Lear Capital, LLC Detailed US Privacy Notice

LAST UPDATED: November 2023

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 Policy before using, or submitting information, to this Website.

Your Consent

This Privacy Notice sets forth the Website's current policies and practices with respect to nonpublic personal information of the users of the Website. By using this Website, you agree with the terms of this Privacy Notice. Whenever you submit information via this Website, 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 information 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 POLICY (OTHERWISE NOTED AS THIS “AGREEMENT”) CAREFULLY BEFORE USING THE WEBSITE BY USING THIS WEBSITE, YOU SIGNIFY YOUR ASSENT TO THIS AGREEMENT. IF YOU DO NOT ASSENT TO THIS AGREEMENT, PLEASE DO NOT USE THIS WEBSITE.

At Lear Capital, we share your concerns about privacy. We have created this privacy statement in order to demonstrate our firm commitment. The following discloses our information gathering and dissemination practices for all our Website web pages.

Information for US Residents

We collect Personal Data from US residents and comply with the consumer privacy laws of California, Colorado, Connecticut, Utah, and Virginia (“US Privacy Laws”). This Detailed US Privacy Notice applies to US residents (“users,” “you,” or “your”).

For the purposes of this Detailed US 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 from the scope of 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:
• The rights to access, correct, or delete Personal Data;
• The right to obtain a portable copy of Personal Data;
• The right to limit the use of sensitive Personal Data in certain circumstances;
• The rights to opt out of targeted advertising, sales of Personal Data, or profiling; and
• The right to appeal our decisions about your requests.

Categories of Non-Sensitive Personal Data

The table below outlines the non-sensitive categories of Personal Data Lear Capital, LLC collects about US residents and whether and how they are disclosed to third parties.

We collect Non-Sensitive Personal Data from the following sources:

• Directly from our users

Categories of Sensitive Personal Data

We do not Process any categories of Sensitive Personal Data.

Use of Personal Data

We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.

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 do not sell Personal Data to anyone.

Exercising Your Personal Data Rights

US residents have the following rights under US Privacy Laws:

• The rights to access, correct, or delete Personal Data;
• The right to obtain a portable copy of Personal Data;
• The right to limit the use of Sensitive Personal Data in certain circumstances;
• The rights to opt out of targeted advertising, sales of personal data, or profiling;
• The right not to receive discriminatory treatment for exercising your privacy rights; and
• The right to appeal our decisions about your requests if you disagree with them.

If you are a US resident, you can submit a request to exercise your personal data rights under US Privacy Laws by Sending us an e-mail stating your request to CustomerSupport@learcapital.com or calling our toll free number at www.LearCapital.com (800.576.9355).

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.

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 Information to stop selling and/or sharing their Personal Information 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 can opt out of the sharing of your Personal Data by Sending us an e-mail stating your request to CustomerSupport@learcapital.com or calling our toll free number at www.LearCapital.com (800.576.9355).

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. However, Lear Capital, LLC does not Process any Sensitive Data.

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

Children’s Data

We do not knowingly collect or use the Personal Information of children under 16. If you believe that we have collected the Personal Information of a child under 16, please contact us at CustomerSupport@learcapital.com.

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.

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.

Contact Us

If you have any questions or concerns regarding this Detailed US Privacy Notice, contact us at

CustomerSupport@learcapital.com

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