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Sequoia Heritage Privacy Policy

Privacy Policy

Sequoia Heritage, through various Sequoia Heritage entities and related Heritage entities (“Sequoia Heritage”) obtains and uses personal information about individuals as part of our business. This privacy policy explains how Sequoia uses, shares and protects personal information that it collects, including on websites operated by Sequoia Heritage (“Site”).

Investors in Sequoia Heritage will receive a privacy notice as part of their subscription documents, and nothing in this policy is intended to modify or amend any other written agreement you may have with Sequoia Heritage (“Other Agreements”), if any, which may currently be in effect. In the event of any inconsistency between this policy and any Other Agreements, the Other Agreements will govern.

The Sources and Categories of Information Sequoia Heritage collects personal information from you in various ways, including when you visit the Site, interact with our team, or apply for a position with us. The personal information we collect about you will vary by context and may include your name and contact details; your professional background; your stated and inferred interests; and your activity on the Site.

Cookies and Automatic Collection of Data We may use cookies, web beacons, and other technologies. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We do not modify your online experience based upon whether such a signal is broadcast.

Our Use of Your Personal Information We may use your personal information for multiple internal and external purposes, including but not limited to administering, facilitating and managing your relationship with Sequoia Heritage; further communications with you about our business; improving our Site and developing new products and services; administering Sequoia Heritage’s systems and troubleshooting purposes; and facilitating our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

For United States residents, we undertake marketing only in compliance with the CAN-SPAM Act, the Telephone Consumer Protection Act, and other applicable law. For European Union residents, we undertake marketing only with your express affirmative consent and in compliance with applicable data privacy laws. EU residents will not be added to Sequoia Heritage marketing lists unless they have already provided express affirmative consent consistent with data protection laws.

Disclosures of Your Personal Information to Third Parties Sequoia Heritage does not share personal information with unaffiliated third parties for those third parties’ own purposes. Sequoia Heritage may, however, share personal information with our third-party service providers, agents, contractors, or partners in connection with services that these individuals or entities perform for, or with Sequoia Heritage.

Sequoia Heritage may also disclose your personal information to investigate, establish, and protect Sequoia Heritage’s legal rights and interests. Under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; and to otherwise cooperate with law enforcement or regulatory authorities.

We may transfer or share a copy of personal information about you in the event that Sequoia Heritage or one of its assets, affiliates, or subsidiaries goes through a business transition, such as a merger, being acquired by another company, being reorganized or liquidated, or by selling a portion of its assets. Nothing in this Privacy Policy is intended to interfere with the ability of Sequoia Heritage to transfer all or part of its business and/or assets to an affiliate or independent third party at any time, for any purpose, without any limitation whatsoever, including during any diligence process.

We do not sell your personal information and we do not share your personal information with third parties or corporate affiliates for their direct marketing purposes.

Data Quality, Storage, and Access While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us by promptly notifying us if there are any changes to your personal information.

We store personal information for different periods of time consistent with the purposes for which they were originally collected, as subsequently further authorized, or when required or allowed under applicable law.

Information Security Sequoia Heritage is committed to protecting the privacy of your personal information. While we implement security measures to help safeguard your data, no physical or electronic security system is impenetrable and do not guarantee the security of our servers, databases, or systems.

California Privacy Rights Under California Civil Code sections 1798.100–.199 California residents may have the right to request access to certain personal information collected by us dating back one year before you make your request. Specifically, you may have the right to ask that we disclose to you (1) the categories of personal information we have collected about you; (2) the categories of sources from which we collect personal information; (3) our business or commercial purpose for collecting personal information; (4) the categories of third parties with whom we share personal information; (5) the specific pieces of information we have collected about you; and (6) if we disclosed personal Information for a business purpose, a list of the categories of personal information we have disclosed in the prior 12 months.

You also may have the right to ask that we delete your personal information. We will not delete your personal information if we need it in order to service your account, to protect the security or functionality of our operations, to comply with legal or regulatory obligations, or for certain other reasons.

You may submit request for access or deletion via the methods set forth in the “Contact Information” section below.

Only you, or a person authorized by you to act on your behalf, may submit a request for access to, or deletion of, your personal information.

In connection with an access or deletion request, we will undertake steps to verify your identity. We may ask you to provide information that we have on file about you or, if the request is submitted in writing or online, we may contact you via another method (e.g., phone) to verify your identity. We will only use personal information provided in a request to verify the requestor’s identity and authority to make the request. We will maintain a record of access and deletion requests as required by law.

We will not deny services, charge different prices, offer a different quality of service or otherwise discriminate against an individual for exercising the rights afforded to you under the Cal. Civ. Code §§ 1798.100–.199.

Children’s Privacy This Site is not intended for children. We do not knowingly collect personal information from children under the age of 13, and in the event that we learn that a child under the age of 13 has provided information on our Site, we will delete that information as soon as possible.

Data Subject Rights Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Uruguay, and certain other jurisdictions have certain data subject rights. These rights vary but they may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) the right to data portability. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority.

If you make a request related to information about you, you may be required to supply a valid means of identification as a security precaution. We will process your request within the time provided by applicable law.

Questions Regarding Your Privacy and This Policy If you believe that Sequoia Heritage may be processing data about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as if responding to the request would be unreasonably expensive.

Please also let us know if you have any questions, concerns, disputes, or issues. If you need to reach us about a privacy or data protection issue, please contact us using the contact information below.

Other Privacy Policies or Statements; Changes to Policy This policy provides a general statement of the ways in which Sequoia Heritage protects your personal information. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Site.

Contact Information Sequoia Heritage | (800) 392-1466 |

Effective Date: February 25, 2020

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