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Crux Climate Privacy and KYC Policy

Last updated: April 23, 2025

Crux Climate, LLC (“Crux,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites, and related services (collectively, our “Services”). This privacy policy (the “Privacy  and KYC Policy”) explains how we collect, use, and disclose information from users of our Services (“Users,” “you,” and/or “your”) in order to enable developers, tax credit buyers, lenders, borrowers, and financial institutions to transact and manage transferable tax credits and complete lending transactions in the clean energy space. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy and KYC Policy describes. Beyond the Privacy and KYC Policy, your use of our Services is also subject to our Terms of Service.

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Information we collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

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A. Information you provide to us

Registration and profile information. When you sign up for an account, register to use our Services, sign up for notifications or updates, or participate in our surveys, we may ask you for information such as your name, email address, phone number, job title, employer, employer address, and financial information. 

Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. When you communicate with us online, third party vendors receive and store these communications on our behalf. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn. 

Renewable energy project information. We also may collect information regarding renewable energy projects such as name, location, photos, videos, transmission operator, size, credit value, adders, description, and insurance.

Energy developer/seller/borrower information. We may also collect information regarding energy developers, such as the number of states they are operational in, megawatts completed, years in service, fiscal year end, technology types and location.

Tax credit buyer and lender information. We may also collect information regarding tax credit buyers and project lenders, including, where applicable, location, experience with energy tax credits, tax liability, lender profile, targeted tax credit purchase value, targeted lending value and fiscal year end.

Advisor information. In some cases, Crux works with advisor parties, including banks, brokers, syndicators, law firms, tax advisors and other third party businesses (each such business, an “Advisor”). We may also collect information regarding Advisors, such as details about their business model and types of clients. 

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B. Information we collect when you use our services

Location information. When you use our Services, you may infer your general location information, for example by using your internet protocol (IP) address. 

Device information. We receive information about the device and software you use to access our Services, including IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens. 

Usage information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, your comments, any content you post, transaction information, and the dates and times of your visits.

Information from cookies and similar technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

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C. Information we receive from third parties 

Information from third-party services. If you choose to link our Services to a third-party account, we may receive information about you, including your profile information and your photo, and your use of the third-party account. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

Other third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you.

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How we use the information we collect

We use the information we collect:

  • To provide, maintain, improve, and enhance our Services;
  • To personalize your experience on our Services such as by providing tailored content and recommendations; 
  • To understand and analyze how you use our Services and develop new products, services, features, and functionality;
  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
  • To facilitate the connection of third-party services or applications;
  • For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
  • To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use for any lawful purpose, both internally and externally, including analytics, benchmarking, transaction term tracking and analysis, pricing algorithms, marketing and reports;
  • To send you text messages and push notifications;
  • To facilitate transactions and payments;
  • To find and prevent fraud and abuse, and respond to trust and safety issues that may arise; 
  • For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
  • For other purposes for which we provide specific notice at the time the information is collected.

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How we disclose the information we collect

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Affiliates. We may disclose any information we receive to our affiliates for any of the purposes described in this Privacy and KYC Policy. 

Vendors and service providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services. 

Third-party app integrations. If you connect a third-party application to our Services, we may disclose certain information to that third party. 

Analytics partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/. 

Advertising partners. We work with third-party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.

As required by law and similar disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, sale, or other asset transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy and KYC Policy in effect at the time the applicable information was collected.

For any lawful business purpose, including sharing with external third parties, either on a free or monetized basis. We may transfer your information to other third parties for any lawful business purpose, either on a free or monetized basis, but only when such information is part of anonymized, aggregate data containing only de-identified, non-personal information that we are using for any lawful purpose, both internally and externally, including analytics, benchmarking, transaction term tracking and analysis, pricing algorithms, marketing and reports.

Consent. We may also disclose your information with your permission.

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Your choices

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Marketing communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

If you choose not to provide us with information we request, some features of our Services may not work as intended.

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Third parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy and KYC Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

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Security 

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

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Children’s privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy and KYC Policy, then you may alert us at legal-notices@cruxclimate.com. 

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International visitors

Our Services are hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

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Update your information 

You can update your account and profile information through your profile settings. You may request deletion of your account by contacting us via email at legal-notices@cruxclimate.com.

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Data room usage

We provide access to a data room hosted by Box, Inc. (“Box”) to facilitate the sharing of information among parties involved in transactions on our platform. By uploading materials to the data room, you agree to the Box Terms of Service and acknowledge that such materials are subject to Box’s privacy practices and infrastructure, including any use of artificial intelligence (AI) or large language models (LLMs) enabled within the Box platform.

You understand and agree that:

  • Box terms apply: Any content you upload to the data room is governed by Box’s terms and policies. Crux Climate, LLC (“Crux) does not control Box’s security measures, infrastructure, or practices. You should review the Box Terms of Service and related policies before using the data room.

  • Third-party access: Any materials you upload may be accessed by other parties whom you or your organization have invited into the data room. Crux does not control, monitor, or accept responsibility for the actions of these invitees or how they may use or disclose any data shared with them.

  • Confidentiality obligations: You agree that materials you access in the data room which were uploaded by another party must be treated as confidential and handled in accordance with any applicable non-disclosure agreement (NDA) or similar agreement you have with the uploading party. Crux is not responsible for managing or enforcing such agreements.

  • User access and controls: You are responsible for managing the permissions and invitations related to your content. You agree not to circumvent, disable, or otherwise interfere with any access controls set within the data room.

  • Authorization for uploaded content: You represent and warrant that you have all necessary rights, permissions, and authority to upload or share any content, including materials received from or related to third parties. Crux Climate assumes no responsibility for verifying the legality of such uploads and disclaims liability for any unauthorized content, including where permission has not been obtained.

  • Audit logging and activity monitoring: Activity within the data room may be logged, including document views, downloads, uploads, edits, and deletions. These logs may be reviewed for security, compliance, or analytics purposes.

  • Security and compliance: While Crux and Box implement commercially reasonable safeguards, no system is completely secure. You are responsible for ensuring that your use of the data room complies with all applicable laws and regulations, including data protection and export control laws.

  • Aggregated and anonymized use: Crux may use information uploaded to the data room in aggregated and anonymized form for lawful business purposes, such as to: (a) track use of the Service; (b) provide support for the Service; (c) monitor the performance and stability of the Service; (d) prevent or address technical issues with the Service; (e) improve the Service, our other products and services, and to develop new products and services; and (f) for all other lawful business practices, such as analytics, benchmarking, marketing and reports, in a manner consistent with the provisions of the Crux Terms of Service.

  • Use of AI and LLMs: Information in the data room may be processed using artificial intelligence technologies, including large language models (LLMs), for limited, authorized purposes such as document summarization, search, classification, or enhancing user productivity. These capabilities may be provided by Box or Crux and are subject to strict access controls. Crux will never use your uploaded data to train publicly available or general-purpose AI models. Additionally, where Box offers LLM functionality, we rely on their published commitments not to use customer data for model training without explicit opt-in consent. All AI usage is conducted in a manner that maintains confidentiality, respects access permissions, and aligns with our security standards and privacy obligations.

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Know your customer (KYC) 

As part of our commitment to regulatory compliance, risk management, and the protection of our platform and its users, we reserve the right to conduct due diligence on any current or prospective user of our services.

This due diligence may include, but is not limited to, identity verification, Know Your Customer (KYC) procedures, anti-money laundering (AML) screening, fraud detection, sanctions screening, reputational risk analysis, litigation checks, bankruptcy risk assessments, and other compliance-related or risk-based evaluations (collectively, “Due Diligence Checks”).

By accessing or using our services, you acknowledge and agree that we may, at any time and in our sole and reasonable discretion, initiate or require you to participate in such Due Diligence Checks. You further agree to promptly provide any information or documentation we reasonably request in connection with these checks.

We reserve the right to suspend, restrict, or terminate your access to the platform or any part of our services, without liability to you, in the event that:

  • You fail to provide requested information in a timely or complete manner;

  • The results of our Due Diligence Checks are, in our reasonable discretion, unsatisfactory or indicative of material risk; or

  • We determine, in our reasonable discretion, that continued engagement with you may expose us or our users to regulatory, financial, operational, or reputational risk.

Our Due Diligence Checks may be conducted directly or through one or more third-party service providers, and you expressly consent to our use of such providers as necessary to carry out these obligations.

These KYC terms are incorporated by reference into our Terms of Service and forms an integral part thereof. We may update this policy from time to time to reflect changes in applicable laws, regulatory guidance, or our internal risk policies.

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Changes to this privacy and KYC policy

We will post any adjustments to the Privacy and KYC Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

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Contact information

If you have any questions, comments, or concerns about our processing activities, please email us at legal-notices@cruxclimate.com.

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