Listing Strategy Decision Record Published by LTC Capital, LLC

Privacy Policy

Last updated: July 14, 2026

LTC Capital, LLC (“Company”, “we”, “our”, or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our website, the LSDR product, and other services that link to this policy (our “Services”) and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.

It does not apply to information collected by:

• Us through any other means, including on any other website operated by Company or any third party that does not link to this policy; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children’s and Minors’ Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, payment card information, or any other identifier we may use to contact you online or offline).

The types and categories of personal data we collect or process include:

• Account information, including your name, brokerage or business name, address, email address, phone number, and other contact information you provide us.
• Payment information, including payment card information you provide at checkout, which is processed by our third-party payment processor.
• Transaction information, including your license, purchases, order history, and renewal activity.
• Technical information, including your IP address, device identifiers, operating system and version, browser type and settings, and usage details about your interactions with the Services.
• Configuration information, including the brokerage identity, MLS and form references, practice statements, and other inputs and form entries you provide to configure your Artifact.
• Communication information, including the contents of, and metadata about, your communications with us, such as emails, chats, and form submissions.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, subscribe to or purchase the LSDR product, configure an Artifact, or otherwise communicate with us. We also collect information, including your email address, that you submit through any form available on our website, whether or not related to the LSDR product, such as contact, inquiry, demonstration-request, newsletter, and email sign-up forms.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies, including details of your interactions with our Services, such as traffic data, logs, and other communication data, and which resources and Services features that you access and use.

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Web Beacons. Some parts of the Services 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 the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by contacting us using the details in the Contact Information section below. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about your or your device. These third parties may include:

• Analytics providers.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from service providers we engage to perform services on our behalf, such as our payment processor, email platform, content-delivery, and analytics, security, and anti-fraud providers.

Seller Information and the LSDR Artifact

Our LSDR product is delivered as a configured file (an “Artifact”) that the licensed real estate professional uses locally. Information about a seller that is entered into the Artifact (“Seller Information”) is entered and retained locally by the licensee and is not transmitted to or hosted by us through ordinary use of the Artifact. The licensee, and not LTC Capital, LLC, determines the purposes and means of collecting and using Seller Information and is responsible for providing notices, obtaining consents, securing the information, and otherwise complying with applicable law. We do not receive Seller Information unless a licensee affirmatively sends it to us through an approved secure channel where lawful and necessary. This policy governs the information we collect and process as described in this policy (principally the business-contact, configuration, transaction, payment, technical, and communication information of licensees and website visitors) and does not govern a licensee’s independent handling of Seller Information.

How We Use Your Information

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

• Provide you with the Services and any contents, features, information, products, or services that we make available through the Services.
• Fulfill and manage purchases, orders, and payments.
• Fulfill any other purpose for which you provide it.
• Provide you with expiration and renewal notices for the LSDR product.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• Promote our Services, business, and offerings, including by sending marketing communications as described below.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when Services updates are available and about changes to any products or services we offer or provide though them.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We use your contact and website-submission information to send you product updates, renewal notices, and marketing communications about our Services. Where you provide your email address through a sign-up form on our website or at checkout, we treat that submission as your request to receive marketing communications from us. Every marketing email we send includes a clear and conspicuous unsubscribe link or reply-to-unsubscribe mechanism and our valid physical postal address. You may opt out of marketing communications at any time as described in Your Rights and Choices About Your Information.

Large Language Model Training

We do not collect, use, or sell personal data for the purpose of training large language models.

Who We Disclose Your Information To

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

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our organization.
• 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 LTC Capital, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by LTC Capital, LLC 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 data:

• 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 Service (available at https://lsdr.ltccapitalholdings.com/terms) 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 our organization, our customers, or others.

The categories of personal data we may disclose include:

• Account and contact information.
• Payment information.
• Transaction information.
• Technical information.
• Content and information you elect to provide to us.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked.
• Promotions by the Company. If you do not wish us to use your information to promote our own or third parties’ products or services, you can opt out by using the unsubscribe link or other opt-out mechanism included in each marketing email, or by contacting us using the details in the Contact Information section below. Opting out of marketing does not affect transactional messages, which are described in How We Use Your Information.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law.
• Opt Out of Using Personal Data for Sales, Targeted Advertising, and Profiling for Certain Legal or Similarly Significant Decisions. You may request that we do not use your personal data for these purposes.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please contact us using the details in the Contact Information section below. To appeal a decision regarding a consumer rights request, submit your appeal to the contact address in the Contact Information section.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt-out rights may submit a request to this designated address: vcyr@thecyrteam.com. However, we do not currently sell personal data triggering that statute’s opt-out requirements.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: vcyr@thecyrteam.com or 225 Wilmington-West Chester Pike, Suite 223, Chadds Ford, PA 19317.

To register a complaint or concern, please contact us using the details above.