GrowIt Inc.

PRIVACY POLICY

Last Updated: September 18, 2024

Thank you for taking the time to read our privacy policy. At GrowIt (GrowIt, we, or us), your privacy is of the utmost importance. We want you to be fully informed about the information we collect, how it is used, shared, and protected, and the choices you have with it and explain the privacy and data practices at GrowIt.

We help our customers (Customers) raise and manage capital from outside investors for the acquisition of real estate, and manage their portfolio of properties from a central place. (collectively, our Services). This privacy policy sets out how we collect, use, process, store, and disclose personal information in providing the Services.

1. PERSONAL INFORMATION WE COLLECT

Customer Information:

In order to serve our Customers, GrowIt will collect various information on our Customers, including:

• Contact information including your name, phone number, personal or company postal address, personal or company email, company name, company website URL, and company registered agent.
• Company information including, Articles of Organization, company Operating Agreement, and company capitalization table.
• Information regarding the business entity an investor is investing through, including name and beneficial owners and their associated government-issued identification such as drivers license and/or social security numbers.
• Identity information, which may include government-issued identification such as drivers license and/or social security numbers.
• Correspondence, which may include any personal information provided during an email correspondence or customer service engagement.
• Billing and administrative finance information, which may include tax return information.
• Information about how our Customers use our Services, including time spent on our applications, behavioral activity, and metadata associated with software interactions.

Collaborator Information:

When our Customers use our Services, they authorize GrowIt to process various types of personal information on potential business collaborators. Below, we provide a list of the commonly processed personal information of any such collaborators. Please note, the below list is not exhaustive of all personal information, and is intended to serve as a sample set.

• Contact information such as name, email address, phone number and address.
• LinkedIn or other business professional information.
• Billing and administrative finance information.

We do not intentionally collect any personal information from children under the age of 16. If you believe we have obtained personal information associated with children under the age of 16, please contact us at privacy@GrowIt.com and we will delete it.

Information we automatically collect:

• Metadata and Analytics. We may collect Metadata and analytics of your use of our Services, including IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages. We may utilize pixel tags, web beacons and/or cookies to collect this information.

2. HOW WE USE PERSONAL INFORMATION

Subject to our Terms of Service and/or any written client agreements, we may use personal information for the following purposes:

• To provide our Services, including but not limited to setting up, maintaining and making changes to legal entities, filling in template legal documents, filling out forms on behalf of the customer, maintaining your capitalization table, inviting and onboarding new investors or users, receiving insurance quotes, and receiving lending quotes.
• Customer support, including phone, chat and email.
• To improve our Services, for example, we use your information to better our Services.
• To authenticate, verify or otherwise ensure compliance with Customer written instructions or to mitigate the risk of fraud.

3. HOW WE DISCLOSE PERSONAL INFORMATION

We may share personal information with third parties to help us use your personal information, as described above. For example, we may work with the following Partners (as needed):

• 'Know Your Customer' identity and/or 'Know your business' identity and financial validation tools.
• Investor accreditation services
• Regulatory compliance counsel services
• Financial payment services
• Customer Support
• Customer Relationship Management
• Email Service Providers

Subject to client agreements, we may disclose Customers information in order to:

• Execute legal instruments with state or other regulators, which may include filing Beneficial Owner Information in compliance with the Corporate Transparency Act (CTA).
• Protect the legal rights of our company, our employees, our agents, and our affiliates.
• Protect the safety and security of those who access and use our Services.
• Detect and protect against fraud.
• Comply with law or legal process.
• Complete a legal transaction related to the sale of our business or any assets.

GrowIt may share aggregate or anonymous information for any purpose. This means that the information we share does not identify specific individuals, or is combined with other data to protect your privacy.

4. PRIVACY CHOICES

GrowIt provides you with the following choices with our use of your personal information:

• Access the personal information we maintain about you.
• Delete the personal information we maintain about you, subject to legal or regulatory obligations to retain such information for recordkeeping purposes.
• Correct inaccurate personal information we maintain about you
• Opt out of certain uses of your personal information, notably:
  • Marketing Emails: To opt out of marketing e-mail communications, you may click the 'unsubscribe' link in the marketing emails.
  • Marketing Text Messages: To opt out of marketing text messages, you must reply STOP to the text message. You agree that texting 'STOP' in response to our text message is the only reasonable method of opting out. You also understand and agree that any other method of opting out, including, but not limited to, texting words other than 'STOP' or verbally requesting one of our employees to remove you from our list, is not a reasonable means of opting out.

You can exercise these rights by contacting us at privacy@growit.com

5. SECURITY

We maintain reasonable safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. Despite our efforts, we cannot guarantee that unauthorized access or use will never occur. It is important that you take steps to keep your information safe and secure. Choose an account password that is hard for others to guess and don't reveal it to third parties. If you use a shared public computer, do not opt to have your login ID or password remembered and be sure to log out of your account when you finish.

6. RETENTION

We will retain Customer personal information according to the terms of our written agreements or otherwise as required by law or regulation.

7. THIRD-PARTY LINKS

The Services may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy statements of any other site that collects personally identifiable information.

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time as we update or expand our Services. If we make material changes, we will post the updated Privacy Policy on this page with a 'Last Updated' effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services.

9. CONTACT US

If you have any questions about our privacy or security practices, or if you are a GrowIt Customer and would like to request access to or correction of your personal information, you can contact us by email at privacy@growit.com or at: