Privacy Policy

1. Overview

Harwick Securities LLC ("Harwick Securities," "we," "us," or "our") is committed to protecting your personal information. This Privacy Policy describes how we collect, use, share, and protect information in connection with our website located at [INSERT DOMAIN] (the "Site") and our securities offering services.

By accessing the Site or submitting information to us, you agree to the terms of this Privacy Policy. If you do not agree, please do not use our Site.

2. Information We Collect

We collect the following categories of information:

• Contact Information: Name, email address, phone number, and mailing address.
• Financial Information: Investment interest range and related financial profile data you provide.
• Identity Verification: Government-issued ID and other documentation required for AML/KYC compliance under applicable law.
• Usage Data: IP address, browser type, device information, pages visited, and time spent on the Site.
• Communications: Records of any correspondence between you and Harwick Securities.

3. How We Use Your Information

We use the information we collect to:

• Process your indication of interest and investor onboarding
• Comply with FINRA, SEC, and applicable securities regulations
• Conduct AML/KYC identity verification as required by law
• Send you communications about the offering, including offering documents and updates
• Respond to your inquiries and provide investor relations support
• Improve the Site and our services
• Comply with legal obligations and regulatory requirements

4. Information Sharing

We do not sell your personal information. We may share your information with:

• Service Providers: Third-party vendors who assist with technology, identity verification, escrow, and communications services.
• Regulators: FINRA, the SEC, and other regulatory bodies as required by applicable law or legal process.
• Legal Counsel: Our attorneys and advisors in connection with legal obligations.
• Escrow Agent: North Capital Trust Company in connection with the administration of your investment.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal, regulatory, and recordkeeping requirements. FINRA Rule 4511 requires broker-dealers to retain certain books and records for a minimum of six years.

6. Cookies and Tracking

Our Site uses cookies and similar tracking technologies to improve user experience and analyze traffic. You may decline non-essential cookies using the consent banner presented on your first visit. Essential cookies required for Site functionality cannot be disabled.

If you accept analytics cookies, we may use [INSERT ANALYTICS PROVIDER, e.g., Google Analytics] to collect aggregated usage data. No personally identifiable information is shared with analytics providers.

7. Your Rights (California / CCPA)

If you are a California resident, you have the right to: (a) know what personal information we collect and how it is used; (b) request deletion of your personal information, subject to certain exceptions; (c) opt out of the sale of your personal information (we do not sell personal information); and (d) not be discriminated against for exercising your rights.

To exercise your rights, contact us at +1 (329) 203-9125.

8. Security

We implement commercially reasonable technical and organizational measures to protect your personal information. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated Policy on this page with a revised "Last Updated" date. Your continued use of the Site after changes constitutes acceptance of the updated Policy.

10. Contact Us

Questions about this Privacy Policy should be directed to:

Harwick Securities, Privacy Office
535 Fifth Avenue, Suite 1200, New York, NY 10017
investors@harwicksecurities.com
+1 (329) 203-9125
FINRA CRD# 083738