Privacy Policy - HKN Energy

Last Updated: August 23, 2024

This Privacy Policy (or “Policy”) relates to the information collection and use practices of HKN Energy Ltd., an exempted company incorporated in the Cayman Islands with limited liability (“HKN,” “we,” “us,” or “our) in connection with this website (www.hknenergy.com) (the “Website”).

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to the Website (“Visitors,” “you,” or “your”).

This Policy applies to information we collect:

On this Website.
In email and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website (if applicable).

It does not apply to information collected by:

Us offline or through any other means, including on any other websiteoperated by Hillwood or any third party (including our parent company, affiliates, and subsidiaries); or
Any third party (including our parent company, affiliates, and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

The Information We Collect and How We Collect It

We collect several types of information from and about users of our Website, including information:

By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
That is about you but individually does not identify you; and/or
About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Specifically, in the course of operating the Website, we collect or otherwise receive the following types of information:

Contact Information

The contact information collected on our Website varies depending on the webpage but typically includes some combination of your name, email address, contact type, company information (including address), and any information you provide in messages to us. We use such contact information for business purposes such as responding to, and following up regarding, your inquiries, providing you with requested information, or sending you email alerts (including marketing emails, if you have elected to receive them). Depending on the nature of your message (e.g., inquiry regarding a property), we may route your information to an appropriate third party, such as an affiliate or contractor, to better address such message.

In some cases, such as where you sign up for a webcast, presentation, or other event/service, we may receive your contact information from a third-party website, including those white-labeled under our brand. Where we collect such contact information, our use of such contact information shall be pursuant to this Privacy Policy. In addition, please see Links to External Websites below for more information on submission of information to third party websites.

Server Logs

Like most websites today, we use web servers that keep log files that record data each time a device accesses those servers. These log files are maintained by our website hosting service and contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Website, or the pages you’ve clicked on while on our Website). We may wish to use these log files for purposes such as monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.

Cookies and Web Beacons

We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. Below is a general primer on session and persistent cookies. Information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

Session Cookies: We use session cookies to make it easier for you to navigate our Website. A session ID cookie expires when you close your browser.

Persistent Cookies:A persistent cookie remains on your hard drive (or other storage medium) for an extended period of time or until you delete them. To the extent we provide a log-in portal or related feature on our Website, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track analytics and target the interests of our Visitors to personalize the experience on our Website.

In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use.

Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Use of cookies on our Website includes, but is not limited to, the following:

Cookies for the “Contact Us” form and email alert form;

Cookies for Google Analytics functionality;

Cookies for Website announcements, such as banners/pop-ups; and
Web Beacons: Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

In addition to facilitating the purposes described above, cookies and web beacons are useful in understanding your engagement with other content related to our Website (e.g., email open rates, URL clickthroughs).

If you do not want us to place any cookies or web beacons on your device, you may be able to turn that feature off on your computer or mobile device. Please consult your browser’s documentation or your device for information on how to do this. However, if you decide not to accept cookies or beacons from us, certain aspects of the Website or emails may not function properly or as intended.

Third-Party Analytics

We use Google Analytics, a service provided by Google, Inc. (“Google”), as our third–party analytics service to evaluate our users’ of the Website by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links clicked, search terms, and other similar usage data) and analyzing performance metrics. Google Analytics uses cookies and other similar technologies (e.g., pixel tags) to help collect, analyze, and provide us reports or other data. The information generated by the cookie about your use of this Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Google also may transfer this information to third parties where required to do so by law or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website.

To learn more about Google Analytics visit: https://marketingplatform.google.com/about/analytics/. If you do not want us to collect this information, you may opt out at any time by changing your cookies and tracking settings on your computer or device and specifically opt-out of Google Analytics, by downloading the Google-provided browser add-on here: https://tools.google.com/dlpage/gaoptout.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Find Google’s privacy policy here.

Geolocation Information

We do not currently collect geolocation information. The features and functionalities of our Website are not based on your location.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Websiteand its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your inquiry.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Websiteor any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our Website or business.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Hillwood’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Hillwood about our Websiteusers is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Hillwood, our customers, or others.

Without limiting the foregoing, our disclosures may specifically include the following:

Aggregate Data

In an ongoing effort to better understand our Visitors and the Website, we might analyze your information in aggregate form to carry out, maintain, manage, and improve operations in connection with the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services and the Website to current and prospective business partners and to other third parties for other lawful purposes.

Business Transfers

In the event of a merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

Disclosure to Public Authorities

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Other Purposes

We may process your personal information for other purposes as otherwise disclosed to you (or pursuant to your consent) during your experience on, or in relation to, our Website.

Sharing with Third Parties

We engage other companies and individuals to perform certain business-related functions on our behalf in connection with our Website. Examples may include cloud storage and web hosting providers, distributors, technical assistance and security vendors, database management/back-up services, analytics services, email clients, digital marketing services (e.g., marketing automation), customer relationship management/CRM platforms, and customer service vendors. These other companies will have access to your information only as necessary to perform their functions and to the extent permitted by law. We may also share your information with any of our parent companies, subsidiaries, affiliates, or other companies under common control with us in order to support the purposes described in this Privacy Policy.

Opt-Out for Email Marketing and Certain Other Communications

You may also manage your receipt of marketing communications by clicking on the “Unsubscribe” (or similar) link located on the bottom of an applicable marketing email and following the instructions found on any page to which the link may take you.

You may also manage your receipt of press releases and other communications (e.g., SEC filings) that you’ve signed up to receive via email by clicking on the link on the bottom of such applicable email communication and following the instructions found on any page to which the link may take you.

You cannot opt out of receiving administrative or transactional e-mails. In all such cases, please allow us a reasonable time to process your request.

How We Protect Your Information

We take commercially reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.

Children

We do not knowingly collect personal information from children under the age of 13 through the Website. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information to us. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected] and we will endeavor to delete that information from our databases.

Important Notice to All Non-US Residents

Our servers are located in the US. Hillwood does not solicit visitors located outside the U.S., nor does Hillwood track its visitors located outside the U.S. on the internet and use personal data to:

Profile a visitor to make decisions concerning that visitor.
Analyze or predict that visitor’s personal preferences, behaviors, and attitudes.

We advise visitors outside of the U.S. not to use this Website. If you do so, however, to the extent permitted under applicable law, your decision to provide such data to us, or allow us to collect such data through our Website, constitutes your consent to this data transfer. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US.

Your California Privacy Rights

If you are a California resident, please see the Privacy Policy for California Residents regarding your rights and other information under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, see https://oag.ca.gov/privacy/ccpa.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please send an email to [email protected].

Nevada provides its residents with a limited right to opt-out of certain personal information sales. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Do Not Track Notice

We do not respond to or change our tracking practices in response to “Do Not Track” settings or other related mechanisms at this time.

Third parties that have services used on our site, such as an analytics service, may obtain information about your browsing or usage habits but this information does not include personal information. These third parties do not change their tracking practices in response to “do-not-track” signals from your web browser and we do not obligate these parties to honor “do-not-track” signals. To learn more about browser tracking signals and “Do Not Track”, please visit http://allaboutdnt.org.

Links to External Websites

The Website may contain links to third-party websites (“External Sites”). We have no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting or submitting any information through such External Sites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the ‘Last Updated’ date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By visiting the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your information is governed by the Privacy Policy in current effect. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, you may contact us by:

emailing us at [email protected] with “Privacy Policy” in the subject line.
Calling us at 1-833-676-2123
Contacting us through our Website at https://www.hknenergy.com/contact/

Effective Date: August 23, 2024

Last Updated on: August 23, 2024

This Privacy Policy for California Residents supplements the information contained in our standard Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (Proposition 24) (CPRA) and any terms defined in the CCPA or CPRA have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Sensitive Personal Information	(i) personal information that reveals a consumer’s: social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; or genetic data; (ii) contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (iii) biometric information processed for the purpose of uniquely identifying a consumer; and (iv) personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	NO
E. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
F. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
G. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
H. Geolocation data.	Physical location or movements.	NO
I. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
J. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
K. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
L. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

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

Directly from you. For example, from forms you complete or requests made by you.

Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

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

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to request a service, we will use that information to process your request. We may also save your information to facilitate new requests for services.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and, if applicable, to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your opt-in consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users and consumers are among the assets transferred.

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.

We will not re-identify deidentified personal information.

Retention of Personal Information

We retain all personal information for ____ years (DESCRIBE THE RETENTION PERIOD FOR EACH CATEGORY OF PERSONAL INFORMATION OR SENSITIVE PERSONAL INFORMATION, OR THE CRITERIA USED TO DETERMINE THE RELEVANT RETENTION PERIOD. THE CPRA PROHIBITS RETAINING PERSONAL INFORMATION OR SENSITIVE PERSONAL INFORMATION FOR TIME PERIODS LONGER THAN REASONABLY NECESSARY FOR EACH DISCLOSED COLLECTION PURPOSE (CAL. CIV. CODE § 1798.100(A)(3) (EFFECTIVE JANUARY 1, 2023)).).

Disclosure of Personal Information

We may disclose your personal information by providing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Hillwood has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information for any reason or share your personal information with third parties for the purpose of cross-contextual behavioral advertising. In the preceding twelve (12) months, Hillwood has not sold or shared the following categories of personal information to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A: Identifiers.	Affiliates, subsidiaries, service providers, contractors, and other third parties that support the Website or our business	None
B: California Customer Records personal information categories.	Affiliates, subsidiaries, service providers, contractors, and other third parties that support the Website or our business	None
C: Protected classification characteristics under California or federal law.	None	None
D: Sensitive Personal Information: (i) personal information that reveals a consumer’s: social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; or genetic data; (ii) contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (iii) biometric information processed for the purpose of uniquely identifying a consumer; and (iv) personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	None	None
E: Commercial information.	None	None
F: Biometric information.	None	None
G: Internet or other similar network activity.	Affiliates, subsidiaries, service providers, contractors, and other third parties that support the Website or our business	None
H: Geolocation data.	None	None
I: Sensory data.	None	None
J: Professional or employment-related information.	None	None
K: Non-public education information.	None	None
L: Inferences drawn from other personal information.	None	None

Your Rights and Choices

The CCPA/CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will disclose to you:

The categories and specific items 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 or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
For sales: the personal information categories sold and the categories of third parties receiving that information; and
For disclosures for a business purpose: the personal information categories disclosed and the categories of third parties receiving that information.
The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for business to business (B2B) personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for business to business (B2B) personal information.

Right to Correct

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the personal information’s processing purposes. Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception regarding this information applies. We will use commercially reasonable efforts to correct inaccurate personal information about you once we receive and verify your request.

Right to Opt-Out of Sharing Personal Information

We do not share your personal information with third parties for the purpose of cross-contextual behavioral advertising.

Right to Restrict Sensitive Information Processing

We do not collect or process Sensitive Personal Information.

Exercising Your Rights

To exercise your rights to know, right to correct, right to delete, or any other rights described above, please submit a request by either:

Calling us at 1-833-676-2123.
Emailing us at [email protected]
Contacting us through our Website at https://www.hillwood.com/contact/

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. To designate an authorized agent, please contact us as provided above. You may also make a request on behalf of your child by contacting us as provided above.

You may only submit a request to know twice within a 12-month period. Your 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 the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at [email protected], through our Contact Us page, or via our 1-833-676-2123.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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.

Personal Information Sales and Sharing Opt-Out and Opt-In Rights

We do not sell your personal information for any reason or share your personal information with third parties for the purpose of cross-contextual behavioral advertising. If at any time our uses change, we will update our policy to provide you with the right to opt-out.

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.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

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

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CCPA Rights Request Metrics

Metrics regarding the consumer rights requests we received from California residents from January 1, 2022 to December 31, 2022 appear in the following chart:

Request Type	Received	Granted (in whole or in part)	Denied	Average days to Respond
Requests to Know	-0-	N/A	N/A	N/A
Requests to Correct	-0-	N/A	N/A	N/A
Request not to Sell	N/A	N/A	N/A	N/A
Request not to Share	N/A	N/A	N/A	N/A
Request to Restrict Sensitive Information Processing	N/A
Requests to Delete	-0-	N/A	N/A	N/A
Requests to Opt-Out of Personal Information Sales	-0-	N/A	N/A	N/A

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]or write us at: 3000 Turtle Creek Blvd., Dallas TX 75219.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

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

Phone: 1-833-676-2123

Website: www.hillwood.com/contact

Email: [email protected]

Postal Address: 3000 Turtle Creek Blvd., Dallas TX 75219

If you need to access this Policy in an alternative format due to having a disability, please contact using our email [email protected], through our Contact Us page, or via 1-833-676-2123.