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    Privacy Policy

    This Privacy Policy describes how SROA Capital, LLC and affiliates (collectively, “SROA,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

    You can jump to particular topics by going to the headings below:

    Information We Collect

    We collect information about you in a variety of ways depending on how you interact with us and our websites and services, including:

    • Directly from you when you provide it to us, such as when you register for an account, sign up to receive communications from us, or contact us by phone, email, or otherwise.
    • Automatically through the use of cookies, server logs, and other similar technologies when you interact with our websites and emails.
    • From other sources, including, for example, our affiliates, business partners, service providers, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

    The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

    Context

    Types of Data

    Primary Purpose for Collection and Use of Data

    Client Information

    We collect the name, and contact information, of our clients and their employees with whom we may interact.

    We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.

    Cookies and First-Party Tracking

    We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed.

    We have a legitimate interest in making our website operate efficiently.

    Cookies and Third-Party Tracking

    We may place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites.

    Where required by law, we base the use of third-party cookies upon consent.

    Demographic Information

    We collect personal information, such as your age or location.

    We have a legitimate interest in understanding our users and providing tailored services.

    Distance Information

    When you use one of our Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells our products.

    We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.

    Email Interconnectivity

    If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

    We have a legitimate interest in understanding how you interact with our communications to you.

    Employment

    If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.

    Feedback/Support

    If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply.

    We have a legitimate interest in receiving, and acting upon, your feedback or issues.

    Surveys

    When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

    We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.

    Website Interactions

    We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.

    We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

    Web Logs

    We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

    We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

    How We Use Information

    In addition to the purposes and uses described above, we use information in the following ways:

    • To identify you when you visit our websites or our offices.
    • To provide services.
    • To improve our services and product offerings.
    • To conduct analytics.
    • To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
    • To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
    • To debug, identify and repair errors that impair existing intended functionality of our website and services.
    • To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
    • For internal administrative purposes, as well as to manage our relationships.
    • For such other purposes as you may consent (from time to time).

    How We Share Information

    In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

    • Affiliates and Acquisitions: We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
    • Other Disclosures without Your Consent: We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
    • Public: Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
    • Service Providers: We may share your information with service providers. Among other things service providers may help us to administer our website and platform, conduct surveys, provide technical support, executing contracts, processing payments, and assist in the fulfillment of orders.
    • Other Disclosures with Your Consent: We may disclose your information to other third parties when we have your consent or direction to do so.

    Your Choices

    Some jurisdictions give you a right to make the following choices regarding your personal information:

    • Online Tracking: We do not currently recognize the “Do Not Track” signal.
    • Promotional Emails: You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.

    How We Protect and Retain Information

    No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

    Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

    Third-Party Applications/Websites

    For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.

    Changes To This Privacy Policy

    We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

    Contact Information

    If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

    [contact@sroa.com](mailto: contact@sroa.com)
    2751 South Dixie Hwy, Suite 450 West Palm Beach, FL 33405

    Effective Date: December 7th, 2023
    Last Update: December 7th, 2023