This Privacy Policy explains how EMK Development Group, Inc. collects, uses, shares, and protects personal information obtained through our website at emkdevgroup.com and through our investor qualification process. Please read this policy carefully. By using our website or submitting information to us, you agree to the practices described below.

1. Who We Are

EMK Development Group, Inc. (“EMK,” “the Company,” “we,” “us,” or “our”) is a California Corporation with its principal office located at 1401 21st Street, Suite R, Sacramento, CA 95811. We operate the website emkdevgroup.com and conduct a private real estate development and lending business in the Raleigh-Durham-Wake Forest corridor of North Carolina.

EMK Development Group, Inc. is the data controller responsible for your personal information collected through this website and through our investor qualification and relationship management processes.

For questions about this policy, contact us at: (916) 477-2154 or by mail at the address above.

2. Information We Collect

We collect information in two ways: information you provide directly to us, and information collected automatically when you use our website.

Information You Provide Directly

• Contact information: Name, email address, phone number, and mailing address submitted through our contact form or investor questionnaire.
• Financial qualification information: Income, net worth, asset, and investment experience information provided during the accredited investor qualification process. This information is collected solely to satisfy our legal obligations under Rule 506(c) of Regulation D, Securities Act of 1933.
• Identity verification documents: Supporting documentation collected during the accredited investor verification process, which may include tax documents, brokerage statements, professional verification letters, or other financial records.
• Communications: Records of phone calls, emails, messages, or other correspondence between you and EMK Development Group or its representatives.
• Electronic signature data: Signature metadata, timestamp data, and authentication records generated through our electronic document execution platform (currently Zoho Sign).

Information Collected Automatically

• Log data: IP address, browser type and version, operating system, referring URLs, pages visited, and time and date of visits.
• Cookie data: Information collected through cookies and similar tracking technologies, described further in Section 7.
• Device information: General information about the device used to access our website.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Investor qualification and compliance: To fulfill our legal obligation to verify accredited investor status as required by Rule 506(c) of Regulation D before sharing offering materials or accepting any commitment.
• Communication: To respond to inquiries, schedule calls, deliver offering documents, and communicate with you throughout the investment process.
• Investor relations: To provide updates, share project information, and manage the ongoing relationship with investors in active or completed transactions.
• Regulatory recordkeeping: To maintain records required by federal and state securities laws, including records required to be kept under Regulation D and SEC rules.
• Website operation and improvement: To understand how visitors use our website and to improve its performance, content, and functionality.
• Legal compliance: To comply with applicable laws, regulations, legal process, or enforceable governmental requests.
• Protection of rights: To detect, investigate, or prevent fraud, unauthorized access, or other illegal activity.

We do not use your personal information for automated decision-making or profiling in any legally significant manner.

4. Legal Basis for Processing

• Contractual necessity: Processing necessary to enter into or perform an agreement with you, including the execution and administration of promissory notes, mortgage agreements, and related investment documents.
• Legal obligation: Processing required to comply with applicable law, including federal securities laws under the Securities Act of 1933 and Regulation D, as well as applicable state securities regulations.
• Legitimate interests: Processing necessary for our legitimate business interests, including responding to investor inquiries, operating our website, and maintaining business records, where those interests are not overridden by your rights.
• Consent: Where you have expressly consented to processing, such as by submitting a contact form or questionnaire.

5. How We Share Your Information

We do not sell your personal information. We do not share your personal information with third parties for their own marketing purposes. We share information only in the following limited circumstances:

• Service providers: We share information with vendors who provide services on our behalf, such as electronic signature and document management services (Zoho Sign), email services, and website hosting. These vendors are contractually bound to use your information only to provide services to us.
• Professional advisors: We may share information with attorneys, accountants, compliance consultants, or other advisors in connection with our legal obligations, securities compliance, or business operations.
• Licensed closing agents and title companies: We share necessary information with licensed real estate closing agents and title companies in connection with property transactions in which you are participating as a private lender.
• Regulatory authorities: We may disclose information to the SEC, FINRA, or other regulatory bodies when required by law, regulation, subpoena, court order, or other legal process.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such transfer that materially affects how your information is used.
• With your consent: We may share your information for any other purpose with your express consent.

6. Investor Verification Data

Information collected for the purpose of verifying your status as an accredited investor — including financial statements, tax documents, professional verification letters, self-attestation forms, and related records — is subject to heightened handling standards within our organization.

This information is collected solely to satisfy our legal obligations under Rule 506(c) of Regulation D, Securities Act of 1933, and applicable SEC guidance. Under current SEC rules, accredited investor verification records must be maintained for a period of at least five years from the date of collection.

Investor verification documents are not shared with any third party except (a) our legal and compliance advisors, (b) licensed closing agents in connection with transactions in which you are a participating lender, and (c) regulatory authorities upon legally compelled request.

7. Cookies and Tracking Technologies

Our website may use cookies — small text files stored on your device — and similar technologies to operate the site and understand how visitors interact with it. We use the following types of cookies:

• Strictly necessary cookies: Required for the website to function. These cannot be disabled.
• Analytics cookies: Used to collect anonymous information about how visitors use our website, such as pages visited and time spent on site.
• Preference cookies: Used to remember your preferences, such as language or display settings.

You may disable cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the website. We do not use cookies for advertising targeting or cross-site behavioral tracking.

8. Data Retention

• Investor qualification and verification records: Retained for a minimum of five (5) years from the date of collection, as required by SEC recordkeeping rules applicable to Rule 506(c) offerings.
• Investment and transaction records: Retained for a minimum of seven (7) years following the conclusion of a transaction, consistent with applicable securities and tax law requirements.
• General inquiry and contact records: Retained for up to three (3) years from the date of last contact, unless a transaction relationship is established.
• Website analytics data: Retained in aggregate or anonymized form; individual log data is generally retained for up to twelve (12) months.

9. Your Rights — California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following rights:

• Right to Know: You may request disclosure of what personal information we have collected about you, the sources, the business purpose, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions including our legal obligation to retain records required by securities law.
• Right to Correct: You may request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: We do not sell your personal information and do not share it for cross-context behavioral advertising.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

To exercise any of the above rights, please contact us at (916) 477-2154 or by written request mailed to 1401 21st Street, Suite R, Sacramento, CA 95811. We will respond to verified requests within 45 days.

10. Data Security

We implement reasonable and appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include access controls, use of encrypted electronic document platforms, and limiting access to personal information to personnel who require it to perform their duties.

No method of data transmission over the internet or electronic storage system is completely secure. While we take the protection of your information seriously, we cannot guarantee absolute security. If you believe your information has been compromised, please contact us immediately.

11. Third-Party Links

Our website may contain links to third-party websites, including Thayer Homes (thayerhomes.com), Zillow, and the U.S. Securities and Exchange Commission website (sec.gov). EMK Development Group, Inc. does not control these external sites, is not responsible for their content or privacy practices, and this Privacy Policy does not apply to them.

12. Children’s Privacy

Our website and services are directed exclusively at sophisticated adult investors who meet the definition of an accredited investor under Rule 501(a) of Regulation D. We do not knowingly collect personal information from individuals under the age of 18.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or other operational considerations. When we make material changes, we will update the effective date at the top of this page. Your continued use of our website following the posting of changes constitutes your acknowledgment of the revised policy.

14. Contact Us

EMK Development Group, Inc.

Attn: Kevin Alexander, President

1401 21st Street, Suite R

Sacramento, CA 95811

Phone: (916) 477-2154

Email: info@emkdevgroup.com

Website: emkdevgroup.com

We will respond to all privacy-related inquiries within a reasonable time and no later than 45 days for verified consumer rights requests under the CCPA.