Effective Date: January, 2023

Focus Media, Inc. (“we”, “us”, or “our”) provides this Privacy Policy (this “Policy”) to inform you about our collection, use, disclosure, and storage of data about you that we collect via this website, the Focus Media, Inc. platform, and the related services and offerings available on it (collectively, the “Platform”). Please review this Policy carefully. By registering an account for the Platform (whether as an investor, allocator, manager, or other user), or otherwise using the Platform, you agree to the terms and conditions of this Policy. We may update this Policy from time to time in our discretion, for example to keep up with changing laws regarding data processing. We will always keep the current version of this Policy posted on our website. By using the Platform after a new version of this Policy has been posted, you agree to the terms and conditions of such version of this Policy.

PUBLIC POSTINGS
Please keep in mind that certain information submitted to the Platform is publicly visible to other users within the Platform. For example, investor or allocator users may be able to view managers’ performance data in the Platform, and manager users may be able to view investors’ or allocators’ investment preferences in the Platform.

DATA WE COLLECT
“Personal Data” means information that can be used to identify you, and may include your name, email address, phone number, mailing address, birthdate, photograph, etc. We collect Personal Data that you voluntarily provide us, for example when you register a user account, sign up for mailing lists or newsletters, register or pay for an event, verify your eligibility as an investor or manager, or otherwise reach out to us. Your submission of Personal Data is voluntary, but we may be unable to provide you requested information or services if you choose not to provide necessary Personal Data.

The Platform may offer you the ability to log in with, or otherwise connect, your third-party social media accounts. If you choose to use such social media accounts in this manner, you agree that we and the applicable third-party social media provider may exchange Personal Data to fulfill the purpose of the connection.

“Other Information” means information that does not identify you personally, and may include technical details regarding the device you use to access the Platform, IP address, operating system, browser, referral URLs, page views, location data (if location services are enabled), clicks, etc. Our systems automatically collect this kind of Other Information when you interact with the Platform. Other Information also includes information that may originally have been Personal Data but has been aggregated or anonymized such that it cannot be used to identify any individual.

COOKIES & SIMILAR TECHNOLOGY
We use “cookies” to obtain certain types of data when your web browser accesses our website. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to enable our system to recognize you and your personalized settings, to better understand how you interact with the Platform, to monitor aggregate usage, and to optimize web traffic routing on our website. Most browsers have settings to disable or limit cookies, but please note that certain areas or features of the Platform may not be available or fully-functional if you choose to disable cookies for our websites. We may also use pixel tags, web beacons, or similar technologies to understand how our users interact with our sites and emails. Our website does not respond to “do not track” signals.

USE OF YOUR DATA
We use your Personal Data:

• for the purposes for which you provided it to us (e.g., to create or update your user account, register you for promotions, newsletters, or events, or process a transaction, as applicable);
• to verify your eligibility as a manager or investor;
• to respond to your inquiries and communications to us;
• to improve, maintain, and operate the Platform;
• to inform you about opportunities, events, or services in which you may be interested, including those offered by our affiliates;
• to investigate and prevent possible fraud;
• to exercise or defend our rights and comply with statutory and regulatory requirements, including responding to lawful requests for information by governmental authorities; and
• for other reasons with your prior consent.

You can opt out of receiving promotional or marketing emails from us at any time by clicking the unsubscribe, opt-out, or similar link at the bottom of any such emails. Please note we may still contact you in connection with your account or any transactions involving you.

We may use Other Information (which does not identify you personally) for any manner we deem appropriate, including without limitation to improve, maintain, and operate the Platform.

DISCLOSURE OF YOUR DATA
We will not sell your Personal Data to third parties. We may share your Personal Data with our affiliates and as needed to fulfill the purposes described in the “USE OF YOUR DATA” section above, including:

• with managers or investors with whom you may wish to communicate;
  with a third party involved in hosting or supporting an event using the Platform;
• with our service providers, such as email service providers, customer support providers, and payment processors, who are only permitted to use the data on our behalf;
• as necessary to exercise or defend our rights or comply with applicable law or orders from law enforcement and other governmental authorities; and
• to other third parties with your prior consent.

Additionally, in the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets that would generally be transferred is the data we have collected, which would be transferred subject to the applicable version of this Policy.

We may disclose Other Information (which does not identify you personally) to any parties and for any purposes we deem appropriate.

LOCATION; DATA RETENTION, ACCESS, & CORRECTION; SECURITY
We are based in the United States. By using the Platform, you consent to your Personal Data being transferred to and stored in the United States. We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements. You may access and update your Personal Data by visiting your account profile.

We have implemented reasonable physical, organizational, and technical procedures to secure the Personal Data we have in our possession. Unfortunately, no measures can be guaranteed to provide 100% security when dealing with internet connections.

YOUR CALIFORNIA PRIVACY RIGHTS
California law entitles California residents to certain additional protections regarding Personal Data. For purposes of this section alone, “CCPA Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

We collect the following categories of CCPA Personal Information: identifiers, commercial information, Internet or other electronic network activity information, and geolocation data. We collect, use, and disclose CCPA Personal Information in the ways described above in our Privacy Policy. We do not sell CCPA Personal Information to third parties. California residents have the following rights to the extent granted by applicable law:

• information regarding your CCPA Personal Information we have collected in the past 12 months (including the categories of CCPA Personal Information we have collected, the categories of sources of such information, and the purposes for which we have collected such information);
• notice of whether we have disclosed your CCPA Personal Information to third parties in the past 12 months (and if so, what categories of information we have disclosed, and what categories of third parties we have disclosed it to);
  a copy of your CCPA Personal Information collected by us in the past 12 months; and
  that your CCPA Personal Information be deleted.

We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee to the extent permitted by law.

YOUR EUROPEAN UNION & SWISS PRIVACY RIGHTS
If you are a European Union or Swiss resident, applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data. To the extent established under applicable law, European Union or Swiss residents may have the right:
to access, review, and update their Personal Data;

• to restrict our processing of their Personal Data;
• to request that we provide them a copy of, or access to, their Personal Data in structured, commonly used and machine-readable format (or that we transfer their Personal Data to another controller, when technically feasible);
• to withdraw their consent when our processing of their Personal Data is based on consent (and not another legitimate basis);
• to request that we delete their Personal Data (subject to certain limitations); and
• to lodge a complaint with the applicable supervisory authority in the EU. Before you do this, we ask that you please contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

To make any of the above requests, please contact us as set forth at the end of this Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee to the extent permitted by law.

CHILDREN
The Platform is not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information, the parent or guardian should contact us as set forth at the end of this Policy, and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable, legally required or permitted, retention standards).

THIRD PARTY SITES
The Platform may include links to third party sites and services. If you visit or use such third party sites and services, please be mindful that the relevant third party controls the cookies and other technologies it uses on its sites and how it collects, uses, and shares your Personal Data. This Policy only governs our own privacy practices; please review the applicable third party privacy policy when visiting or using any third party sites or services.

CONTACT
For more information or for help in answering any questions, please contact us at [email protected]