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PRIVACY POLICY, DATA PROTECTION & COOKIE POLICY

High Yield Vault, LLC
Last Updated:1 April 2025


1. INTRODUCTION AND SCOPE

High Yield Vault, LLC (“High Yield Vault,” “Company,” “we,” “us,” or “our”) is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us. This Privacy Policy explains how we collect, use, disclose, store, and safeguard personal data in connection with our investment-related services, including access to life settlement investment opportunities.

This Policy applies to:

  • Visitors to our website
  • Prospective and existing investors
  • Advisors, intermediaries, and professional partners
  • Any individual who interacts with us electronically or offline

This Policy is designed to comply with applicable federal laws and state privacy laws, including but not limited to:

  • Gramm-Leach-Bliley Act (GLBA)
  • California Consumer Privacy Act (CCPA/CPRA)
  • Texas Data Privacy and Security Act (TDPSA)
  • New York data protection requirements
  • Florida consumer protection laws

2. INFORMATION WE COLLECT

We collect personal information only to the extent reasonably necessary to conduct our business as a financial services provider.

2.1 Categories of Information

Depending on your interaction with us, we may collect:

  • Identifiers: Full name, email address, phone number, mailing address
  • Financial & Investment Information: Investment objectives, suitability data, accreditation status, transaction history
  • Professional Information: Employment, income range, advisor relationships
  • Technical Data: IP address, browser type, device identifiers, website usage
  • Compliance Data: Information required for KYC, AML, and regulatory compliance

We do not intentionally collect data from minors under the age of 18.


3. PURPOSE OF DATA COLLECTION

We collect and process personal data for legitimate business and legal purposes, including:

  • Evaluating investor eligibility and suitability
  • Providing access to life settlement investment opportunities
  • Facilitating transactions and ownership transfers
  • Communicating with investors and advisors
  • Meeting regulatory, legal, and compliance obligations
  • Preventing fraud, misuse, or unauthorized access
  • Maintaining internal records and audit trails

We do not use personal data for purposes incompatible with these objectives.


4. LEGAL BASIS FOR PROCESSING

Where applicable, personal data is processed based on one or more of the following grounds:

  • Performance of a contract or pre-contractual steps
  • Compliance with legal or regulatory obligations
  • Legitimate business interests
  • Consent, where required by law

5. DISCLOSURE OF INFORMATION

We do not sell personal information.

We may disclose personal information only to:

  • Licensed brokers, advisors, and service providers involved in transactions
  • Legal, accounting, actuarial, and compliance professionals
  • Technology and data hosting providers under strict confidentiality agreements
  • Governmental or regulatory authorities when legally required

All disclosures are limited to what is necessary and permitted by law.


6. DATA SECURITY

We implement reasonable administrative, technical, and physical safeguards designed to protect personal and financial information, including:

  • Encrypted data storage and transmission
  • Access controls and authentication protocols
  • Limited internal access based on role
  • Vendor due diligence and contractual protections
  • Incident detection and response procedures

Despite these safeguards, no system can be guaranteed 100% secure.


7. DATA RETENTION

We retain personal data only for as long as necessary to:

  • Fulfill the purposes described in this Policy
  • Comply with legal, regulatory, and recordkeeping requirements
  • Resolve disputes or enforce agreements

Retention periods vary depending on the nature of the data and applicable law.


8. COOKIES & TRACKING TECHNOLOGIES

8.1 What Are Cookies

Cookies are small text files stored on your device to enhance website functionality, security, and performance.

8.2 Types of Cookies We Use

  • Essential Cookies: Required for website operation
  • Analytics Cookies: To understand usage patterns and improve performance
  • Security Cookies: To protect against fraud and unauthorized access

We do not use cookies for behavioral advertising or data resale.

8.3 Cookie Controls

You may manage or disable cookies through your browser settings. Certain features may be limited if cookies are disabled.


9. INVESTOR COMMUNICATIONS

By submitting your information, you consent to receive communications related to:

  • Investment opportunities
  • Compliance requests
  • Account-related notifications

You may opt out of non-essential communications at any time.


10. YOUR PRIVACY RIGHTS (GENERAL)

Depending on your jurisdiction, you may have the right to:

  • Access personal data
  • Request correction of inaccurate information
  • Request deletion (subject to legal exceptions)
  • Limit or object to certain processing

Requests may be submitted to:
📧 privacy@highyieldvault.com


STATE-SPECIFIC DISCLOSURES


CALIFORNIA (CCPA / CPRA)

California residents have the right to:

  • Know what personal information is collected and disclosed
  • Request access, correction, or deletion
  • Limit use of sensitive personal information
  • Opt out of sale or sharing (we do not sell or share)
  • Be free from discrimination

Requests are processed within statutory timelines.


NEW YORK

High Yield Vault complies with applicable New York data protection and cybersecurity standards. Financial data is handled in accordance with GLBA safeguards, and access is limited strictly to authorized personnel and licensed service providers.


FLORIDA

We collect and use personal data solely for legitimate business and compliance purposes. Personal data is not disclosed except as required to provide services or comply with law.


TEXAS (TDPSA)

Texas residents may:

  • Confirm whether data is processed
  • Access and correct personal data
  • Request deletion
  • Appeal denied requests

Appeals may be submitted to:
📧 compliance@highyieldvault.com


11. INTERNATIONAL USERS

Our services are intended for U.S.-based investors. If you access our services from outside the United States, your information will be processed under U.S. laws.


12. POLICY UPDATES

We reserve the right to update this Policy at any time. Material changes will be posted on our website with a revised effective date.


13. CONTACT INFORMATION

High Yield Vault, LLC
📧 privacy@highyieldvault.com
📧 compliance@highyieldvault.com


14. ACKNOWLEDGMENT

By using our website or services, you acknowledge that you have read, understood, and agreed to this Privacy Policy.