PRIVACY POLICY

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Last updated: February 7th, 2025

We at L40 Partners, Inc. (referred to as "us", "our", or "we") respect your privacy and are committed to providing clarity regarding the collection, use, and disclosure of your Personal Information ("Personal Information") acquired through your use of our websites that link to this Privacy Policy, including www.L40.com (each, a "Website" and collectively, the "Websites").

This Privacy Policy outlines the types of information we may collect from you or that you may provide when you visit our Website and details our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy applies only to Personal Information collected on or through the Websites. It does not apply to information collected by (a) us, or on our behalf, through other means such as in person, by mail, or by telephone, or (b) any third party, including through applications or content (including advertisements) that may link to or be accessible from the Website.

If you are an L40 client, we may also provide you with a separate privacy notice that outlines how we use your Personal Information, which will also apply.

This Privacy Policy may change periodically. If we make material changes to how we handle Personal Information, we will notify you through a notice on the Website and/or by sending an email to the most recent email address you provided. Changes to this Privacy Policy will become effective thirty (30) calendar days after such notice is issued or posted on the Website. We encourage you to periodically review the Website to stay informed about how we are protecting and using your Personal Information. Changes will apply immediately for new users of the Website. If you do not agree with the changes, you must notify us prior to the effective date and cease further use of the Website. Your continued use of the Website following notice of such changes indicates your acknowledgment and acceptance of those changes. The date this Privacy Policy was last updated is listed at the top of this page.

By submitting your Personal Information to us, you acknowledge and consent to the processing outlined in this Privacy Policy. We may also provide additional notices highlighting specific uses of your Personal Information, with options to opt in or out of selected uses, at the time we collect such information from you.

This Privacy Policy covers the following areas:

Information We Collect About You and How We Collect It

We may collect and process the following Personal Information about you when you visit the Website. Our web servers use certain technologies to automatically collect the details of your visit, including but not limited to your operating system, browser type and language, internet domain and host names, IP address, the pages you request on the Website, the dates and times that the Website is accessed, how long you spend on each page, and the details of the website you linked from to the Website. For further information, please see the section under the heading “Cookies” below.

We collect the information you voluntarily provide to us when you contact us. For example, the Website may enable you to submit requests for certain information. If you voluntarily submit information through the Website, we may record any Personal Information you provide, including but not limited to your name, title, address, phone number, email address, and company information such as name, type, and description.

Additionally, we may have certain legal and regulatory responsibilities to verify the identity of clients and may need to obtain specific information from you for that purpose. You confirm that all information you supply will be accurate and that we may disclose such information as necessary to comply with legal and regulatory requirements (as described under the heading “Disclosure of Personal Information” below).

Use of Personal Information, Including Marketing

In general, the Personal Information we collect from you is used:

• To monitor, improve, and administer the Website and the information and services provided on the Website, or for our internal business purposes;
• To fulfill your requests for information, products, or services;
• To communicate with you; and
• To enable us to comply with our legal and regulatory obligations and related internal business procedures.

We may also use Personal Information to market our own and selected third-party products and services to you by post, email, SMS, phone, or other means. This includes sending newsletters, announcements, and invitations we believe may be of interest to you.

You may opt out of marketing communications by following the unsubscribe instructions provided in the email you receive or by contacting us directly at info@l40.com. Please note that, despite your indicated email preferences, we may still send you service-related communications, including notices about updates to our Terms of Use, Cookies Policy, or Privacy Policy.

Our use of Personal Information is compliant with applicable laws and may be based on the following grounds:

• Your consent;
• The need to perform our contractual obligations with you;
• Our legal and regulatory obligations;
• The necessity to establish, exercise, or defend our legal rights; or
• Our legitimate business interests, such as managing our business operations effectively and maintaining compliance with internal policies.

Security and Export of Personal Information

We have implemented measures to secure Personal Information from accidental loss, unauthorized access, use, alteration, and disclosure. If we provide you with a password for access to certain parts of the Website, you are responsible for keeping this password confidential and for complying with any security procedures we notify you of. Do not share your password with anyone.

While we take steps to protect your Personal Information, the Internet is an inherently insecure environment. Therefore, we cannot guarantee the security or confidentiality of your information. Any transmission of Personal Information is at your own risk. We assume no liability for any unauthorized access, data loss, or other breaches that occur due to factors beyond our control.

If you access third-party websites from the Website, please note that we cannot control how these third parties use or protect your information. You should carefully review their privacy policies before disclosing any Personal Information.

Disclosure of Personal Information

We may disclose Personal Information we collect from or about you to the following persons or organizations:

• Our affiliated entities;
• Contractors, service providers, and other third parties who support our business, including marketing services providers;
• Buyer(s) or successor(s) in the event of a merger, divestiture, restructuring, or sale of some or all of our assets;
• For purposes disclosed to you when you provide the information; and
• With your consent.

Additionally, we may disclose Personal Information if:

• We are required or authorized by law, regulatory authorities, or law enforcement agencies;
• It is necessary to enforce our Terms of Use;
• We believe disclosure is necessary to protect the rights, property, or safety of any person or entity; or
• It is necessary to investigate or prevent violations of applicable laws or policies.

Your Rights

Depending on applicable data protection laws, you may have rights related to your Personal Information, such as:

• Accessing and obtaining information about the processing of your Personal Information;
• Withdrawing your consent to processing at any time (where consent is the basis for processing);
• Receiving your Personal Information in a structured, machine-readable format in certain circumstances;
• Requesting that we rectify inaccurate or incomplete Personal Information;
• Requesting the erasure of your Personal Information in certain circumstances;
• Requesting that we restrict the processing of your Personal Information in certain circumstances; and
• Lodging a complaint with a data protection regulator.

To exercise these rights, please contact us using the details provided below. There may be fees associated with certain requests, as permitted by law.

Retention of Personal Information

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected and to comply with legal and regulatory obligations. The retention period may vary depending on the nature of the information and the applicable legal requirements.

Cookies

The Website uses cookies to enhance your user experience. For more details, please see our Cookies Policy.

Children

The Website is not intended for children under 13 years of age. We do not knowingly collect information from children. No one under 13 may provide any information to or on the Website.

California Privacy Rights Act (CPRA)

Information for California Residents

L40 Partners, Inc. ("L40," "we," "us," or "our") collects and processes Personal Data in compliance with the California Privacy Rights Act (“CPRA”). This California Privacy Notice applies specifically to residents of California ("Consumers," "you," or "your").

For purposes of this California Privacy Notice, “Personal Data” refers to information that is linked or reasonably linkable to a particular individual or household. However, the following are not considered Personal Data under the CPRA:

• Publicly available information;
• Deidentified or aggregated data; and
• Information otherwise excluded from the CPRA's scope.

This Privacy Notice outlines:

1. The categories of Personal Data we collect;
2. The purposes for which we use Personal Data;
3. The categories of Personal Data we disclose to third parties;
4. The categories of third parties to whom we disclose Personal Data; and
5. How Consumers can exercise their rights under the CPRA, including:
   
   • 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; and
   • The rights to opt out of sharing of Personal Data for purposes such as behavioral advertising or sales of Personal Data.

Categories of Non-Sensitive Personal Data

The list below details the non-sensitive categories of Personal Data collected by L40 and whether it is disclosed to third parties.

Category: Identifiers

• Examples: Name, postal address, email address, phone number, driver’s license, passport number
• Purpose(s): Internal business operations, compliance with legal and regulatory requirements
• Targeted Advertising: We do not engage in targeted advertising
• Sale: We do not sell Personal Data
• Sharing: May be shared with processors
• Retention: We retain data as necessary to meet legal and regulatory requirements

Category: Professional Information

• Examples: Current and past employment details
• Purpose(s): Recruiting, internal human resources, compliance with legal obligations
• Targeted Advertising: We do not engage in targeted advertising
• Sale: We do not sell Personal Data
• Sharing: Not shared with third parties
• Retention: Retained to meet legal and regulatory obligations

Category: Commercial Information

• Examples: Financial data related to individuals or businesses
• Purpose(s): To provide services and for marketing purposes
• Targeted Advertising: We do not engage in targeted advertising
• Sale: We do not sell Personal Data
• Sharing: Not shared with third parties
• Retention: Retained to meet legal and regulatory obligations

Categories of Sensitive Personal Data

The list below outlines the sensitive categories of Personal Data collected by L40 and how it is managed in accordance with applicable law.

Category: Government ID Data

• Examples: Passport, driver’s license, or other government-issued ID
• Purpose(s): Compliance with regulatory requirements, such as identity verification and anti-money laundering checks
• Targeted Advertising: We do not engage in targeted advertising
• Sale: We do not sell Personal Data
• Sharing: Not shared with third parties
• Retention: Retained to comply with legal and regulatory requirements

Category: Sensitive Characteristics

• Examples: Race, gender identity, and age
• Purpose(s): Diversity initiatives and compliance with regulatory requirements
• Targeted Advertising: We do not engage in targeted advertising
• Sale: We do not sell Personal Data
• Sharing: Not shared with third parties
• Retention: Retained to meet legal obligations

Use of Personal Data

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

Disclosure of Personal Data

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

• Processors: We engage processors to handle Personal Data securely on our behalf under contractual obligations to protect the data.

We do not sell Personal Data to anyone.

Exercising Your Rights

Under the CPRA, California Consumers have the following rights:

1. Right to Access, Correct, or Delete: You may request access to, correction of, or deletion of your Personal Data.
2. Right to Data Portability: You may request a portable copy of your Personal Data.
3. Right to Limit the Use of Sensitive Personal Data: You may direct us to limit the use of Sensitive Personal Data in certain situations.
4. Right to Opt-Out: You may opt out of sharing Personal Data for purposes such as targeted advertising, sales of Personal Data, or certain types of profiling.

To exercise these rights, please submit a request by sending an email to info@l40.com , with the subject of the email being: “California Privacy Rights Act”.

To protect your privacy, we may need to verify your identity before processing your request. We will send a verification email to confirm your request. If you do not verify your identity, we may not be able to process your request.

We will respond to verified requests within 45 days, with the possibility of a 45-day extension if necessary. Requests that are manifestly unfounded or excessive may be declined or subject to a reasonable fee.

Limiting the Use of Sensitive Personal Data

You can request to limit the use of Sensitive Personal Data by submitting a request through the process described above.

Authorized Agent Requests

You may designate an authorized agent to make a rights request on your behalf. Verification of the authorized agent's identity and your authorization will be required.

Contact Us

If you have any questions regarding this California Privacy Notice, please contact us at:

Email: info@l40.com

Questions

If you have any questions, concerns, complaints, or comments about this Privacy Policy and our privacy practices, or if you would like details regarding the relevant regulator, please contact us at:

Email: info@l40.com

We will make reasonable efforts to respond promptly to your inquiries and address any concerns you may have.

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