Privacy Policy

Effective Date: March 3, 2026

East5 LLC (“East5,” “Company,” “we,” “us,” or “our”) operates a restricted-access portal (the “Portal”) used by approved counterparties to evaluate potential life settlement acquisition opportunities.

This Privacy Policy describes how information is collected, used, transmitted, and protected in connection with the Portal.

By accessing or using the Portal, you acknowledge this Privacy Policy.

1. Scope

This Privacy Policy applies solely to information collected through the Portal. It does not govern information exchanged directly between transaction parties outside the Portal pursuant to separately executed agreements.

If a separately executed written agreement (including a Master Life Agreement or confidentiality agreement) exists between you and East5 LLC, that agreement controls in the event of conflict.

2. Information We Collect

We may collect and process the following categories of information:

Account Information

• Name
• Email address
• Organization
• Login credentials

Technical Information

• IP address
• Browser type
• Device information
• Access timestamps
• Login attempts and authentication logs

Portal Activity Information

• Policies viewed
• Selections or interest indications
• Notes entered within the Portal
• Document downloads
• Audit logs of user activity

Transaction-Related Information

• Underwriting materials transmitted for evaluation
• Mortality assessments (including reports generated by third-party providers such as eNoah)
• Medical summaries
• Identifying information provided by licensed brokers

3. Sensitive and Medical Information

The Portal may transmit identifying and health-related information contained in underwriting materials supplied by licensed life insurance brokers and third-party underwriting support providers.

East5 LLC:

• Does not originate medical records
• Does not create life expectancy reports
• Does not independently verify medical data
• Acts solely as a facilitator of information flow between authorized parties

Such information is transmitted strictly for transaction evaluation purposes under applicable contractual confidentiality obligations.

4. How We Use Information

We use collected information solely to:

• Provide and administer Portal access
• Facilitate evaluation of acquisition opportunities
• Coordinate communications with brokers and escrow agents
• Maintain security and audit logs
• Enforce contractual rights
• Detect and prevent unauthorized access or misuse

We do not use Portal data for marketing purposes unrelated to transaction evaluation.

5. Sharing of Information

We do not sell, rent, or monetize personal information.

Information may be shared only as necessary with:

• Authorized representatives of Buyer
• Licensed life insurance brokers
• Escrow agents or closing professionals
• Third-party underwriting support providers (e.g., eNoah)
• Hosting and infrastructure providers
• Technology vendors supporting secure Portal operation

All sharing is limited to what is reasonably necessary for evaluation and transaction processing.

6. Data Security

East5 LLC implements reasonable administrative, technical, and physical safeguards designed to protect information transmitted through the Portal, including:

• Password-protected access
• Role-based access controls
• Activity logging
• Encrypted data transmission (where applicable)

However, no electronic system can be guaranteed to be completely secure. Users are responsible for safeguarding credentials and maintaining the security of downloaded materials.

7. Data Retention

Information is retained only as long as necessary to:

• Fulfill evaluation purposes
• Comply with contractual obligations
• Maintain audit records
• Resolve disputes
• Satisfy legal requirements

East5 LLC may delete or archive Portal data at its discretion, subject to applicable agreements.

8. User Responsibilities

Users agree to:

• Maintain confidentiality of login credentials
• Restrict access to authorized representatives
• Protect downloaded underwriting materials
• Promptly notify East5 LLC of suspected unauthorized access

Unauthorized forwarding, copying, or distribution of underwriting materials may violate contractual and legal obligations.

9. No Public Portal

The Portal is not a public website and is accessible only to approved users pursuant to executed agreements. It is not intended for consumer use.

10. Governing Law

This Privacy Policy is governed by the laws of the State of Florida.

11. Changes to This Policy

East5 LLC may update this Privacy Policy from time to time. Continued use of the Portal after updates constitutes acceptance of the revised policy.