This California Privacy Policy (the "Policy") supplements the Online Privacy Policies of Headlands Technologies LLC ("HT") and Headlands Tech Global Markets, LLC ("HTGM") and their affiliates (collectively, "we," "us," or "our") and applies solely to users, visitors, business partners, employees, candidates, and others who reside in the State of California ("consumers" or "you"). This Policy has been adopted to comply with the California Consumer Privacy Act of 2018 (the "CCPA") and other California Privacy laws. Any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information that is lawfully made available from federal, state, or local government records.
• Deidentified or aggregate consumer information.
• Information specifically excluded from the CCPA’s scope, including:
• protected health or medical information collected by a covered entity under the Confidentiality of Medical Information Act or governed by the privacy, security, and breach notification rules under the Health Insurance Portability and Availability Act of 1996 ("HIPAA");
• personal information covered by certain other privacy laws, including the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA"), California Financial information Privacy Act ("FIPA"), and the Driver’s Privacy Protection Act of 1994.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our business partners or counterparties, or their agents. For example, from documents that our counterparties provide as part of our Customer Identification Program.
• Indirectly from our business partners or counterparties, or their agents. For example, through information we collect from our business partners during the course of consuming or providing services.
• Directly and indirectly from activity on our websites (www.headlandstech.com; www.htglobalmarkets.com). For example, from interactions through the HTGM website portal or website usage details collected automatically.
• Directly from our employees. For example, through information collected to maintain a complete employee personnel file.
• Directly or indirectly from recruiting candidates. For example, through a resume submitted by a candidate or a third-party recruiter.

We do not and will not knowingly collect, disclose, or sell data relating to children, that is, individuals under the age of 16 years.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information as part of an employment application, we will use that information to evaluate your background and credentials in considering you for employment.
• To provide you with information, products, or services that you request from us.
• To maintain an accurate and up to date personnel file.
• To evaluate and identify candidates for recruitment.
• To conduct due diligence and KYC procedures.
• To meet our financial obligations.
• To facilitate employee background checks.
• To verify employment eligibility.
• To determine benefits eligibility.
• To comply with regulatory requirements (e.g., fingerprinting).
• To facilitate employee expense reimbursement.
• To provide access to office locations.
• To improve our websites and present their contents to you.
• As necessary or appropriate to protect the rights, property, or safety of us or others.
• To respond to law enforcement requests and as required by applicable law, court order, or government regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates
• Service providers
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

We do not and will not sell any personal information. In the preceding twelve (12) months, we have not sold any personal information.

Your Rights

The CCPA grants consumers (i.e., California residents) certain rights regarding their personal information. This section describes your rights under the CCPA and explains how you can exercise those rights.

Right to Access Specific Information and Data Portability

You have the right to request that we disclose which of your personal information we have collected or used over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share your personal information.
• The specific pieces of information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, we will identify the personal information categories that were disclosed to each category of recipient.

Right to Request Deletion of Personal Information

You have the right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions. After we receive and confirm your verifiable consumer request, we will delete, and/or we will direct our service providers to delete, your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal or regulatory obligation (e.g. litigation holds, document retention requirements).
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

• Calling us at (888) 611-4611
• Visiting www.headlandstech.com or www.htglobalmarkets.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for disclosure of personal information collected twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We aim to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA we will not:

• Deny you goods or services.
• Provide you a different level or quality of goods or services.

Changes to our Privacy Policy

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post a notice on our website.

Contact Information

If you have any questions or comments about this Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Updated: December 2019