Additional California Privacy Disclosures

This California Privacy Notice (this "California Notice") supplements the FE International Privacy Policy and applies only to natural persons who reside in the State of California ("California residents or "you"). It describes how FE International, Inc. ("FE International, "we, "our, or "us") collects, uses, discloses, and otherwise processes personal information about California residents, and the rights you have under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the "CCPA).

Capitalized terms used in this California Notice that are not defined here have the meaning given to them in the FE International Privacy Policy or in the CCPA. Any conflict between this California Notice and the Privacy Policy with respect to California residents is resolved in favor of this California Notice.

California's "Shine the Light" law (Cal. Civ. Code § 1798.83) also gives California residents the right, once per calendar year, to request information about our disclosures of certain categories of personal information to third parties for those parties' own direct-marketing purposes. To make a Shine the Light request, please email privacy@feinternational.com.

1. Your Rights at a Glance

Subject to the conditions described in this California Notice, California residents have the following rights with respect to personal information FE International collects about them:

Right to Know — request information about the categories and specific pieces of personal information we collect, the sources, the purposes, and the categories of third parties with whom we share that information.

Right to Access (Portability) — request a copy of the specific pieces of personal information we hold about you, in a portable format where reasonably feasible.

Right to Correct — request that we correct inaccurate personal information we maintain about you.

Right to Delete — request that we delete personal information we have collected from you, subject to legal exceptions.

Right to Opt Out of Sale or Sharing — direct us not to "sell" or "share" your personal information, as those terms are defined under the CCPA. FE International does not sell personal information for money, and we have not knowingly "sold" personal information in the prior twelve (12) months. Where our use of analytics or advertising technologies could be construed as "sharing" for cross-context behavioral advertising, you may opt out as described in Section 6.

Right to Limit Use of Sensitive Personal Information — if we use sensitive personal information for purposes other than those permitted by the CCPA, direct us to limit that use.

Right to Non-Discrimination — exercise any of these rights without receiving discriminatory treatment from FE International.

Right to Appeal a Denial — if we deny a request, you may submit a written appeal to privacy@feinternational.com explaining the basis for your appeal, and we will respond within the time period required by law.

Section 4 explains how to submit a request and how we verify it.

2. Categories of Personal Information We Collect

In the prior twelve (12) months, FE International has collected the following CCPA-defined categories of personal information about California residents. The table also identifies whether we have disclosed the category for a business purpose, and whether we have "sold" or "shared" the category as those terms are defined under the CCPA.

3. Purposes for Collection, Use, and Disclosure

3.1 Business Purposes

FE International collects, uses, and discloses personal information for the following business purposes (each as defined in the CCPA):

• providing, operating, and securing the FE International website, the FE International Marketplace, and our products and services;
• creating, administering, and maintaining your account, including authentication, password reset, and account recovery;
• processing transactions, calculating and collecting fees (including the Closing Fee), and producing receipts, statements, and tax-related reporting;
• verifying identity and performing know-your-customer, anti-money-laundering, sanctions-screening, and fraud-prevention checks, including through third-party verification providers;
• communicating with you about your account, transactions, listings, support requests, and changes to our terms or policies;
• providing customer service and technical support;
• personalizing the Site, recommending listings or content that may be relevant to you, and improving our products and services;
• performing analytics, research, and quality assurance, including measuring engagement and the effectiveness of marketing;
• marketing FE International products and services where permitted by law, and managing email and other communication preferences;
• detecting, investigating, and preventing security incidents, fraud, abuse, or other illegal activity;
• complying with legal obligations, responding to lawful requests from public authorities, and enforcing our agreements; and
• any other purpose disclosed at the point of collection or to which you consent.

3.2 Categories of Recipients

We may disclose personal information to the following categories of third parties for the business purposes above:

• service providers and processors that help us operate the Site and Marketplace (for example, hosting, security, analytics, customer support, email delivery, payment processing, identity verification, and cloud storage);
• professional advisors (legal, accounting, audit, tax, and insurance) acting on our behalf;
• M&A advisors, lenders, escrow partners, and similar partners that you choose to engage in connection with a transaction;
• other users of the Site or Marketplace, but only as needed to facilitate communication or a transaction you initiated, and consistent with the Buyer & Seller Platform Terms;
• government agencies, courts, regulators, and law-enforcement authorities, where we believe disclosure is required by law, legal process, or to protect our rights, users, or the public; and
• actual or potential acquirers, investors, lenders, or successors in connection with a financing, merger, acquisition, reorganization, or sale of substantially all of our assets, subject to customary confidentiality protections.

3.3 Retention

FE International retains each category of personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide our services, maintain business records, comply with our legal and tax obligations, resolve disputes, prevent fraud and abuse, and enforce our agreements. Retention periods vary by category and are determined based on the nature and sensitivity of the information, the purpose for which it is processed, applicable legal requirements (including statutes of limitation and recordkeeping laws), and our legitimate business needs. When personal information is no longer needed, we delete or de-identify it in accordance with our retention schedule.

4. How to Submit a Request

4.1 Right to Know, Access, Correct, or Delete

To exercise your Right to Know, Right to Access, Right to Correct, or Right to Delete, please email support@feinternational.com with the subject line that identifies the request type (for example, "California Right to Know Request"). Include enough information for us to (a) reasonably verify your identity and (b) understand and respond to your request.

4.2 Right to Opt Out of Sale or Sharing

To exercise your Right to Opt Out of Sale or Sharing, please use the "Do Not Sell or Share My Personal Information" link in the footer of https://www.feinternational.com or email support@feinternational.com. We also honor recognized opt-out signals such as the Global Privacy Control (GPC) when received from a browser or device you are using.

4.3 Right to Limit Use of Sensitive Personal Information

Because FE International only uses sensitive personal information for purposes permitted by CCPA § 7027(m) (such as identity verification and fraud prevention), there are no additional uses for you to limit. If our practices change, we will update this California Notice and provide a way to exercise this right. You may still email support@feinternational.com with any questions.

4.4 Verification

To protect your information, we will take reasonable steps to verify your identity before responding to a Right to Know, Access, Correct, or Delete request. The verification process depends on the sensitivity of the information requested and your relationship with us. For most account-based requests, we will verify by matching information you provide with information already in our records. For requests involving more sensitive information, we may require additional verification.

If you do not have an account with us, we may not have enough information to verify your identity to a sufficient degree of certainty. In that case, we will explain why we cannot verify the request and give you the chance to provide additional information.

4.5 Authorized Agents

You may use an authorized agent to submit a request on your behalf. We will require: (a) written permission signed by you authorizing the agent to act on your behalf, or a valid power of attorney under California Probate Code §§ 4000–4465; (b) verification of the agent's identity; and (c) where required by law, direct verification of your own identity. We may deny a request from an agent who cannot meet these requirements.

4.6 Response Timing

We will confirm receipt of a verifiable consumer request within ten (10) business days and will respond within forty-five (45) calendar days, with a possible 45-day extension where reasonably necessary and with notice to you. There is no charge to submit a request, except as permitted by law for manifestly unfounded or excessive requests.

4.7 Frequency

You may submit a verifiable Right to Know or Right to Access request up to two (2) times in any twelve-month period.

4.8 Appeals

If we deny your request in whole or in part, you may submit a written appeal to privacy@feinternational.com within sixty (60) days of our response. We will review the appeal and respond within the time required by law. If we deny the appeal, we will explain the basis and inform you of your right to contact the California Privacy Protection Agency or the California Attorney General.

5. Reasons We May Decline a Deletion Request

Subject to the CCPA, we may retain some or all of your personal information notwithstanding a deletion request where retention is necessary for us, our service providers, or our contractors to:

• complete the transaction for which the personal information was collected, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall, or otherwise perform a contract with you;
• help ensure the security and integrity of our services, including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• debug to identify and repair errors that impair existing intended functionality;
• exercise free speech, ensure the right of another consumer to exercise free speech, or exercise another right provided for by law;
• comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, where deletion would render the research impossible or seriously impair it, and where you previously provided informed consent;
• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information;
• comply with a legal obligation, including tax, accounting, audit, and recordkeeping requirements; or
• make other internal and lawful uses of the information that are compatible with the context in which it was provided.

Where we retain personal information under one of these exceptions, we will not use it for any purpose other than the exception that justified retention, and we will instruct our service providers to do the same.

6. Cookies, Analytics, and Cross-Context Behavioral Advertising

FE International uses cookies, pixels, SDKs, and similar technologies on the Site for authentication, security, preference storage, analytics, and marketing measurement. Some of these technologies are operated by third parties — for example, Google Analytics, HubSpot, and similar tools — that collect information about your interactions with the Site on our behalf.

Depending on how these tools are configured, the data they collect could be considered "sharing" of personal information for cross-context behavioral advertising under the CCPA. We do not exchange personal information for money. Where our practices fall within the CCPA definition of "sharing," California residents may opt out by:

using the "Do Not Sell or Share My Personal Information" link in the footer of https://www.feinternational.com;

enabling the Global Privacy Control (GPC) on a supported browser or extension — we treat a valid GPC signal as a Right to Opt Out of Sale or Sharing for that browser or device; or

emailing support@feinternational.com.

If you have an account, please opt out while logged in so that the opt-out can be linked to your account and applied across devices where reasonably feasible.

7. Households

FE International does not currently collect personal information that is organized at a household level. If multiple members of a household submit requests, we will treat each request as an individual request from that household member.

8. Children Under 16

The FE International Site and Marketplace are not directed to, and we do not knowingly collect personal information from, children under 16. Consistent with the CCPA, we do not sell or share the personal information of consumers we know to be under 16 without the affirmative consent required by law. If we learn that we have collected personal information from a child under 16 without the required consent, we will delete that information.

9. Non-Discrimination

FE International will not discriminate against you for exercising any of your CCPA rights. Specifically, we will not (except as permitted by the CCPA) deny goods or services, charge different prices or rates, provide a different level or quality of services, or suggest that any of the foregoing will occur because you exercised a right under the CCPA.

10. Changes to This California Notice

FE International may update this California Notice from time to time to reflect changes in our practices, technologies, legal requirements, or for other reasons. When we make material changes, we will update the "Effective Date" above and provide notice through the Site or by other reasonable means. Continued use of the Site after the Effective Date of an updated California Notice constitutes your acknowledgment of the changes.

11. Contact Us

If you have any questions about this California Notice or our handling of personal information, please contact us:

Email: support@feinternational.com

Web: https://www.feinternational.com/contact/

Mail: FE International, Inc., Attn: Privacy, 75 Rockefeller Plaza, 19th Floor, New York, NY 10019, USA.

© FE International, Inc. All rights reserved.

California residents with questions: support@feinternational.com.

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