Personal Information Does Not Include

x Publicly available information from government records.

x De-identified or aggregated consumer information.

x 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) or clinical trial 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.

RHI Obtains the Categories of Personal Information Listed Above From the Following Categories of Sources

Directly from consumers or their agents. For example, from conversations and discussions and from documents that RHI borrowers provide to RHI related to mortgage loan origination. Indirectly from consumers or their agents. For example, through information RHI collects and obtains during the mortgage loan origination process. Directly and indirectly from activity on our website (www.roxfordholdings.com). For example, from submissions through our website portal or website usage details collected automatically. From unaffiliated 3rd For example, an Appraiser or Appraisal Management Company.

Use of Personal Information

RHI may use or disclose the personal information it collects for one or more of the following business purposes:

To provide World Class Service in meeting the reason for which the information is provided. For example, if you provide RHI with personal information for RHI to originate, process, underwrite and close a mortgage loan, then RHI will use that information either partially or during the entire loan process life cycle. To provide you with information, products or services that you request from us. To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you. To improve our website and present its contents to you. As necessary or appropriate to protect the rights, property or safety of RHI, and past, present and future RHI clients or others. 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. To evaluate or conduct a merger, divestiture, or other sale or transfer of some or all of RHI assets, in which personal information held by RHI is among the assets transferred.

At all times relevant, RHI will not collect additional categories of personal information or use the personal information RHI collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

RHI may disclose your personal information to a third party for a business purpose. When RHI discloses personal information for a business purpose, the recipient is required to both keep that personal information confidential and not use it for any purpose. In the preceding twelve (12) months, RHI disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category I: Professional or employment-related information.RHI discloses your personal information for a business purpose to the following categories of third parties:

Our affiliates.Service providers.Third parties to whom you or your agents authorized RHI to disclose your personal information.

In the preceding twelve (12) months, RHI has not sold any personal information.

Your Rights and Options

The CCPA provides consumers (California residents, California property owners and those contemplating or purchasing California property) with detailed rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. RHI DOES NOT SELL, NOR DOES RHI INTEND TO SELL, YOUR PERSONAL INFORMATION TO THIRD PARTIES.

Access to Specific Information

You have the right to request that RHI disclose certain information to you about RHI’s collection and use of your personal information over the past 12 months. Once RHI is in receipt of and confirms your verifiable consumer request, RHI will disclose to you:

The categories of personal information RHI collected about you. The categories of sources for the personal information RHI collected about you. RHI’s business or commercial purpose for collecting that personal information. The categories of third parties with whom RHI shared that personal information. The specific pieces of personal information RHI collected about you. If RHI disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that RHI delete any of your personal information that RHI collected from you and retained, subject to certain Exceptions. Once RHI receives and confirms your verifiable consumer request, RHI will delete (and direct RHI’s service providers to delete) your personal information from RHI’s records, unless an Exception applies.RHI may not be in apposition to accommodate your request and RHI may deny your deletion request if retaining the information is required by other Federal and/or State laws, statutes, regulations or rules, which may be in conflict with or supersede the CCPA, or it is necessary for RHI or our service providers to:

Complete the transaction for which RHI collected the personal information, provide a service that you requested, or perform or take actions reasonably anticipated within the context of RHI’s ongoing business relationship with you. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 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 ).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.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access and/or deletion rights described above, please submit a verifiable consumer request to us by either:

Calling RHI corporate headquarters at 888.466.5422 Visiting roxfordholdings.com and scrolling to the bottom of the Main Landing Page and selecting the link for Legal + Privacy.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request should:

Provide enough information that permits RHI to reasonably verify you are the person about whom RHI collected personal information.Describe your request with details that allows RHI to properly understand, evaluate, and respond to it.

RHI cannot timely or accurately respond to your request or provide you with personal information if RHI cannot verify your identity or authority to make the request and confirm the personal information relates to you. PLEASE be advised that submitting a verifiable consumer request does not require you to create an account with RHI. RHI will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

RHI will use best efforts and diligently respond to a verifiable consumer request on or before 45 days of receipt. Should unusual circumstances dictate that additional time (up to 90 days) is warranted, RHI will inform you of the reason and extension period in writing. RHI will deliver a written response by mail or electronically, at RHI’s option. Any disclosures RHI provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. RHI’s response may also explain the reason(s) that RHI cannot comply with a request, if applicable. At this time and until further notice, RHI does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, malicious, repetitive, harassing in nature or manifestly unfounded. If RHI determines that the request warrants a fee, RHI will tell you why RHI made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

RHI does not and will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, RHI 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.

Changes to Our Privacy Notice

RHI reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

Should you, the California consumer, have any questions, concerns or comments about RHI’s California Privacy Policy, the manner in which RHI collects and/or uses your personal information, your choices and rights regarding such use, or desire to exercise any and or all of your rights, either singularly or combined, under California law, kindly contact us by either or all of the below 4 methods at:

Phone:888-466-5422 (to ensure prompt and proper service please mention the CCPA)

Website:www.roxfordholdings.com

Email:[email protected]

By Mail: Roxford Holdings Inc

555 Anton Blvd Ste 150, Costa Mesa, CA 92626