This Privacy Policy explains how Asteroid Property Management, Inc. d/b/a Locke Alliance (“Locke Alliance,” “we,” “us,” or “our”) collects, uses, shares, and protects information in connection with our website at lockealliance.com, our capital pre-qualification application, and related services (collectively, the “Services”). It works alongside our Terms & Conditions, including the mutual confidentiality obligations in Section 9 of those Terms.

1. Introduction and Scope

This Policy applies to information we collect through the Services, including information that property management companies and their principals provide when they request a business valuation or pre-qualify for growth capital. It does not apply to the practices of third parties we do not control, or to information governed by a separate written agreement between you and Locke Alliance, which controls to the extent of any conflict with this Policy.

2. Information We Collect

2.1 Information you provide.

When you use our application or otherwise contact us, you may provide, and we collect:

• Company and contact details: your company’s legal name, your name, title, work email, phone number, website, and primary market(s).

• Portfolio profile: number of doors managed, company type, property types managed, and property management software platform.

• Financial and operating metrics: gross management revenue and variance, average occupancy, on-time rent collection rate, largest owner concentration, estimated EBITDA or SDE margin, and any rent roll or cash flow documents you upload.

• Legal and standing disclosures: information about pending litigation, liens, regulatory actions, and whether significant owners will accept personal guarantees.

• Capital interest: prior capital-raising history, target timeline, and intended use of proceeds.

• Communications: the content of messages you send us and records of your interactions with our team.

2.2 Information collected automatically.

When you visit the Services, we and our service providers automatically collect certain technical information, such as your IP address, device and browser type, pages viewed, referring pages, and dates and times of access. We collect this information using cookies and similar technologies described in Section 4.

2.3 Information from other sources.

We may receive information about you or your company from service providers that help us operate the Services, from publicly available sources, and from references or advisors you identify to us. As part of the pre-qualification, we do not perform a consumer credit check; any credit, background, or verification checks would occur only later, with your knowledge, under a separate written agreement.

3. How We Use Your Information

We use the information we collect to:

1. evaluate your application, prepare a business valuation, and determine capital pre-qualification;

2. communicate with you about your application, respond to your inquiries, and provide related information and materials;

3. conduct due diligence and, where applicable, negotiate and administer a potential financing or membership relationship;

4. operate, maintain, secure, and improve the Services and develop new features;

5. detect, prevent, and address fraud, security incidents, and misuse; and

6. comply with legal obligations and enforce our Terms & Conditions and other agreements.

4. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Services, remember your preferences, measure site traffic, and understand how the Services are used. Some cookies are necessary for the site to function; others help us with analytics and performance. You can control cookies through your browser settings, though disabling some cookies may affect how the Services work.

Do Not Track and Global Privacy Control. Some browsers offer a “Do Not Track” signal. Because there is no common industry standard for responding to Do Not Track signals, the Services do not currently respond to them. Where required by applicable law, we honor recognized universal opt-out mechanisms such as the Global Privacy Control (GPC) as an opt-out of any sale of personal data or processing for targeted advertising.

5. How We Share Your Information

We do not sell your personal data, and we do not use it for targeted advertising or cross-context behavioral advertising. We share information only as described below:

• Service providers. With vendors who perform services for us, such as website and form hosting, cloud storage, email delivery, and analytics, under contracts that require them to protect the information and use it only for our purposes.

• Professional advisors. With our attorneys, accountants, and consultants as needed to evaluate your application and operate our business.

• Affiliates and financing partners. With our affiliates and, where relevant to your application, potential financing partners, co-investors, or lenders, subject to confidentiality obligations.

• Legal and safety. When we believe disclosure is required by law or legal process, or to protect the rights, property, or safety of Locke Alliance, our users, or others.

• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to confidentiality obligations.

• With your direction. With other parties when you ask us to or otherwise consent.

6. Confidentiality of Application Data

We understand that the financial and operating information you share through the application is sensitive. In addition to this Policy, the information exchanged between you and Locke Alliance in connection with your application is protected by the mutual confidentiality obligations in Section 9 of our Terms & Conditions, which limit how each party may use and disclose the other’s confidential information.

7. Data Retention

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, including to evaluate and, where applicable, administer a relationship with you, and to comply with our legal, accounting, and reporting obligations. Where an application does not proceed, we retain the related information only for a reasonable period consistent with those purposes, after which we delete or de-identify it.

8. Data Security

We maintain administrative, technical, and physical safeguards designed to protect the information we collect, including encryption of data in transit and access controls that limit access to those who need it. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping any credentials associated with your use of the Services confidential.

9. Your Privacy Choices and Rights

9.1 Communications.

You can ask us to stop sending non-essential communications at any time by contacting us at hello@lockealliance.com. We may still send you messages necessary to administer your application or our relationship.

9.2 Cookies.

You can manage cookies through your browser settings as described in Section 4.

9.3 Texas residents.

To the extent the Texas Data Privacy and Security Act applies to us, Texas residents have the right to: (a) confirm whether we process their personal data and access that data; (b) correct inaccuracies; (c) delete personal data; (d) obtain a portable copy of personal data they previously provided; and (e) opt out of the sale of personal data, targeted advertising, and certain profiling. As noted in Section 5, we do not sell personal data or use it for targeted advertising. We will not discriminate against you for exercising these rights.

9.4 How to exercise your rights.

To exercise any of these rights, contact us at hello@lockealliance.com or at the address in Section 14. We will respond within the time required by applicable law, generally within 45 days, with an extension where permitted. If we decline your request, you may appeal that decision by replying to our response or contacting us at the same address, and we will respond to your appeal within 60 days. We may need to verify your identity before acting on a request.

Residents of other states may have similar rights under their own laws. We will honor those rights to the extent they apply to us.

10. Children’s Privacy

The Services are intended for businesses and professionals and are not directed to children under 18. We do not knowingly collect personal data from children under 18. If you believe a child has provided us personal data, contact us and we will take appropriate steps to delete it.

11. Where Your Information Is Processed

We are based in the United States, and we and our service providers process and store information in the United States. If you access the Services from outside the United States, you understand that your information will be processed in the United States, where data protection laws may differ from those in your location.

12. Third-Party Links

The Services may link to third-party websites or services we do not control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third party before providing your information.

13. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the “Last updated” date above and, where appropriate, provide additional notice. Changes are effective when posted. Your continued use of the Services after changes become effective constitutes your acceptance of the revised Policy.

14. How to Contact Us

Questions about this Policy or your personal data may be directed to:

Asteroid Property Management, Inc. d/b/a Locke Alliance
Attn: Privacy
816 Congress Ave, Suite 700
Austin, TX 78701
Email: hello@lockealliance.com