Privacy Policy

Last Updated: April 2025

Introduction

Horizon Digital Inc. ("Horizon," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services.

By accessing or using our services, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the website or use our services.

Notice at Collection

We collect the categories of personal information listed below. This information is collected for the purposes described in the "How We Use Your Information" section. We do not sell or share your personal information in exchange for monetary or other valuable consideration. For more details, see "Your CCPA Rights" below.

Information We Collect

We may collect information about you in a variety of ways:

Categories of Personal Information Collected

We collect the following categories of personal information, as defined under the CCPA:

• Identifiers (e.g., name, email address, phone number, mailing address, IP address)

• Personal records (e.g., Social Security number, TIN, account information)

• Commercial information (e.g., transaction history, services purchased)

• Internet activity (e.g., browsing history, usage data)

• Geolocation data (if collected through IP or app activity)

• Professional or employment information

• Inferences drawn from the above to create a profile about a consumer

Data Retention

We retain personal information only as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. The retention period may vary depending on the type of data and our legal obligations.

How We Use Your Information

We may use your information for the following purposes:

• To provide, maintain, and improve our services

• To process and complete transactions, including home equity investments

• To verify your identity and eligibility for our services

• To communicate with you about our products, services, and promotions

• To personalize your experience and deliver content relevant to your interests

• To comply with legal and regulatory requirements

• To detect, investigate, and prevent fraudulent transactions and other illegal activities

• To analyze usage patterns and improve our website and services

We may share your information with our Preferred Partner as necessary to evaluate your eligibility and facilitate the services offered through Horizon.

Disclosure of Your Information

We may share your information in the following situations:

• With service providers who perform services on our behalf

• With financial institutions and partners to facilitate transactions

• With credit bureaus and reporting agencies

• With legal, governmental, and regulatory authorities when required by law

• In connection with, or during negotiations for, any merger, sale of company assets, financing, or acquisition

• With your consent or at your direction

Security of Your Information

We use administrative, technical, and physical security measures to protect your personal information. While we have taken reasonable steps to secure the information you provide to us, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the security of your information.

Cookies and Tracking Technologies

We may use cookies, web beacons, tracking pixels, and other tracking technologies (collectively, "Cookies") when you visit our website to help customize the website, analyze performance, and improve your experience.

Use of Cookies

Cookies help us understand how you interact with our website, remember your preferences, and deliver relevant content and features.

First-Party and Third-Party Cookies

First-party Cookies are set by us and are essential for the website to function. Third-party Cookies are set by service providers for analytics, advertising, and other purposes and are governed by their privacy policies.

How to Control Cookies

You can manage your cookie preferences through your browser settings. Disabling Cookies may impact functionality. For more information about cookies, please visit allaboutcookies.org.

Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information, which may include:

• The right to access and receive a copy of your personal information

• The right to correct inaccurate or incomplete information

• The right to delete your personal information

• The right to restrict or object to processing of your personal information

• The right to data portability

• The right to withdraw consent

To exercise these rights, please contact us using the information provided below.

Your CCPA Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the CPRA:

• Right to Know: You have the right to request information about the categories and specific pieces of personal information we collect, use, disclose, and sell or share.

• Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.

• Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.

• Right to Opt-Out of Sale or Sharing: You have the right to direct us not to sell or share your personal information.

• Right to Limit Use of Sensitive Personal Information: If we use sensitive personal information beyond what is necessary to provide our services, you have the right to limit such use.

• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

To exercise these rights, you may contact us at support@joinhorizon.com or submit a verifiable consumer request via our online form (if available).

You may designate an authorized agent to make requests on your behalf. We will take steps to verify your identity and the authority of your agent before fulfilling your request.

Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at:

Email: support@joinhorizon.com