CALIFORNIA PRIVACY NOTICE

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Serra Nova Financial and its affiliates (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, households, and others who reside in the State of California (“consumers” or “you”).

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In particular, we have collected the following categories of personal information within the last twelve (12) months:

A. Identifiers – Examples: real name, alias, postal address, unique personal identifier, IP address, email address, account name, Social Security number, driver’s license or passport number. (Collected: YES)

B. Personal information categories listed in Cal. Civ. Code §1798.80(e) – Examples: name, Social Security number, address, telephone number, education, employment history, bank account or financial info. (Collected: YES)

C. Protected classification characteristics under California or federal law – Examples: age, race, color, ancestry, citizenship, marital status, sex, gender identity, disability, veteran status, and similar. (Collected: YES)

D. Commercial information – Examples: records of personal property, products or services purchased, obtained, or considered, or other purchasing tendencies. (Collected: YES)

E. Biometric information – Examples: fingerprints, faceprints, voiceprints, iris scans, gait, or other biometric data. (Collected: NO for customers / YES for certain employees)

F. Internet or other similar network activity – Examples: browsing history, search history, information on a consumer’s interaction with our website or ads. (Collected: YES)

G. Geolocation data – Examples: physical location or movements. (Collected: YES)

H. Sensory data – Examples: audio, electronic, visual, or similar information. (Collected: YES)

I. Professional or employment-related information – Examples: current or past job history or performance evaluations. (Collected: YES)

J. Non-public education information – Examples: grades, transcripts, student financial information. (Collected: NO)

K. Inferences drawn from other personal information – Examples: profile reflecting preferences, characteristics, psychological trends, behavior, attitudes, or abilities. (Collected: YES)

Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information excluded from the CCPA’s scope such as:

• Health or medical information covered by HIPAA or CMIA

• Personal information covered by sector-specific privacy laws (GLBA, FCRA, FIPA, DPPA)

Sources of Information

We obtain the categories of personal information listed above from:

• Directly from our clients or their agents (for example, documents provided for services).

• Indirectly from our clients or their agents (for example, information collected in the course of providing services).

• Directly and indirectly from activity on our website (for example, submissions through our website portal or automatically collected usage details).

• From third parties that interact with us in connection with the services we perform (for example, affiliate marketers or credit reporting agencies).

• Publicly available information online or elsewhere.

• Employees and job applicants.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.

• To provide you with information, products, or services that you request from us.

• To provide you with email alerts, newsletters, and other notices concerning our products, services, or events.

• To carry out our obligations and enforce rights from any contracts between you and us, including billing and collections.

• To assist you in identifying appropriate resources if we cannot serve you.

• To provide a third party with qualified leads for a program they may administer.

• To improve our website and present its contents to you.

• For testing, research, analysis, and product development.

• To conduct audit, compliance, or other legal work associated with our business.

• For financial reporting, accounting, and general business administration.

• To assess vendors and service providers.

• As necessary to protect the rights, property, or safety of us, our customers, or others.

• To respond to law enforcement requests or comply with legal obligations.

• To evaluate or conduct a merger, reorganization, dissolution, or similar transaction in which personal information may be transferred.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we do, we enter into a contract that requires the recipient to keep the information confidential and use it only for the intended purpose.

In the past twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

A. Identifiers

B. California Customer Records personal information categories

C. Protected classification characteristics

D. Commercial information

E. Biometric data

F. Internet or network activity

I. Professional or employment-related information

K. Inferences drawn from other personal information

We disclose personal information for business purposes to:

• Our affiliates

• Service providers

• Third parties you or your agents authorize us to disclose information to in connection with products or services we provide.

We may also disclose your personal information for a commercial purpose (for example, providing your information to a provider that can assist you). When we do, we require those recipients to comply with data privacy regulations and use it only as described.

In the past twelve (12) months, we have disclosed for a commercial purpose:

A. Identifiers

B. California Customer Records personal information categories

D. Commercial information

We disclose for commercial purposes to:

• Our affiliates

• Corporate credit facility lenders

• Service providers

• Vendors

• Other third parties including marketers

Your Rights and Choices

The CCPA provides California consumers with specific rights regarding their personal information. Your rights and choices are described in our main Privacy Policy and include the right to know, delete, and opt out of certain data sharing, subject to verification and applicable law.

Changes to This Notice

We reserve the right to amend this notice at our discretion and at any time. When we make changes, we will post an updated notice on our homepage and through other appropriate means.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, how we collect and use your personal information, or wish to exercise your rights under California law, please contact us:

Email: operations@serranovafinancial.com

Toll-Free: 727-614-5690

Mail: Serra Nova Financial, 30 N Gould St Ste N, Sheridan, WY 82801

Website: www.serranovafinancial.com

Effective Date: January 2025