Lear Capital, LLC US Privacy Notice

LAST UPDATED: February 2025

Welcome to the Lear Capital, LLC website (www.learcapital.com, the "Website"). This Privacy Notice is designed to tell you about our practices regarding collection, use, and disclosure of information that you may provide via this Website and certain related services. Please be sure to read this entire Privacy Notice before using, or submitting information, to this Website.

1. Your Consent

This Privacy Notice sets forth the Website's current policies and practices with respect to nonpublic Personal Data of the users of the Website. By using this Website, you agree with the terms of this Privacy Notice. Whenever you submit information to Lear Capital via this Website, as well as over the phone, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Notice.

At Lear Capital, we put the needs of our customers first. The information gathered from you on our Website includes Personal Data such as your name, phone number(s), and email address, is stored in our in-house database and is used to contact you in response to your inquiries. Any information shared electronically with us is subject to this Privacy Notice.

PLEASE READ THE FOLLOWING PRIVACY NOTICE CAREFULLY BEFORE USING THE WEBSITE. BY USING THIS WEBSITE, YOU SIGNIFY YOUR ASSENT TO THIS PRIVACY NOTICE. IF YOU DO NOT ASSENT TO THIS PRIVACY NOTICE, PLEASE DO NOT USE THIS WEBSITE.

2. Scope of this Privacy Notice

We follow this Privacy Notice in accordance with the applicable law of the United States and those of its states in which we operate. We do not operate in countries other than the United States and we do not knowingly offer or provide our services to residents of countries other than those of the United States.

For the purposes of this Privacy Notice, "Personal Data" means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:

• Publicly available information;
• Deidentified or aggregated data; or
• Information otherwise excluded under the applicable laws (US Privacy Laws).

This Privacy Notice provides the following information to US residents:

• Categories of Personal Data we collect;
• Purposes for which we use Personal Data;
• Categories of Personal Data we disclose to third parties;
• Categories of third parties to which we disclose Personal Data; and
• How US residents can exercise their rights under US Privacy Laws.

3. Categories of Personal Data

We collect Personal Data from you through our Website and over the phone in order to provide you with more information about our services and to manage our relationship with you. You will voluntarily provide most of this information directly to us. We also use cookies, pixels, and tags on our Website and certain marketing emails, which collect your IP address and certain other information from you when you visit our Website, including when you visit our Website via a link on another website. We also collect information using analytics tools, including when you visit our Website.

Please know that we do not knowingly collect Personal Data from anyone under 13 years of age. Our Website, products and services are all directed to people who are at least 18 years old or older. We do not draw inferences from your Personal Data to build your consumer profile.

We obtain the categories of Personal Data listed below from the following categories of sources:

• Directly from you. For example, when you provide us with some information through the Website or call us, we collect certain information from you, including your name, billing address, payment information (including credit card numbers, email address, and phone number.)
• Indirectly from you. When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, your video viewing history on the Website, what websites or search terms referred you to the Site, and information about how you interact with the Website.

We collect this automatically collected information ("Usage Information") using the following technologies:

• "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• "Web beacons", "tags", and "pixels" are electronic files used to record information about how you browse the Website.

For more information on the automatically collected information please see Section 7 (Cookie and Similar Technology Policy).

The table below outlines the categories of Personal Data we collect about US residents and whether and how they are disclosed to third parties.

When we refer to sale or sharing in this Privacy Notice we mean exchanging Personal Data with a third party for money or anything of value, and "sharing" means disclosing Personal Data to a third party for use in conducting "cross-context behavioral advertising," also referred to as "targeted advertising." For more information please see Section 10 (Notice of Right to Opt-Out of Sale/Sharing for Targeted Advertising).

4. Categories of Sensitive Personal Data

Through the IRA application, we may collect your passport, ID card or Social Security Number. We collect this information as required by law for Anti-Money Laundering (AML) transactions to file a form 8300 with the IRS. We do not use your Sensitive Personal Data for any other purposes.

5. Use of Personal Data

We use Personal Data for the purposes described above. Consistent with applicable law and choices and controls that may be available to you, we may use your Personal Data to:

• Provide you with information about the products and services that you request or view. For example, by sending you the free information guide or marketing emails you have asked to receive;
• Communicate with you about the products and services we offer, including responding to your emails, phone calls, and other inquiries;
• Operate, understand, optimize, develop, or improve our Website, products, services, and operations;
• Provide you with tailored content, services, advertisements and offers from our brands;
• Verifying your identity on the Website and to process your purchases and other transactions;
• Screen our orders for potential risk or fraud;
• Fulfill product purchases;
• Send notice of changes to our policies;
• Improve our customer service and product offerings;
• Conduct research and analytics related to our operations;
• Protect our legal rights and interests;

and

• Comply with any obligations, laws, regulations, or rules to which we are subject, including by cooperating with regulators and other public authorities, such as by responding to any requests for information or complying with our reporting and other legal obligations.

Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.

6. Disclosing Personal Data

We share Personal Data with the following categories of third parties:

• Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes.
• Our Analytics and Advertising Partners: We use analytics services to collect and process certain data and to provide you with relevant advertising. These services may also collect information about your use of certain other websites, apps, and online resources.

See the table above for more details about how different categories of Personal Data are disclosed.

We may share your Personal Data with trusted third parties who assist us in operating our Website, conducting our business, or providing services to you on our behalf, such as sending you marketing emails. In sharing Personal Data with these third-party vendors, we require that they keep your Personal Data confidential and are prohibited from using your Personal Data for purposes other than those related to the services for which we are using them.

Otherwise, we may share your Personal Data to enforce our Online Purchase Agreement, to protect the rights, property, and safety of ourselves and others, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law. Examples include responding to a subpoena or similar legal process, protecting against fraud, and cooperating with law enforcement or regulatory authorities.

7. Cookie and Similar Technology Policy

We may also use various methods and technologies to store or collect Usage Information ("Tracking Technologies"). Tracking Technologies may set, change, alter and/or modify settings or configurations on your device.

Cookies. A cookie is a file placed on a device to uniquely identify your browser or to store information on your Device. Our Sites may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage. We use cookies (small text files placed on the hard drive of your computer or device) and similar technologies (e.g., flash cookies and web beacons) on our Website and marketing emails to:

• Make sure our Website functions as it should;
• Recognize you when you return to the Website;
• Understand how you arrived at and used our Website;
• Present you with customized options relating to your interests, based on your previous use of the Website; and
• Aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Please note that some of the cookies on our Website are third party cookies (e.g. Google advertising cookies) which we do not control. In that instance, please view the relevant third party's website for details of their privacy policy.

Use of some cookies like, for instance, Meta Pixel may lead to the disclosure of your video viewing history if you watch any videos on our Website.

You agree to the disclosure of your Personal Data and Usage Information through such third party cookies and other Tracking Technologies when you accept cookies on our Website.

Please also note that most web browsers (Chrome, Safari, Firefox, etc.) give you the option to receive a warning each time a cookie is being placed on your device or to block most cookies. You can do this through your browser settings or use your browser's Help menu to learn how to do this.

For more information about cookies and how to disable and/or delete them, please visit www.allaboutcookies.org. If you would like to opt-out of non-essential cookies, please manage your cookie preferences. Please note that the strictly necessary cookies cannot be disabled.

• Web Beacons. A web beacon is a small tag (which may be invisible to you) that may be placed on our Website's pages and messages.
• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Website, such as the links you click on.
• ETag, or entity tag. An ETag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
• Browser Fingerprinting. Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
• Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We may use Tracking Technologies for a variety of purposes, including: (i) to allow you to use and access the Website including for the prevention of fraudulent activity and improved security functionality; (ii) to assess the performance of the Website, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Website; (iii) to offer you enhanced functionality when accessing the Website, including identifying you when you sign into our Website, keeping track of your specified preferences and/or to track your online activities over time and across third-party sites; and (iv) to deliver content relevant to your interests on our Website and third party sites based on how you interact with our content.

You may opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

8. Email Marketing

Opting Out of Marketing Communications. You can opt-out of receiving marketing communications from us by going to CustomerSupport@learcapital.com and providing the names/email address that you would like removed from our marketing databases and added to our "Do Not Contact list" or by following the unsubscribe instructions included in our marketing communications.

You can also stop receiving promotional e-mails at any time by clicking on the "unsubscribe" link at the bottom of any promotional e-mail that you receive from us.

Restricting Online Data Collection. You can restrict how cookies are used to track and log data about your visits to our Websites. Note that if you restrict the use of cookies some of the features on our Websites may not be fully functional. We use Google Analytics and/or other third-party data analytics services to place the cookies, track Website usage data, and provide reports to us. We do not disclose any directly identifying Personal Data to a third-party data analytics service. However, the service may monitor a user's visits to the Website and combine this data with data from other websites monitored by the same service provider and then use the aggregated findings for its own commercial purposes. The service provider may have means of correlating data from our Website to an identifiable individual, in which case the processing of Personal Data will be the responsibility of the service provider.

By using the Website you consent to the processing of your Personal Data by both us and our analytics services providers, including Google Analytics. You can restrict how cookies and other internet technologies are used to track and log data about your computer and mobile device usage of our Website by managing the preference settings on your browser or device.

9. Exercising Your Personal Data Rights

You have certain rights in relation to your Personal Data. Under certain circumstances, and subject to legal conditions, you may have the following rights:

• Right to Know. You may request that we disclose to you the categories of Personal Data we collect about you, the categories of sources from which we collected that Personal Data, the categories of Personal Data we sold or disclosed, our business or commercial purposes for collecting and selling such Personal Data, the categories of third parties with whom we shared such personal information, and the specific pieces of Personal Data we collected about you over the past 12 months.
• Right to Access. You have the right to confirm whether or not we are processing your Personal Data and access such personal information. Please note that this right might be subject to certain limitations.
• Right to Data Portability. You can request to obtain a portable copy of your Personal Data.
• Right to Request Deletion of Your Personal Data. You may request we delete some or all of the Personal Data we maintain about you, subject to certain exceptions.
• Opt-out of "Sale"/ "Sharing" of Your Personal Data. We do not currently consider the ways we shared consumer Personal Data in the past 12 months to comprise the "sale" of personal information. For purposes of this Privacy Notice, "sell" means the sale of your Personal Data to an outside party for monetary or other valuable consideration, subject to certain exceptions in applicable privacy laws. However use of some tracking and analytics technologies may be under some circumstances considered sale of data, to this end we provide a path for you to exercise you right to opt-out. Please see Section 10 (Notice of Right to Opt-Out of Sale/Sharing for Targeted Advertising).
• Right to Correct Inaccurate Personal Data. Taking into account the nature of the Personal Data and the purposes of the processing, this right provides an individual with the ability to seek to correct or update Personal Data that individual considers that we hold about that individual.
• Right to Limit Use of Sensitive Personal Data. This right is limited to Sensitive Personal Data used for the purpose of inferring characteristics about an individual. We do not collect Sensitive Personal Data nor do we use Sensitive Personal Data for the purpose of inferring characteristics about an individual, therefore we do not offer a path to exercise this right.
• Right of Non-Discrimination and Non Retaliation. You not to be subject to any discrimination or subject to retaliation for exercising any of these rights. We will not deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights.
• Shine the Light. California Civil Code Section 1798.83, also known as the "Shine the Light" law, permits California residents to annually request, free of charge, information about the Personal Data (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. To make a request, please contact us at CustomerSupport@learcapital.com.
• Right to opt out of the processing of your Personal Data for the purposes of targeted advertising and for profiling in furtherance of decisions, including, solely automated decisions that produce legal or similarly significant effects.

When We Do Not Act on a Request — Appeal Process. In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested. Additionally, you have the right to appeal our decision.

To exercise any of these rights, please contact us by email at CustomerSupport@learcapital.com, calling our toll free number at www.LearCapital.com (800-576-9355), or by filling out the form available at https://www.learcapital.com/privacy-request/

Please put "Request Regarding Personal Data" in the Subject line of the email or at the beginning of your message if you submit a form online.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.

Your request must:

• Provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative of such person; and
• Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.

To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify identity by confirming other relevant personal information. We may ask you for additional information as part of this process, including the last 4 digits of your telephone number. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. Please be aware that we do not accept or process rights requests submitted through other means.

We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.

We reserve the right to decline to process, or charge a reasonable fee for, requests from a US resident that are manifestly unfounded, excessive, or repetitive.

10. Notice of Right to Opt-Out of Sale/Sharing for Targeted Advertising

US Privacy Laws give US residents the right to direct a business that "sells" or "shares" their Personal Data to stop selling and/or sharing their Personal Data at any time. As used here, "selling" means exchanging Personal Data with a third party for money or anything of value, and "sharing" means disclosing Personal Data to a third party for use in conducting "cross-context behavioral advertising," also referred to as "targeted advertising." An example of targeted advertising is displaying advertisements to a person where the advertisement is selected based on Personal Data obtained from their activities over time and across non-affiliated websites or applications to predict their preferences or interests. In certain situations and as detailed above, we share for targeted advertising Personal Data with third parties. You (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

"Do Not Sell or Share My Personal Information"

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by following the same link.

11. Notice of Right to Limit the Use of Sensitive Personal Information

You have the right to limit some uses of Sensitive Personal Data. In particular, you may direct companies not to use Sensitive Personal Data except as necessary to provide goods or services you have requested or other exempt purposes.

12. Testimonials

We may display personal testimonials on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your name and city/state of residence. If you wish to update or delete your testimonial, you can contact us at CustomerSupport@learcapital.com

Opt-Out Preference Signal

We currently do not respond to "Do not Track" signals in browsers. You may opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

13. Children's Data

We do not knowingly collect or use the Personal Data of children under 13. If you believe that we have collected the Personal Data of a child under 13, please contact us at CustomerSupport@learcapital.com.

14. Authorized Agent Requests

You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above in the section titled Exercising Your Personal Data Rights. We may require verification of your authorized agent's authority in addition to the information we require for verification of your identity. If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected Personal Data and that you are authorized to submit the request on their behalf. For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Privacy Notice, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

15. Changes to this Privacy Notice

This Privacy Notice describes the types of information we currently collect, and the ways we use and protect that information. From time to time, we may collect different types of information and use that information in different ways. In these cases, we may edit this policy to explain the new practices. Because protecting your privacy is very important to us, we do not expect major changes in policy. However, if we do make significant changes in our practices, we will include announcements on the Website home page so that you will know to review the revised policy.

16. Contact Us

If you have any questions or concerns regarding this Detailed US Privacy Notice, contact us at CustomerSupport@learcapital.com or calling our toll free number at www.LearCapital.com (844.203.9739).

PLEASE PRINT AND RETAIN A COPY OF THIS PRIVACY NOTICE FOR YOUR RECORDS.