Privacy

OUR PRIVACY POLICY AND HOW WE PROTECT YOUR PERSONAL
INFORMATION

The following Federal Privacy Notice is provided under the
Gramm-Leach-Bliley Act and Regulation P and applies to nonpublic
personal information we collect in connection with consumer financial
products or services.

The following additional disclosures apply to personal
information that may not be covered by the GLBA notice, including
website, employment, business-contact, investor, and other information,
where applicable.

Privacy Policy

Introduction

Your privacy is very important to us. This notice (this “Privacy
Notice”) is provided by Silver Hill Capital, LLC and the various
investment funds and accounts affiliated with Silver Hill Capital, LLC
(such funds and accounts, the “Bayview Funds”, and together “we” or
“us”), and sets forth our policies for the collection, use, storage,
sharing, disclosure (collectively, “processing”) and protection of
personal data relating to current, prospective and former participants
in the Bayview Funds, as applicable.

References to “you” or an “investor” or “borrower” in this Privacy
Notice mean any investor or borrower who is a person or entity, as
applicable.

Certain information we collect in connection with financial products
or services may be subject to the Gramm-Leach-Bliley Act and Regulation
P and is addressed in our GLBA Privacy Notice. Additional rights may
apply depending on your state of residence.

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the
applicable requirements under the privacy and data protection laws that
apply in the jurisdictions where we operate (collectively, the “Data
Protection Laws”). Silver Hill Capital is considered to be the data
controller in respect of any personal information we hold about you for
the purposes of certain Data Protection Laws. This means that Silver
Hill Capital determines the purposes and the means of the processing of
your personal information.

Please contact us at 866-853-1799 with any questions about this
Privacy Notice or requests with regards to the personal data we
hold.

Please note that the administrators and custodians of Silver Hill
Capital, LLC (collectively, the “Counterparties”) work under a range of
professional and legal obligations that require them to process personal
data (e.g., anti-money laundering legislation). In order to meet the
requirements of such obligations, they, from time to time, would not be
acting on our instructions but instead in accordance with their own
respective professional or legal obligations and therefore as data
controllers in their own right with respect to such processing. For more
specific information or requests in relation to the processing of
personal data by Silver Hill Capital, LLC, you may also contact us for
the contact information of the relevant counterparty.

The Types of Personal Data We May Hold

The categories of personal data we may collect include names,
residential or business addresses, or other contact details, signature,
nationality, tax identification or passport number, date of birth, place
of birth, photographs, copies of identification documents, bank account
details, information about assets or net worth, credit history,
information on investment activities, or other personal information,
such as certain special categories of personal data (including, where
relevant, 2 information on political affiliations, ethnic origin, or
criminal convictions), as specified under the applicable Data Protection
Laws, that may be contained in the relevant materials, documents, or
obtained through background searches.

How We Collect Personal Data

We may collect personal data about you through: (i) information
provided directly to us by you, or another person on your behalf; or
(ii) information that we obtain in relation to any transactions between
you and us.

We also may receive your personal information from third parties or
other sources, such as our affiliates, the relevant Bayview Fund
administrator, publicly accessible databases or registers, tax
authorities, governmental agencies and supervisory authorities, credit
agencies, fraud prevention and detection agencies, or other publicly
accessible sources, such as the Internet.

How We May Use Personal Information

We may process your personal data for the purposes of administering
the relationship between you and us (including acceptance,
communications, and reporting), marketing of our products and services,
monitoring and analyzing our activities, and complying with applicable
legal or regulatory requirements (including anti-money laundering, fraud
prevention, tax reporting, sanctions compliance, or responding to
requests for information from supervisory authorities, or law
enforcement agencies).

We will use one of the permitted grounds under the applicable Data
Protection Laws to process your personal information. Such grounds
include, for example, circumstances where:

(i) processing is necessary to perform our obligations under the
relevant fund documents;

(ii) we are required to comply with a legal or regulatory obligation
applicable to us; or

(iii) we, or a third party on our behalf, have determined that it is
necessary for our legitimate interests to collect and use your personal
information, such as if we believe that you have a reasonable
expectation for us or a third party to collect or use your personal
information for such purpose.

What Are the Consequences of Failing to Provide Personal
Information

Where personal data is required to satisfy a statutory obligation
(including compliance with applicable anti-money laundering or sanctions
requirements) or a contractual requirement, providing your information
is required. Where there is suspicion of unlawful activity, failure to
provide personal data may result in the submission of a report to the
relevant law enforcement agency or supervisory authority.

How We May Share Personal Data

We may disclose information about you to our affiliates, service
providers, or other third parties to accept your subscription,
administer and maintain your account(s), or otherwise perform our
contractual obligations. We may also need to share your personal
information with regulatory, tax or law enforcement authorities to
comply with applicable legal or regulatory requirements, respond to
court orders, or in the context of regulatory requests for information,
administrative proceedings, or investigations. We will also release
information about you if you direct us to do so.

We may also disclose information about you, or your transactions and
experiences with us, to our affiliates or service providers for our
everyday business purposes, such as administration of our business,
record-keeping, maintaining security of our information technology
systems, reporting and monitoring of our activities, investor relations
activities, collections, servicing, and compliance with applicable legal
and regulatory requirements.

You may opt out of the sale or sharing of personal information and
targeted advertising by using our “Manage Preferences” link or by
enabling a recognized opt-out preference signal, where required by
applicable law.

Retention Periods and Security Measures

We will not retain personal data for longer than is necessary in
relation to the purpose for which it is collected, subject to the
applicable Data Protection Laws. Personal data will be retained for a
minimum of five years after your loan is obtained by Silver Hill Capital
or applicable Bayview Fund. We may retain personal data for a longer
period for the purpose of marketing our products and services or
compliance with applicable law. From time to time, we will review the
purpose for which personal data has been collected and decide whether to
retain it or to delete if it no longer serves any purpose to us.

We maintain administrative, technical, and physical safeguards
designed to protect personal information against unauthorized access,
use, disclosure, alteration, and destruction. These safeguards may
include access controls, encryption, monitoring, vendor oversight,
employee training, incident response procedures, and physical security
controls, as appropriate to the nature of the information and our
operations.We require service providers and contractors that process
personal information on our behalf to use personal information only for
the services we request, to maintain appropriate safeguards, and to
comply with applicable contractual and legal obligations.

We will notify you of any material personal data breaches affecting
you in accordance with the requirements of applicable Data Protection
Laws.

Additional Information under the U.S. Gramm-Leach-Bliley Act
1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Notice applies to
current and former borrowers who are individuals or entities. We are
providing this additional information under U.S. federal law.

We may disclose information about our borrowers, prospective
borrowers or former borrowers to affiliates (i.e., financial and
non-financial companies related by common ownership or control) or
non-affiliates (i.e., financial or non-financial companies not related
by common ownership or 4 control) for our everyday business purposes,
such as to process your transactions, maintain your account(s) or
respond to court orders and legal investigations. Thus, it may be
necessary or appropriate, under anti-money laundering and similar laws,
to disclose information about Silver Hill Capital’s borrowers in order
to accept subscriptions from them. We will also release information
about you if you direct us to do so.

We may furnish information about your account to consumer reporting
agencies as permitted by law. If you believe information we reported is
inaccurate, you may contact us at 1-866-853-1799, www.silverhillcapitalloanservicing.com
or 4425 Ponce de Leon Blvd., Suite 300, Coral Gables, FL 33146 and
provide sufficient information for us to investigate your dispute.

We may share your information with our affiliates for direct
marketing purposes, such as offers of products and services to you by us
or our affiliates. You may prevent this type of sharing by contacting us
at 866-853-1799. If you are a new borrower, we can
begin sharing your information with our affiliates for direct marketing
purposes 30 days from the date you are sent this Privacy Notice. When
you are no longer our borrower, we may continue to share your
information with our affiliates for such purposes.

You may contact us at any time to limit our sharing of your personal
information. If you limit sharing for an account you hold jointly with
someone else, your choices will apply to everyone on your account. U.S.
state laws may give you additional rights to limit sharing.

We may disclose information you provide to us to companies that
perform marketing services on our behalf.

Privacy Notice for California Consumers

This notice contains disclosures required by the California Privacy
Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning
when used in this notice. This notice is only relevant to California
residents (“consumers” or “you”).

Personal information collected, processed, shared, or disclosed
pursuant to the Gramm-Leach-Bliley Act and its implementing regulations
may be exempt from certain state privacy law requirements. However, this
Notice also describes our practices for personal information that may
fall outside those exemptions, such as website, marketing, employment,
business-contact, and other non-GLBA information.

Information We Collect.

Personal Information does not include information that is publicly
available, de-identified/aggregated, or subject to HIPAA or GLBA.

We collect Personal Information from the following categories of
sources:

• Your communications with us;
• Service providers, including, but not limited to: administrators,
  lenders, banks, brokers, auditors, law firms, consultants, placement
  agents, employment agencies, credit bureaus; and
• Government entities.

Our services are not directed to children under 13. We do not
knowingly collect, solicit or sell Personal Information from anyone
under the age of 16 without the prior consent of a parent or
guardian.

We may collect and process financial information relevant to consumer
loans or mortgage loans as applicable, including loan application
information, credit reports, income and employment information, tax
records, bank statements, property information, appraisal information,
insurance information, payment history, escrow information, servicing
notes, loss-mitigation information, call recordings, complaints, and
communications with borrowers, brokers, servicers, investors, insurers,
title companies, settlement agents, government agencies, and credit
reporting agencies.

Purpose for Collection and Use of Personal
Information.

We may collect or use Personal Information for one or more of the
following purposes:

• Providing you with information about our products and
  services;
• Providing you with performance and other updates;
• One or more of the following business purposes:
  • Performing services (for us or our service provider or
    contractor) such as account servicing, processing orders and payments,
    and analytics;
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and
    illegal activity;
  • Debugging;
  • Internal research for technological improvement;
  • Internal operations;
  • Activities to maintain and improve our services; and
  • Short-term, transient use, such that the personal information is
    not disclosed to another third party and is not used to build a profile
    about you.

We use this information to evaluate applications, originate loans,
acquire or sell loans, service accounts, process payments, administer
escrow, manage defaults or loss mitigation, prevent fraud, comply with
investor and regulatory requirements, report to credit bureaus, respond
to legal requests, and protect our rights and property.

Sharing Personal Information.

We may disclose Personal Information to:

• Service providers, including but not limited to: administrators,
  lenders, banks, brokers, auditors, law firms, consultants, placement
  agents, credit bureaus;
• Affiliates;
• Business partners;
• Legal or government regulatory authorities as required by
  applicable law;
• In connection with a potential business transfer; and
• Third parties to whom you or your agents authorize us to disclose
  such information in connection with services we provide to you.

In the past 12 months, we have not sold Personal Information to third
parties. We do not sell personal information for money. We may share
personal information with nonaffiliates as described in our Federal
Privacy Notice, including where permitted by law or with your
consent.

Length of Time.

We will keep your sensitive personal information or any other
Personal Information for as long as necessary to comply with our
regulatory obligations. For example, personal data will be retained for
a minimum of five years after your loan is obtained by Silver Hill
Capital or applicable Bayview Fund. We may retain personal data for a
longer period for the purpose of marketing our products and services or
compliance with applicable law. From time to time, we will review the
purpose for which personal data has been collected and decide whether to
retain it or to delete if it no longer serves any purpose to us.

Rights of California Consumers.

The CPRA provides a California consumer the following rights, subject
to certain exceptions and limitations:

• The right to request: (a) the categories and specific pieces of
  Personal Information we collect about you; (b) the categories of sources
  from which we collect your Personal Information; (c) our business or
  commercial purposes for collecting, selling or sharing your Personal
  Information; (d) the categories of Personal Information disclosed for a
  business purpose and the categories of persons to whom it was disclosed;
  (e) the categories of your Personal Information (if any) that we have
  either sold, shared, or disclosed.
• For certain categories of Personal Information, the right to
  request a list of what we disclosed to third parties for their own
  direct marketing purposes in the past 12 months and the names and
  addresses of those third parties.
• The right to request that we delete your Personal Information,
  subject to certain exceptions.
• The right to opt out of our sale(s) (if any) of your Personal
  Information.
• The right to request we correct any inaccurate Personal
  Information maintained about you.
• The right to limit our use of your sensitive personal information
  to only use that is necessary to perform the services expected or
  provide the goods reasonably expected.
• The right not to receive discriminatory treatment for exercising
  your CPRA rights.

We collect sensitive personal information only as reasonably
necessary for our business, legal, compliance, security, and
financial-services purposes, including to verify identity, evaluate
applications, service accounts, prevent fraud, comply with law, and
manage legal claims. We do not use sensitive personal information for
purposes that would require a right to limit under California law unless
we provide that right.

You may submit requests relating to your exercise of CPRA rights to
us via:

By Telephone:

866-853-1799;

or

Online form:

https://silverhillcapitalloanservicing.com/contact-us/

You may only make a verifiable request for access or data
portability twice within a 12-month period. All verifiable requests must
provide (1) enough information that allows us to reasonably verify you
are the person about whom we collected Personal Information or an
authorized representative, and (2) sufficient detail that allows us to
properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its
receipt. If we require more time, we will inform you of the reason and
extension period in writing. We will deliver our written response by
mail or electronically, at your option.

We will not discriminate against you for exercising privacy rights,
but we may be unable to provide certain services if we cannot process
information necessary to provide those services or comply with law.

Additional U.S. State Privacy Rights.

Depending on your state of residence and subject to applicable
exemptions, you may have the right to request access to, correction of,
deletion of, or a copy of certain personal information; to opt out of
certain processing for targeted advertising, sale, or profiling in
furtherance of decisions that produce legal or similarly significant
effects; and to appeal our decision regarding a privacy request. These
rights may not apply to personal information governed by GLBA, FCRA, or
other financial services laws.

Appeals.

If we deny your rights request, you may appeal our decision by
contacting us at https://silverhillcapitalloanservicing.com/contact-us/
and stating “Privacy Rights Appeal” in the subject line. We will respond
within the time required by applicable law.

Questions

If you have questions regarding this Notice, please contact us at
1-866-853-1799 or
https://silverhillcapitalloanservicing.com/contact-us/.