PRIVACY POLICY

This Online Privacy Policy ("Policy") applies to your use of the REEcycle Holdings, Inc. ("REEcycle," "we," "us," or "our") website at reecycleinc.com and any related subdomains (collectively, the "Website"). REEcycle is a U.S. corporation incorporated in Delaware.

This Policy explains how we collect, use, and manage information from visitors to the Website. We are committed to protecting your personal information and comply with applicable privacy laws, including: (i) applicable U.S. state privacy laws; and (iii) to the extent REEcycle maintains operations in Australia, the Privacy Act 1988 (Cth). Where these laws conflict, we apply the standard most protective of your rights.

IMPORTANT NOTICE - NOT AN OFFER OR SOLICITATION

REEcycle is currently party to a non-binding Letter of Intent with Hall Chadwick Acquisition Corp. (Nasdaq: HCACU) for a proposed de-SPAC business combination. This Website and the information contained herein do not constitute an offer to sell, a solicitation of an offer to buy, or a recommendation to purchase any security of REEcycle Holdings, Inc., Hall Chadwick Acquisition Corp., or any other entity. Nothing on this Website should be construed as investment advice or as an inducement or encouragement to invest. Any securities offering will be made only by means of a prospectus or other offering document filed with, or exempt from filing with, the U.S. Securities and Exchange Commission ("SEC"). Prospective investors should read any such offering document carefully before making an investment decision.

IMPORTANT - BUSINESS-TO-BUSINESS WEBSITE

The Website is operated for informational and business development purposes only. REEcycle does not sell products or services directly to consumers through this Website. Data collected through this Website is limited to professional inquiries, investor relations, job applicants, and general business contacts.

What information do we collect and how do we use it?

REEcycle uses cookies to collect and log certain information about your browsing experience on the Website for statistical purposes (see “Cookies” below).

Some sections of this Website may also allow you to contact us by email or otherwise volunteer information about yourself, such as your name, email address, and your preferred means of communication. By providing us with this information, you consent to this information being used and disclosed for the purposes of carrying out or responding to your requests, or for any other purposes outlined at the time you provide the information.

REEcycle may disclose your personal information to our affiliates and to service providers who assist us in providing this Website and conducting our business. REEcycle may also disclose your personal information to third parties, where you consent to the disclosure or in circumstances where such disclosure is required or authorized by law. This includes mandatory disclosures to U.S. securities regulators (including the SEC), Nasdaq, and law enforcement authorities.

Some personal information you submit on the website, for example, via an online form, may need to be processed by a third party. By submitting personal information via the Website or an online form, you consent to the disclosure of that information to a third party, which may be located overseas, for the purposes of carrying out or responding to your request, and processing the online form.

REEcycle may disclose your information to overseas recipients. We will only transfer your personal information to overseas recipients where: (i) you have given your express consent; (ii) such transfer is required or authorized by law; (iii) the transfer is necessary for the performance of a contract to which you are party; or (iv) we have implemented appropriate safeguards (such as standard contractual clauses) to protect your information. Transfers to the United States and Australia may occur in the ordinary course of our operations.

No Solicitation of Investor Interest. The inclusion of references to the proposed business combination with Hall Chadwick Acquisition Corp. in this Policy is for disclosure and transparency purposes only. This Website does not solicit, accept, or process expressions of investor interest. REEcycle does not collect personal information from Website visitors for the purpose of identifying or qualifying prospective investors. Any individual who submits personal information through this Website (e.g., via a contact form) will not be treated as a prospective investor on the basis of that submission alone, and no such submission constitutes an indication of investment interest. Any formal investor outreach in connection with the proposed transaction will be conducted exclusively through REEcycle's authorized financial advisors and designated offering materials.

 

Cookies

Cookies are small data files that a website is able to place on a user’s hard drive to record aspects of that user’s experience of the website. Like many sites, this website may use cookies from time to time.

We use the following categories of cookies:

  • Strictly Necessary Cookies: Required for the Website to function. These cannot be disabled.

  • Analytics/Performance Cookies: Help us understand how visitors use the Website (e.g., Google Analytics). These cookies collect aggregate, anonymized data.

  • Functional Cookies: Allow the Website to remember preferences such as language or region.

  • Marketing Cookies: Currently not in use. We will update this Policy and seek consent before deploying any marketing cookies.

For example, we may use cookies to record that a user visited a particular section of the Website, that their browsing software was a particular version or that they chose not to be on a mailing list. In this way, cookies can improve the operation of the website, and make the experience more efficient, more enjoyable or more personalized.

Importantly, cookies do not need to identify the user or record any personal information. No attempt is made to identify you or your browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the service provider’s logs, or where your usage is causing technical issues for our site that may need to be resolved and we need to contact you. A notice will be posted on this website if this website attempts to identify individuals from their cookies unless that identification is required by law or to assist in law enforcement.

The default settings of most internet browsers allow cookies. However, users may change their browser settings to disallow cookies. Please note that some parts of this website may not function fully for users that disallow cookies.

Security

REEcycle takes appropriate technical, administrative, and organizational security measures to protect personal information from loss, misuse and from unauthorized access, modification or disclosure. However, there are risks in transmitting information across the Internet. So while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us online and individuals do so at their own risk. As far as permissible under law, REEcycle accepts no responsibility for the unauthorized access of personal information held by REEcycle. In the event of a data breach involving your personal information, we will notify you and relevant regulators within the timeframes required by applicable law.

Updating this Privacy Policy

The content of this Privacy Policy. may be updated from time to time. We will post a notice on the Website whenever we make material changes to this Policy.

Links to other websites

This website provides links to other third party websites. These third party websites are not subject to the REEcycle Privacy Policy and REEcycle is not responsible for the privacy practices of these third party sites, or for the accuracy, completeness, or suitability of any content available through any such third party websites.

Access your information

If you want further information regarding this Privacy Policy, wish to request access to any personal information we hold about you, or make a complaint about a possible breach or a failure to comply with this Privacy Policy, please contact us using the “Contact” section of the website. We take all complaints seriously, and will respond to your complaint within a reasonable period.

Unsubscribe

If you have registered for REEcycle newsletters or alerts, or you receive invitations to survey or events from REEcycle and you prefer not to receive future email communications from us, please review the communications settings in your profile, follow the instructions on the page where you have subscribed or registered, and click unsubscribe from all REEcycle communications.