We do not sell personal information. In the preceding 12 months, we have collected the following categories of personal information: identifiers, characteristics of protected classifications under California or federal law, commercial information, Internet or other electronic network activity information, professional or employment-related information, education information and inferences drawn from any of the information collected. For examples of the precise data points we collect and the sources of such collection, please see “Collection of Information” above. We collect personal information for the business and commercial purposes described in “Use of Information” above.

Disclosure of Personal Information: We may share your personal information with third parties as described in the “Sharing of Information” section above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: social security number, name, date of birth, postal address, email address, telephone number, bank account number, account user name and password, and online identifier (such as LinkedIn profile details).

Your Consumer Rights

If you are a California resident, you have the right to request (1) more information about the categories and specific pieces of personal information we have collected and disclosed for a business purpose in the last 12 months and (2) deletion of your personal information. You may make these requests by contacting your assigned Exit 156 representative or emailing us at info@exit156.com. Please note we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. If you are an investor, we will verify your request by asking you to provide information related to your recent interactions with us, such as information regarding a recent investment. If you have not invested with Exit 156, we will verify your request by asking you to confirm the details of your chosen communication method (such as your email address). To designate an authorized agent to exercise these rights on your behalf, please contact us using the details identified in the “Contact Us” section below. We will not discriminate against you if you exercise your rights under the CCPA.

Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us by emailing us at info@exit156.com or calling us at 605-961-2281.