IMPACT MARKETPLACE PRIVACY POLICY

Last Updated: September 1, 2026

Impact Marketplace, LLC (“Impact”, “we,” “our,” or “us”) is a business-to-business (B2B) platform that facilitates New Markets Tax Credit (NMTC) investment relationships and provides a consolidated data-tracking platform for investment activity. We are committed to safeguarding your privacy in our various interactions with you, including your use of our websites located at https://www.impactmarketplace.com/ and https://www.platform.impactmarketplace.com (collectively, the “Site” or “Services”).

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Site or use our Services. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Site or use the Services.

We may change this policy from time to time so please check back often. If we significantly change our collection, use, or disclosure practices, we may send you an updated notice via email if you have provided us with an email address.

Personal Information We Collect

“Personal information” means any 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 or household. Personal information does not include information that has been deidentified or aggregated as permitted by applicable law.

We may collect the following categories of personal information in connection with our Services:

·         Identifiers – Name, email address, postal address, IP address, account name, and online identifiers.

·         Contact and Business Relationship Information – Business or organizational affiliation, job title, department, business address, business email, business phone number, information about your professional role or relationship with us, marketing and communication preferences, event attendance records, and information about your interactions with our marketing materials or communications.

• Communications and Inquiry Content. The content of messages, inquiries, correspondence, requests, forms, and other communications you submit or exchange with us through the Site, email, telephone, events, or other channels.

·         Internet and Electronic Network Activity Information – Browsing history on our Site, search history, cookies, device type and identification number, browser type, internet service provider, user language, screen resolution, connection type, operating system, date and time of visit, referring website, pages accessed, links clicked, and other technical information.

·         Geolocation Data – We collect location information (e.g., country or city-level location which we derive from other data). We do not collect precise GPS-level geolocation data.

·         Audio, Electronic, and Visual Information – We use chatbot tools and session replay analytics on our platform. Chatbot sessions may be recorded. Session replay tools capture user interactions as described in the “How We Collect Information” section below.

How We Collect Personal Information

We collect and receive personal information through the following methods:

• Directly From You. You may provide personal information to us directly when you submit an inquiry through our contact form, correspond with us by email, telephone, or mail, attend a conference, event, or meeting, enter into a contract or business relationship with us, or otherwise communicate or interact with us.
• From Your Browser or Device. When you access or interact with the Site, and were you opt-in, we may collect certain technical and usage data through cookies, pixels, tags, analytics technologies, advertising technologies, session analytics tools, and similar tracking technologies deployed on the Site.
• From Service Providers, Vendors, and Business Partners. We may receive personal information from service providers that support our operations, analytics and advertising partners, and other business partners in the ordinary course of our operations.
• From Publicly Available Sources, Referrals, and Professional Contacts. We may collect personal information from publicly available sources (such as professional networking platforms, business directories, and public records), from referrals, and from other professional contacts in connection with business development, relationship management, and similar activities.

Cookie Policy & Consent

We use an opt-in consent framework for cookies and tracking technologies. This means that, with the exception of strictly necessary cookies, we will not place cookies or activate tracking technologies on your device unless you have affirmatively consented to their use.

We may use the following categories of cookies and similar technologies on the Site:

• Strictly Necessary Cookies. These are essential for the operation of the Site and enable you to navigate and use its features. Strictly necessary cookies cannot be disabled.
• Performance and Analytics Technologies. These technologies help us understand how visitors use the Site, including pages viewed, links clicked, scrolling activity, navigation paths, session interactions, approximate time spent on pages, and similar usage information. These technologies may include session analytics, session replay, heat mapping, and similar tools.
• Advertising and Targeting Technologies. These are used to deliver advertisements that are more relevant to you and your interests, to limit the number of times you see a particular advertisement, to measure the effectiveness of advertising campaigns, and to support retargeting, audience building, attribution, and related advertising activities. Advertising and targeting technologies may be set by third-party advertising networks and platforms with our permission.

Managing Your Preferences

You can manage your preferences for non-essential cookies and tracking technologies through the following methods:

• Browser settings: Most browsers allow you to block or delete cookies. Please note that disabling cookies may affect the functionality of certain features of the Site.
• Cookie preference center: You may adjust your preferences through our cookie preference center accessible on the Site via the “Your Privacy Choices” link. The cookie preference center is also where you can opt out of the use of your personal information for sale or sharing and targeted advertising, as applicable.
• Opt-out preference signals: We honor recognized opt-out preference signals, such as Global Privacy Control (“GPC”), as requests to opt out of targeted advertising and the sale or sharing of personal information for the applicable browser or device, and where we can reasonably associate the signal with you, for your consumer profile.
• Industry opt-out tools: You may opt out of interest-based advertising through participating advertising networks by visiting the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.

How We Use Your Personal Information

We may collect, use, and otherwise process personal information for the following purposes:

• Operate and Improve the Site. To provide, maintain, and improve the Site, including monitoring performance, diagnosing technical issues, and enhancing functionality and user experience.
• Respond to Inquiries and Manage Communications. To respond to your questions, inquiries, and communications submitted through the Site, email, telephone, events, or other channels, and to route communications to the appropriate personnel or departments.
• Manage Business Relationships. To develop, maintain, and administer business relationships including communicating about services, coordinating engagements, and managing contractual obligations.
• Marketing and Business Development Communications. To send service-related communications and, where permitted by applicable law and consistent with your preferences, marketing, promotional, or business development communications about our services.
• Analytics and Measurement. To understand how visitors use the Site, measure Site and marketing performance, analyze trends, and support research and analytics purposes.
• Targeted Advertising and Retargeting. To deliver advertisements relevant to your interests, measure advertising effectiveness, support retargeting campaigns, build audiences, and conduct attribution analysis, where permitted by applicable law.
• Security and Fraud Prevention. To protect the Site and our operations, detect and prevent fraud, unauthorized access, and other misuse, and to maintain the integrity and security of our systems, facilities, and personnel.
• Legal Compliance and Claims. To comply with applicable legal or regulatory obligations, respond to legal process, cooperate with governmental authorities, and to establish, exercise, or defend legal claims, investigations, audits, and dispute resolution.
• Accounting, Finance, and Audit. To maintain financial records, process payments, conduct internal and external audits, and administer accounting, tax, and reporting functions.
• Business Operations and Transactions. To support general business operations, recordkeeping, and administration, and in connection with actual or proposed mergers, acquisitions, financings, reorganizations, or other corporate transactions.

How We Share Personal Information

We may share your personal information with the following categories of third parties:

o   Affiliates. We may share your personally identifiable information with our corporate affiliates.

o   Service Providers. We may engage other companies to provide limited services on our behalf, including Site development and operation, communicating with you or answering customer questions about the Services, analyzing Site use, processing payments, providing investor information and processing data.

o   Marketplace Participants. We may share your personal information with participants in the Impact Marketplace to facilitate NMTC projects.

o   Legal Requirements. We also may disclose your personal information to identify, contact or bring legal action, defend against legal claims or regulatory actions, respond to a subpoena, or cooperate with law enforcement.

o   Business Transfer. We may share your personal information in connection with a merger, acquisition, or sale of all or a portion of our assets.

o   Other Parties at Your Direction or With Your Consent. We may disclose personal information to other third parties where you direct us to do so or otherwise provide consent.

We may also use and disclose deidentified or aggregated information for lawful business purposes, including analytics, research, and reporting, provided such information cannot reasonably be used to identify you.

Your Privacy Rights

Depending on your state of residence, you may have certain rights regarding our collection and use of your personal information.

• Right to Access. You may request information about the personal information we have collected about you, including the categories, sources, purposes, and third parties with whom we have shared it.
• Right to Deletion. You may request that we delete personal information we have collected from you. We may retain certain information as permitted by applicable law.
• Right to Correction. You may request that we correct any inaccuracies in your personal information.
• Right to Opt Out of Targeted Advertising. You may opt out of the use of your personal information for targeted advertising purposes.
• Right to Data Portability. You may request a copy of your personal information in a portable and readily usable format.

Non-Discrimination

We will not discriminate against you for exercising your privacy rights. We will not deny you services, charge you different prices, or provide you a different level or quality of service for exercising any privacy right.

You may contact us at legal@impactmarketplace.com to inquire about or exercise the foregoing rights.

Security

We implement commercially reasonable security measures to protect your personal information, including password protection, encryption technology, Transport Layer Security (TLS) for data in transit, access controls, and AWS Cognito for secure authentication.

No data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or from our services, and you do so at your own risk.

Data Retention

We will retain your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, including to comply with our legal obligations, resolve disputes, and enforce our agreements. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

Children’s Privacy

Our website is not intended to solicit, collect or process personal information from any individual under the age of 18. If you are a parent or guardian, please contact us if you believe information regarding a child has been collected by us through our website.

Third-Party Links and Embedded Services

The Site may contain links to third-party websites, applications, or services that are not owned or controlled by us, including embedded content and functionality provided by third-party platforms. This Policy does not apply to any third-party websites, applications, or services. We encourage you to review the privacy policies of any third-party websites or services before providing personal information. Impact is not responsible for the privacy practices or content of third-party websites, applications, or services.

Changes to This Privacy Policy

Impact reserves the right to modify this Policy at any time. If we make changes to this Policy, we will post the updated Policy on the Site with a revised effective date. Where required by applicable law, we will provide additional notice or obtain consent before applying material changes to previously collected personal information. We encourage you to review this Policy periodically.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: legal@impactmarketplace.com

Impact Marketplace, LLC

8301 Maryland Avenue, Suite 350

St. Louis, MO 63105