Breakwall Investments ("Breakwall," "we," "us," or "our") is committed to protecting the privacy of individuals who visit our website and of our investors, prospective investors, and business contacts. This Privacy Policy describes how we collect, use, store, and share personal information through our website at breakwallinvestments.com (the "Site") and through our investor communications and operations.

Because Breakwall Investments operates in the private real estate investment space, this policy addresses not only general website visitors but also the personal information of accredited investors, prospective investors, and their representatives who engage with us in connection with investment opportunities. Please read this policy carefully.

1. Scope of This Policy

This Privacy Policy applies to:

•       Visitors to the Breakwall Investments public website at breakwallinvestments.com.

•       Prospective investors who contact us through the Site or by email, phone, or in person to inquire about investment opportunities.

•       Current and former investors who have invested in Breakwall-sponsored investment vehicles and who access the investor portal or receive investor communications from us.

•       Business contacts, service providers, and professional counterparties whose personal information we process in connection with our operations.

This policy does not apply to information collected through the AppFolio Investment Management portal (investors.appfolioim.com/breakwall/investor/login), which is a third-party platform operated by AppFolio, Inc. subject to AppFolio's own privacy policy. It does not apply to the privacy practices of portfolio property management companies or co-investors.

2. Information We Collect

2.1 Information You Provide to Us

We collect personal information that you voluntarily provide when you interact with us, including:

•       General inquiries: When you contact us through the Site, we collect your name, email address, phone number, company or organization name, and the content of your message.

•       Investor inquiries and onboarding: When you express interest in investing with Breakwall or proceed through our investor onboarding process, we collect information including your full name, mailing address, email address, phone number, professional background, net worth and income information (for accredited investor verification purposes), Social Security number or taxpayer identification number, bank or wire transfer information, and investment objectives and experience.

•       Investor portal: When you register for or use the AppFolio investor portal, you provide information directly to AppFolio. We receive investor data from AppFolio in connection with investment management. See Section 4 and Section 10 for more information about AppFolio.

•       Communications: We collect the content of emails, letters, and other communications you send to us, including in connection with investor relations, distributions, tax documents, and capital calls.

•       Tax and regulatory compliance: We collect tax identification information (Form W-9 or W-8 series) and other documentation required for IRS reporting and regulatory compliance.

2.2 Accredited Investor Verification

Federal securities law requires that investors in certain private offerings qualify as "accredited investors" as defined under SEC Rule 501 of Regulation D. In connection with any investment opportunity, we collect documentation sufficient to verify accredited investor status, which may include:

•       Income verification: Tax returns, W-2s, or letters from licensed professionals (CPA, attorney, broker-dealer) confirming income.

•       Net worth verification: Bank or brokerage statements, appraisals, or professional letters confirming net worth.

•       Professional credentials: Evidence of Series 7, 65, or 82 licensure, or knowledgeable employee status, where applicable.

This information is collected, used, and retained solely for accredited investor verification and regulatory compliance purposes. It is treated with the highest level of confidentiality and is not used for any other purpose without your consent.

2.3 Information Collected Automatically

When you visit our Site, certain technical information is collected automatically through our website platform (Squarespace) and any analytics tools we use, including:

•       Log data: IP address, browser type and version, pages visited, time and date of visit, and referring URLs.

•       Device information: Device type, operating system, and screen resolution.

•       Analytics data: Aggregate, anonymized data about Site traffic and usage patterns.

We do not use cookies or tracking technologies to build personal profiles of website visitors or to serve targeted advertising.

2.4 Information from Third Parties

We may receive personal information about you from third parties, including:

•       Referral sources: If you are referred to us by a broker-dealer, registered investment adviser, or other professional, we may receive your contact information from that source.

•       Background and verification services: We may use third-party services to verify accredited investor status, conduct background checks, or perform anti-money laundering (AML) / know-your-customer (KYC) screening as required by law or our internal compliance policies.

•       Co-investors and co-GPs: In joint venture structures, we may exchange investor information with co-investment partners as required to administer the investment vehicle.

3. How We Use Your Information

We use personal information for the following purposes:

3.1 Investment Operations

•       To evaluate and process expressions of interest in Breakwall investment opportunities.

•       To verify accredited investor status and satisfy subscription document requirements.

•       To administer investor capital accounts, process capital contributions and distributions, and maintain investor records.

•       To prepare and deliver K-1s, tax documents, financial statements, and other required investor communications.

•       To respond to investor inquiries and manage ongoing investor relations.

•       To comply with anti-money laundering (AML), know-your-customer (KYC), and other regulatory obligations.

3.2 Communications

•       To send investment updates, quarterly reports, distribution notices, and capital call notices to current investors.

•       To send information about new investment opportunities to prospective investors who have expressed interest, subject to applicable securities laws and your communication preferences.

•       To respond to general inquiries submitted through the Site.

 3.3 Site Operations

•       To operate, maintain, and improve our website.

•       To analyze aggregate usage patterns to improve the Site's content and functionality.

 3.4 Legal and Compliance

•       To comply with applicable federal and state securities laws and regulations.

•       To comply with tax reporting obligations (IRS Form 1099, Schedule K-1, FBAR, etc.).

•       To maintain records required by applicable law or our investment documents.

•       To protect against fraud, unauthorized access, and other illegal activity.

4. How We Share Your Information

We do not sell personal information. We share personal information only as described below.

4.1 Investment Administration

We share investor personal information with parties involved in administering investment vehicles, including:

•       AppFolio Investment Management: We use AppFolio IMS as our investor portal platform. Investor information accessible through the portal is processed by AppFolio subject to AppFolio's Privacy Policy and Data Processing Agreement. AppFolio is a data processor acting on our behalf.

•       Fund administrators and accountants: We may share investor information with our CPA firm, fund administrator, or third-party accountants for tax preparation, audit, and financial reporting purposes.

•       Legal counsel: We share investor information with our attorneys as necessary for fund formation, securities compliance, and transaction execution.

•       Lenders and title companies: In connection with property acquisitions financed with debt, we may share information about the investment entity and its investors as required by lenders or title insurers.

•       Co-investors and joint venture partners: In joint venture or co-investment structures, we share investor entity information (not individual investor personal data) with co-investment partners as required by the applicable operating agreement. Individual investor personal data is shared only to the extent required by the investment structure or applicable law.

4.2 CRM and Email Communications Platform

We use a customer relationship management (CRM) platform and/or email marketing platform to manage investor and prospect communications. [CONFIRM AND INSERT: Name the specific CRM and/or email platform used, e.g., HubSpot, Salesforce, Mailchimp, Constant Contact.] Personal information stored in these platforms is subject to those providers' privacy and security practices. We maintain data processing agreements with these providers requiring them to protect your information and use it only to provide services to us.

4.3 Legal and Regulatory Disclosure

We may disclose personal information as required by applicable law, including:

•       In response to subpoenas, court orders, or other legal process.

•       To comply with SEC, FINRA, Wisconsin DFI, or other regulatory inquiries or examinations.

•       To IRS and other taxing authorities as required for tax reporting.

•       To protect our legal rights or defend against legal claims.

4.4 Business Transfers

If Breakwall Investments or any of its investment vehicles undergoes a restructuring, merger, sale, or wind-down, investor personal information may be transferred as part of that transaction, subject to confidentiality obligations consistent with this policy.

5. AppFolio Investor Portal

Current investors access investment documents, capital account statements, K-1s, and distributions through the AppFolio Investment Management portal at investors.appfolioim.com/breakwall/investor/login. This portal is operated by AppFolio, Inc., an independent third-party technology company. Your use of the AppFolio portal is governed by AppFolio's Terms of Service and Privacy Policy, available at https://www.appfolio.com/privacy.

Breakwall Investments shares investor data with AppFolio as necessary to operate the portal and deliver investor account services. AppFolio processes this data as a service provider on our behalf under a data processing agreement. Breakwall remains responsible for the personal information we provide to AppFolio in connection with your investor account.

If you have questions about data held within the AppFolio portal, please contact us at the address in Section 11 and we will coordinate with AppFolio on your behalf.

6. Cookies and Tracking Technologies

Our public website uses cookies and analytics tools provided by Squarespace, our website platform. These tools collect aggregate, anonymized data about website traffic and usage patterns to help us understand how our site is being used.

Essential Cookies

Necessary for the Site to function. They support basic navigation and page rendering and cannot be disabled.

Analytics Cookies

Provided by Squarespace to collect aggregate, anonymized Site usage data. These cookies do not identify individual visitors personally and are not used to track investor behavior across other websites.

Managing Cookies

You can control cookies through your browser settings (Chrome: Settings > Privacy; Firefox: Options > Privacy & Security; Safari: Preferences > Privacy; Edge: Settings > Privacy). Disabling analytics cookies does not affect your ability to use the Site or access the investor portal.

7. Data Security

Given the sensitivity of investor financial information, Breakwall Investments takes data security seriously. We implement the following safeguards:

•       Access controls: Investor personal and financial information is accessible only to Breakwall personnel and service providers with a need to know for legitimate business purposes.

•       Encryption: Sensitive investor documents shared electronically are transmitted via encrypted channels. We do not request sensitive financial information (SSNs, bank account numbers) via unencrypted email.

•       Third-party security: We use established platforms (AppFolio, [CRM platform]) that maintain their own security certifications and practices.

•       Physical security: Paper records containing investor personal information are stored securely and disposed of through secure shredding.

No security measure is completely foolproof. If you believe your personal information or investor account may have been compromised, please contact us immediately at the address in Section 11.

Important notice: Breakwall Investments will never request sensitive investor information — including Social Security numbers, bank account details, or passwords — via unsolicited email or phone call. If you receive such a request purportedly from Breakwall, do not respond and contact us immediately.

8. Your Rights and Choices

8.1 Access, Correction, and Deletion

You may contact us at any time to request access to personal information we hold about you, request correction of inaccurate information, or request deletion of personal information no longer needed for legitimate business or legal purposes. We will respond within 30 days. Note that certain investor records must be retained for legal, tax, and regulatory compliance purposes and cannot be deleted on request.

8.2 Investor Communication Preferences

Current investors receive investment-related communications (capital calls, distribution notices, K-1s, investor reports) as required by their subscription agreements and applicable law — these cannot be opted out of while you hold an investment with Breakwall. For discretionary investor communications (market updates, new opportunity announcements), you may opt out by contacting us at the address in Section 11 or by clicking the unsubscribe link in any such email.

Prospective investors who have expressed interest in Breakwall opportunities may opt out of further communications at any time by contacting us or using the unsubscribe mechanism in any email we send.

8.3 California Residents — CCPA Rights

If you are a California resident, the CCPA as amended by the CPRA provides the following rights:

•       Right to Know: Request the categories and specific pieces of personal information collected about you in the past 12 months, the purposes of collection, and third parties with whom it was shared.

•       Right to Delete: Request deletion of personal information, subject to legal retention exceptions (including securities law and tax recordkeeping requirements, which override deletion requests for investor records).

•       Right to Correct: Request correction of inaccurate personal information.

•       Right to Opt Out of Sale or Sharing: We do not sell personal information and do not share it for cross-context behavioral advertising.

•       Right to Limit Use of Sensitive Personal Information: We use sensitive personal information (SSN, financial data) only for the purposes of investor onboarding and administration as described in this policy.

•       Right to Non-Discrimination: We will not discriminate against you for exercising CCPA rights.

To submit a CCPA request, contact us at the address in Section 11. We will verify your identity before processing the request and respond within 45 days.

8.4 European and International Investors

Breakwall Investments is a U.S.-based private real estate investment firm. Our operations and data processing occur primarily in the United States. If you are located in the European Economic Area (EEA), United Kingdom, or another jurisdiction with data protection laws, please note that by providing us with personal information you acknowledge that it will be processed in the United States.

If you are in the EEA or UK and have questions about your GDPR or UK GDPR rights, please contact us at the address in Section 11. We will work with you to address your request in accordance with applicable law.

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes in this policy or as required by law. Specific retention guidelines:

•       Investor subscription documents and accredited investor verification: Retained for the life of the investment plus a minimum of 5 years following full liquidation of the applicable investment vehicle, or longer as required by applicable securities law.

•       Tax records (K-1s, Form 1099, W-9): Retained for a minimum of 7 years in accordance with IRS recordkeeping requirements.

•       Investor capital account and transaction records: Retained for the life of the investment plus 7 years following wind-down.

•       Investor communications and correspondence: Retained for 5 years following the end of the investment relationship.

•       Prospective investor inquiry records: Retained for up to 3 years from the date of last contact, unless an investment relationship results.

•       Website analytics data: Aggregate or anonymized data retained indefinitely; identifiable log data retained for up to 12 months.

These retention periods reflect our obligations under federal and state securities laws, IRS regulations, and applicable statutes of limitation. Investor records subject to legal hold or ongoing regulatory inquiries are retained for the duration of the relevant proceeding.

10. Third-Party Links and Services

Our Site and investor communications may contain links to or references to third-party websites and services, including:

•       AppFolio Investment Management ( investors.appfolioim.com/breakwall/investor/login): Our investor portal platform. Governed by AppFolio's Privacy Policy.

•       Inland Companies (inlandcompanies.com): Our affiliated property management and commercial real estate parent company. Governed by Inland's Privacy Policy.

We are not responsible for the privacy practices of third-party sites. We encourage you to review their respective privacy policies before providing personal information.

11. Contact Us

For questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact us:

Breakwall Investments

833 E Michigan Street, Suite 520

Milwaukee, WI 53202

Phone: 414-278-6819

We will respond to general privacy inquiries within 30 days and to CCPA requests within 45 days. For urgent security concerns, please call us directly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the platforms we use. When we make material changes, we will update the "Last Updated" date above. For current investors, material changes to how we handle investor personal information will be communicated by email or through the investor portal.

Your continued use of our Site or continued participation as an investor following notice of any changes constitutes your acceptance of the revised policy.