Privacy Notice

LIBA Capital, LLC, a Florida limited liability company ("LIBA Capital," "LIBA," "we," "us," or "our"), respects the privacy of people who visit our websites, use our platforms, submit investment or deal inquiries, apply for investor access, or otherwise interact with us. This Privacy Notice explains how we collect, use, disclose, retain, and protect personal information.

This Notice applies to www.libacapital.com and libacapital.com (including the LIBA Capital investor portal), getliba.si, app.libaiq.com (the live LIBA SI platform and sign-in), and related services that link to this Notice (collectively, the "Services").

LIBA Capital LLC is an independent real estate investment and operating company that uses LIBA SI technology under license. LIBA SI is the technology brand of LIBA Inc., a separate software company. LIBA Capital operates its real estate investment and investor-facing activities. LIBA Inc. develops and operates the LIBA SI technology and related platform services. Depending on the service and relationship, LIBA Capital and LIBA Inc. may each process information on their own behalf or as a service provider to the other.

This Notice does not replace any privacy notice, offering document, subscription agreement, customer agreement, or other document that applies to a specific investment, account, employment relationship, or contract. Where another notice or agreement applies, it controls to the extent of a conflict.

This Notice does not cover information about residents of, or rental applicants for, properties owned or operated by LIBA Capital. Residents and applicants should refer to the notices provided in connection with their tenancy or application, or contact us using the details below.

1. Information We Collect

Depending on how you use the Services, we may collect:

• Contact and account information: name, business name, title, email address, telephone number, mailing address, login credentials, and account identifiers.
• Investor identity and verification information: date of birth, residential address, government-issued identification documents, identity-verification (KYC) results, accredited-investor questionnaire responses, and supporting documents used to verify accredited-investor status, such as tax returns, account statements, entity documents, or confirmation letters from licensed professionals.
• Tax and financial account information: Social Security number or other taxpayer identification number, W-9 and other tax forms, and bank account details used to fund investments and receive distributions, where collected.
• Investment and transaction information: information submitted in connection with an inquiry, offering, subscription, electronic signature, investor communication, due-diligence review, or investment relationship.
• Property, deal, broker, and business information: deal submissions, broker or intermediary contact information, referral information, property details, and research and communications needed to evaluate a potential investment or business relationship.
• Property ownership and public-record information: information about property owners and related parties obtained from public records and commercial data sources, such as ownership, parcel, lien, and lawfully obtained pre-foreclosure records, used to identify and evaluate investment opportunities and for sourcing and outreach.
• Platform, device, and usage information: IP address, browser and device information, session and authentication data, security logs, cookie identifiers, pages or features used, and diagnostic information.
• Communications: messages, requests, support communications, and correspondence with us.
• Information from third parties: public records, service providers, identity-verification and accreditation-verification providers, professional advisers, referral sources, and other lawful sources.

Please do not send Social Security numbers, bank account information, payment-card numbers, or identity documents by ordinary email. We will provide a secure method when that information is needed.

2. How We Use Information

We use personal information to:

• operate, secure, maintain, and improve the Services;
• authenticate users, administer accounts, enforce access controls, and prevent fraud or misuse;
• respond to inquiries, evaluate investor, broker, owner, partner, and customer requests, and communicate with you;
• verify identity and accredited-investor status where required for an offering or related access;
• administer investment opportunities, subscriptions, distributions, tax reporting, due diligence, investor communications, and records;
• identify, research, and evaluate potential property acquisitions, including contacting property owners;
• conduct property, market, underwriting, and decision-intelligence analysis under human review;
• comply with law, legal process, regulatory obligations, recordkeeping obligations, and contractual commitments;
• protect the rights, safety, property, and security of LIBA, our users, investors, and others; and
• establish, exercise, or defend legal claims.

AI and decision intelligence. LIBA SI uses deterministic calculations and model-assisted analysis, including third-party AI model services, to organize evidence, calculations, and analytical context. LIBA SI does not make investment decisions, approve investors, or replace human legal, financial, compliance, underwriting, or investment judgment. Authorized people make those decisions.

3. Direct Investor Offerings and Broker Relationships

LIBA may communicate directly with prospective investors and may also receive inquiries, property opportunities, referrals, or other business information from brokers, intermediaries, owners, operators, and partners. We use information submitted through those channels to evaluate the relevant relationship, opportunity, transaction, or request and to communicate with the submitting person or organization.

Access to nonpublic offering materials, due-diligence materials, subscription documents, and investor reporting is restricted to authorized persons. Any offer or sale of a security or investment interest is made only through the applicable definitive offering documents and only to persons eligible under applicable law. Nothing in this Notice is an offer to sell, a solicitation to buy, or investment advice.

Where a broker or intermediary provides information about another person, the broker or intermediary is responsible for having an appropriate legal basis and any required permission to provide that information to LIBA. Brokers and intermediaries are not authorized to disclose restricted investor materials, confidential LIBA information, or another person's personal information beyond their authority.

4. Customer Data on the LIBA SI Platform

When an organization uses LIBA SI services and submits its own data to the platform, we process that data on the organization's behalf under our agreement with it. That organization's own privacy notice governs its data. Individuals whose information is included in customer data should direct privacy requests to that organization; we will assist it as our agreement and applicable law require.

For enterprise customer-uploaded data, LIBA SI generally acts as a service provider/processor under the customer agreement, and the customer's privacy notice controls that data.

5. How We Disclose Information

We disclose personal information only as needed for the purposes above, including to:

• authorized LIBA personnel, principals, employees, and advisers with a legitimate need to know;
• service providers that support hosting, databases, authentication, storage, email, mapping, identity and accreditation verification, electronic signature, AI model services, security, diagnostics, document processing, and other operational functions, subject to contractual and security controls;
• fund administrators, tax preparers, auditors, professional advisers, insurers, lenders, and transaction participants where appropriate and lawful;
• government authorities, regulators, courts, or other parties when required by law or legal process, or to protect rights and safety; and
• a buyer, successor, or other participant in a merger, financing, acquisition, or similar corporate transaction, subject to applicable law.

Approved AI/model providers may process submitted information only to provide LIBA SI services, subject to contractual controls. LIBA does not permit approved AI/model providers to use Customer Data for model training unless expressly disclosed in the applicable customer agreement.

We do not sell personal information. If this practice changes, we will provide any notice and choice required by law before doing so.

6. Sensitive Information and Investor Materials

Government identification, Social Security and taxpayer identification numbers, date of birth, bank account details, financial supporting documentation, identity-verification records, and accredited-investor information are sensitive. We limit access to authorized personnel and service providers with a legitimate operational, legal, or compliance need, and we use this information only for verification, fraud prevention, account security, legal and tax compliance, investment administration, and recordkeeping.

Access to investor materials on the platform requires an authenticated, authorized account. Sensitive investor documents, contracts, downloads, signing, funding, and distribution features require authenticated, authorized access and AAL2/multi-factor authentication where enabled by the platform. We do not make offering materials, investor documents, or subscription documents available to the general public.

7. Cookies and Similar Technologies

LIBA uses cookies and similar technologies, such as browser storage, as described in this Notice to operate the Services, maintain sign-in and security, remember necessary settings, and diagnose reliability issues. Our hosting and security providers may use similar technologies to deliver and protect the Services. We will update this Notice if we introduce analytics, advertising, session-replay, or similar tracking technologies.

You can control cookies through your browser settings, but disabling certain cookies may prevent sign-in or other features from working.

8. Retention

We keep personal information only as long as reasonably necessary for the purposes in this Notice, including to provide the Services, maintain security and audit records, meet legal, tax, securities, anti-fraud, and recordkeeping obligations, resolve disputes, and enforce agreements. Retention periods vary by type of information and relationship. Investor verification, subscription, and tax records are generally kept for the periods required by securities, tax, and anti-fraud law. Information subject to a legal hold is kept until the hold is released.

9. Security

LIBA uses access controls, authentication, multi-factor authentication for protected access, audit logging, and other safeguards designed to protect personal information.

No system is completely secure. You are responsible for protecting your account credentials and should notify us promptly if you suspect unauthorized access to your account.

10. Your Privacy Choices and Rights

Depending on where you live and the law that applies, you may have rights to access, correct, delete, or receive a copy of your personal information, to receive information about how we process it, to opt out of certain processing, to limit certain uses of sensitive personal information, and to appeal a decision about your request.

To make a request, email investors@libacapital.com or write to the address below with the subject line Privacy Request. We may need to verify your identity, and the authority of anyone acting for you, before we act on a request. An authorized agent may submit a request where permitted by law.

We may keep some information, or be unable to delete it, because of legal, securities, tax, fraud-prevention, security, dispute-resolution, or recordkeeping obligations. Where required by law, we will explain any such limitation.

We will not discriminate against you for exercising privacy rights available under applicable law.

11. U.S. State Privacy Rights

Residents of certain U.S. states, including California, may have additional privacy rights. To the extent a state privacy law applies to LIBA, you may use the request process in Section 10 to exercise those rights, including requests for information about the categories of personal information we collect, use, disclose, and retain, and requests for correction or deletion.

LIBA does not sell personal information as that term is defined in U.S. state privacy laws. If this changes, we will provide any required notice and opt-out mechanism.

12. Financial Privacy and Securities Matters

This Notice does not replace any privacy notice, offering document, subscription agreement, or disclosure required by securities, financial-services, or investment-adviser law. If LIBA or an affiliate is subject to Regulation S-P, the Gramm-Leach-Bliley Act, the FTC Safeguards Rule, or other financial-privacy requirements, we will provide the additional notices and rights those laws require.

13. International Users

The Services are intended for use in the United States, and we process and store information in the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the United States, where privacy laws may differ from those in your country. Where the law of your country requires additional safeguards for that transfer, we will apply them.

14. Children

The Services are not directed to individuals under 18, and we do not knowingly collect personal information from them. If you believe someone under 18 has provided personal information to us, contact us and we will take appropriate steps.

15. Third-Party Links

The Services may link to third-party websites, applications, data sources, or services. Their privacy practices are governed by their own notices, not this Notice, and we are not responsible for them.

16. Changes to This Notice

We may update this Notice from time to time. We will post the revised Notice on this page and update the "Last updated" date. Where required by law, we will provide additional notice or obtain consent before applying a material change.

17. Contact Us

For privacy questions or requests: