Effective Date: January 1, 2026

1. Overview

Hutchlee Technologies, LLC (“Hutchlee,” “Company,” “we,” “us,” or “our”) values your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with (a) our public-facing websites and related sub-domains (collectively, the “Site”) and (b) the EquityBridgePro® software-as-a-service platform and related services (collectively, the “Services”).

Our operations and systems are based in the United States, and we generally process and store information in the United States.

2. Scope

This Privacy Policy applies when:

• You visit or interact with our Site;

• You contact us (including via forms, email, phone, webinars, demos, or events);

• You use the Services as an authorized user.

This Privacy Policy does not apply to information we process strictly on behalf of a government entity or other customer in our role as a service provider/data processor where the customer is the “controller” (i.e., the entity that determines how and why information is processed). In those cases, the customer’s privacy notice and instructions govern. If you are an end user accessing the Services through a county or other customer (for example, a petitioner or other participant), please direct privacy questions to that customer when applicable.

3. Definitions

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with a particular individual. It does not include aggregated or de-identified information.

4. Our Roles: Controller vs. Service Provider/Processor

Site Visitors and Prospective Customers. When you browse our Site or contact us directly, Hutchlee generally acts as a “controller” of your Personal Information.

Service Users (Government/Customer End Users). When you use the Services through a government entity or other customer, Hutchlee typically processes Personal Information on behalf of that customer as a service provider/processor, subject to the applicable contract (including any data processing addendum). In limited circumstances, we may use certain information as a controller for security, fraud prevention, service improvement, and related internal operational purposes, as permitted by law and contract.

5. Personal Information We Collect

We collect Personal Information from the following sources:

A. Information you provide to us

• Contact information (e.g., name, email address, phone number, organization, job title)

• Communications and requests (e.g., messages, support inquiries, demo requests)

• Event/webinar registration information (if applicable)

• Billing and transaction information (if we accept payments through the Site or Services) (note: payment card data may be handled by a payment processor)

B. Information collected automatically (Site/Services usage)

• IP address and approximate location derived from IP address (city/state level)

• Device and browser information, operating system, and settings

• Log data, clickstream data, pages viewed, referral URLs, and interaction data

• Cookies and similar tracking technologies (see Section 9)

C. Information we receive from third parties

• Business contact information from service providers, marketing partners, or publicly available sources (e.g., business directories), where permitted by law

• Information from customers’ account administrators to provision authorized access to the Services

Important: Please do not submit sensitive Personal Information (e.g., Social Security numbers, driver’s license numbers, financial account numbers, medical information) through general “Contact Us” forms unless specifically requested through a secure channel.

6. How We Use Personal Information

We use Personal Information for the following purposes:

• To operate, maintain, and improve the Site and Services;

• To respond to inquiries, provide customer support, and communicate with you;

• To provide demos, onboarding, training, and product updates;

• To manage accounts, authentication (including multifactor authentication if enabled), and access control;

• To monitor, prevent, detect, and investigate fraud, abuse, security incidents, and unlawful activity;

• To perform internal analytics and service improvement (including aggregated or de-identified analysis where feasible);

• To comply with legal obligations, enforce our agreements, and protect our rights and the rights of others;

• With your consent, to send marketing communications (you may opt out at any time).

Legal bases: Because we operate primarily in the United States, our processing is generally based on one or more of the following, as applicable: performance of a contract, our legitimate business interests, compliance with law, and/or your consent.

7. How We Disclose Personal Information

We do not sell your Personal Information.

We may disclose Personal Information to:

• Service providers and vendors that help us operate the Site and Services (e.g., hosting, analytics, customer support tools, email delivery, security monitoring), under contracts requiring appropriate confidentiality and security;

• Government entities or other customers (for example, where they are the controller and instruct us to process information on their behalf);

• Professional advisors (e.g., attorneys, auditors, insurers) where necessary for business purposes;

• Law enforcement, regulators, or other parties when required by law or when we believe disclosure is necessary to protect rights, safety, or prevent fraud;

• In connection with a corporate transaction (e.g., merger, acquisition, financing, or sale of assets), subject to appropriate protections.

We may also share aggregated or de-identified information that does not identify you.

8. Public Records Notice (Florida Government Customers)

If you interact with the Services in connection with a Florida governmental entity, certain records may be subject to disclosure under Florida’s public records laws (Chapter 119, Florida Statutes). The applicable governmental entity remains the custodian of its records and is responsible for responding to public records requests. Hutchlee acts as a service provider and does not determine whether particular records are subject to disclosure unless expressly agreed in writing.

If you have questions about public records applicable to your submission, contact the relevant government entity.

9. Cookies and Similar Technologies

We may use cookies and similar technologies to operate the Site, remember preferences, understand usage, and improve performance. Depending on your configuration, we may use analytics tools (such as Google Analytics or similar) to help us understand how visitors use the Site.

You can control cookies through your browser settings. If you disable cookies, parts of the Site may not function properly.

10. Marketing Preferences

You may opt out of marketing emails by using the unsubscribe link in our messages or by contacting us using the information in Section 16. We may still send you non-marketing communications, such as security notices or transactional/account messages.

11. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect Personal Information. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

12. Data Retention

We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law, contract, or to resolve disputes and enforce agreements. Where feasible, we may de-identify information for longer-term analytics and service improvement.

13. Your Privacy Rights and Choices

Depending on your state of residence and applicable law, you may have rights to request access to, correction of, deletion of, or a copy of certain Personal Information we hold about you, and to opt out of certain processing (such as targeted advertising, where applicable).

Florida residents: We will respond to verifiable consumer requests as required by applicable Florida law.

How to exercise rights: Please contact us using the information in Section 16. To protect your privacy, we may need to verify your identity before completing a request. If we process information on behalf of a government entity or other customer as a service provider/processor, we may refer your request to that customer when appropriate.

14. Children’s Privacy

The Site and Services are not directed to children under 13, and we do not knowingly collect Personal Information from children under 13. If you believe a child has provided Personal Information to us, please contact us and we will take appropriate steps.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Effective Date” above indicates when

this Privacy Policy was last revised. Your continued use of the Site or Services after an update constitutes your acceptance of the revised Privacy Policy to the extent permitted by law.

16. Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact:

Hutchlee Technologies, LLC

Attn: Privacy

[email protected]