The Exeter Group of Companies Privacy Policy

Effective Date: Monday, June 8, 2026

1. Scope and Overview

This Privacy Policy (hereinafter referred to as “Policy”) describes the privacy practices of The Exeter Group, LLC, a California limited liability company, and its operating subsidiaries and affiliate companies, including Exeter 1031 Exchange Services, LLC, a California limited liability company, Exeter Trust Company, a Wyoming corporation, Exeter Asset Services Corporation, a Wyoming corporation, Exeter Management Corporation, a Wyoming corporation, and Exeter SDIRA Corporation, a Wyoming corporation (collectively, “Exeter,” “we,” “our,” or “us”).

This Policy applies to personal information we collect through our websites, including, but not limited to, exeterco.com, exeter1031.com, 1031.exeterco.com, sdira.exeterco.com, exetertrustcompany.net, exeterassetservices.com, exetermanagement.com, and any other websites or online services we operate that link to this Policy (hereinafter collectively referred to as, the “Exeter Sites” or “Sites”), as well as information we collect in connection with our business services.

By accessing or using the Exeter Sites, you acknowledge that you have read and understand this Policy, and that you further agree to the collection and use of personal information in accordance with this Policy. If you do not agree with the practices described herein, please exit immediately and do not access or use the Exeter Sites.

A limited number of Exeter subsidiaries or affiliated entities may maintain their own separate privacy policies. Where a separate policy is in place, it will be posted on the applicable website, and this Policy will not apply to that entity’s practices.

2. Information We Collect and Use

We may collect the following categories of personal and browsing information.

2.1 Personal Information You Provide

Contact and identity information — such as your name, street address, mailing address, telephone numbers, and email addresses
Account credentials — such as user IDs and passwords created during registration
Financial and transactional information — such as bank account details, wire transfer instructions or payment information provided in connection with transactions or other services
Government-issued identification — such as Social Security Numbers (SSN), Employer Identification Numbers (EIN), driver’s license numbers, or passport numbers, where required to complete a transaction or verify your identity
Communications — information you submit through contact forms, inquiries, or correspondence with Exeter

2.2 Information We Collect Automatically

When you visit the Exeter Sites, we and our service providers may automatically collect certain device and browsing information, including:

Internet Protocol (IP) address
Browser type, version, and language settings
Device type and operating system
Pages visited and navigation patterns within the Exeter Sites
Date and time of your visit
Referring URL or domain name

This browsing information is used to improve the structure, content, and usability of our websites. It may, where applicable, be linked to your account or personal information for account administration or client service purposes.

2.3 Information We Collect from Other Sources

We may also receive information about you from:

Referral partners and companies that direct users to the Exeter Sites
Your authorized agents, representatives, attorneys, or other parties involved in your transaction
Consumer reporting agencies or governmental entities, where applicable to our services
Affiliated Exeter companies

3. How We Use Your Information

We use the personal information we collect for the following purposes:

Service delivery — to provide, administer, and support the administration of client accounts, execution of transactions and other services you request
Account management — to create, maintain, and secure your account on the Exeter Sites, and to provide you with access to account-specific services and documents
Communications — to respond to your inquiries, process submissions, and notify you about changes to our services, your account, or this Policy
Website improvement — to analyze traffic patterns, troubleshoot technical issues, and improve the performance, structure, and functionality of the Exeter Sites
Security and fraud prevention — to protect the integrity of our systems, detect and prevent unauthorized access, fraud, misrepresentation, or illegal activity
Marketing and educational outreach — to send you seminar and webinar invitations, educational materials, eNewsletters, and informational updates about Exeter’s services, where you have not opted out
Legal and regulatory compliance — to meet applicable legal obligations, respond to lawful government or regulatory requests, and enforce our agreements
Business operations — to conduct internal auditing, recordkeeping, and administrative functions

4. Cookies, Analytics, and Similar Tracking Technologies

4.1 Cookies and Tracking Technologies

When you visit the Exeter Sites, we may place a “cookie” — a small data file — on your device. Cookies and similar tracking technologies help us recognize returning visitors, maintain session continuity, and customize your browsing experience. For example, a cookie may allow you to access certain pages without requiring you to log in again during an active session.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Please be aware that disabling cookies may limit your access to certain pages or features on the Exeter Sites. Our Sites may also contain links to third-party websites that use cookie and tracking technology independently of Exeter. We do not have access to or control over these other websites and any related cookie or tracking technology.

4.2 Web Analytics

We may use third-party analytics tools — such as Google Analytics — to understand how visitors interact with the Exeter Sites. These tools may collect personal information such as your IP address, device type, and pages visited to help us analyze site traffic and improve user experience. If you prefer to opt out of Google Analytics tracking, you may install the Google Analytics Opt-out Browser Add-on available from Google.

4.3 Web Beacons and Similar Tracking Technologies

We may use web beacons or similar tracking technologies to determine when and how many times a page has been viewed. This information is used in aggregate form to improve our websites.

4.4 Do Not Track

At this time, the Exeter Sites do not respond to “Do Not Track” signals transmitted by web browsers.

We do not sell your personal information to nonaffiliated third parties. We may disclose personal and browsing information in the following circumstances.

5.1 Affiliates

We may share your information with Exeter affiliated companies for purposes related to providing products, services, or offers we believe may be of interest to you, and to support the administration of your accounts and transactions.

5.2 Service Providers

We may share your information with nonaffiliated third-party service providers who perform functions on our behalf — such as payment processing, technology hosting, customer service, auditing, or marketing — under agreements that require them to use your information only as directed and necessary to perform those services.

5.3 Payment Processors

We may share information with intermediaries and payment processors who facilitate purchases or financial transactions conducted through the Exeter Sites.

5.4 Legal Authorities and Regulatory Bodies

We may disclose your information to law enforcement agencies, regulators, courts, or other governmental authorities:

In response to a lawful subpoena, court order, or government request
To comply with applicable federal or state laws or regulations
To prevent or investigate criminal activity, fraud, or misrepresentation
To protect the rights, property, or safety of Exeter, our clients, our employees, or the public

The law may not require your prior authorization for these disclosures and may not permit you to restrict them.

5.5 Business Transfers

We reserve the right to transfer your personal information in connection with a merger, acquisition, sale of assets, reorganization, bankruptcy, or similar business transaction in which personal information held by us is among the assets involved. By using the Exeter Sites, you acknowledge and consent to this potential transfer.

We may also share your information with third parties when you have given us your express authorization or consent to do so.

6. Third-Party Links

The Exeter Sites may contain links to third-party websites that are not operated or controlled by Exeter. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policy of every website you visit. When you click a link to leave the Exeter Sites, you are subject to the policies of that destination site.

7. Data Security

We maintain physical, technical, and administrative safeguards designed to protect your personal information from unauthorized access, use, or disclosure. Access to client information by Exeter employees is granted on a need-to-know basis and is protected by password controls, two factor authentication, when applicable. Employees with access to sensitive information are advised of their obligations to handle it appropriately.

While we take reasonable precautions to protect your information, no security system is impenetrable. We cannot guarantee that your information will be completely secure in all circumstances, including during transmission over the internet.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide services, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed for these purposes, we follow established internal procedures to dispose of it appropriately.

9. Your Choices and Rights

9.1 Accessing and Correcting Your Information

If you have an account with Exeter, you are responsible for keeping your profile information accurate and current. To access or request corrections to your personal information, please contact us using the information in Section 14 below.

9.2 Marketing Opt-Out

If you do not wish to receive marketing communications from Exeter — including seminar and webinar invitations, educational eNewsletters, or promotional offers — you may opt out at any time by:

Emailing us at:

notices@exeterco.com

Writing to us at:

The Exeter Group, LLC
Exeter 1031 Exchange Services, LLC
National Corporate Headquarters Office
404 Camino del Rio South, Suite 600
San Diego, CA 92108
Attn: Chief of Staff
(619) 239-3091

Exeter Trust Company
Exeter Asset Services Corporation
Exeter Management Corporation
205 Storey Boulevard, Suite 200
Cheyenne, WY 82009
Attn: Chief of Staff
(307) 222-8750

Please allow ten (10) business days for your request to be processed. Note that even after opting out of marketing communications, you may still receive transactional or administrative messages related to the administration of your accounts or services.

9.3 State-Specific Consumer Privacy Rights

Certain state privacy laws grant residents additional rights regarding their personal information. Depending on the state in which you reside, these rights may include:

The right to know what categories of personal information we have collected about you and how it has been used or disclosed
The right to access or receive a copy of your personal information
The right to correct inaccurate personal information
The right to delete personal information we hold about you, subject to applicable exceptions
The right to opt out of certain sharing of your information
The right to non-discrimination for exercising your privacy rights

States currently with active consumer privacy laws include, but may not be limited to: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Nevada, Oregon, Texas, Utah, Virginia, and others.

To submit a privacy rights request, or to appeal a prior decision regarding a privacy request, please contact us using the methods described in Section 14. We will endeavor to respond to verifiable consumer requests within 45 days of receipt. If additional time is required, we will notify you in writing.

10. Children’s Privacy

The Exeter Sites are not directed to or intended for use by persons under the age of 18. We do not knowingly collect personal information from any person we know to be under the age of 13 without verifiable parental or guardian consent. If you believe we have inadvertently collected information from a minor, please contact us using the information in Section 14 and we will take steps to delete it.

11. International Users

Exeter’s operations and websites are based in the United States. If you reside outside the United States and choose to provide personal information to us, please be aware that your information may be transferred to, stored, and processed in the United States or other jurisdictions that may not provide the same level of data protection as your country of residence. By providing us with your personal information, you consent to this transfer and use in accordance with this Policy.

12. Registration and Password Security

To access certain features of the Exeter Sites — including account services — you may be required to complete a registration form and establish a user account. You are responsible for maintaining the confidentiality and security of your user ID and password. Do not share your credentials with any other person for any reason. We recommend that you change your password regularly to reduce the risk of unauthorized account access. Completed transactional information is accessible only to the client who opened the transaction with Exeter and requires valid credentials to access.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or our services. When changes are made, we will update the “Last Updated” date at the top of this Policy. Your continued use of the Exeter Sites following any posted update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how we collect, use, and protect your information.

14. Contact Information

If you have questions or comments about this Privacy Policy, wish to exercise your privacy rights, or need to access or correct your personal information, please contact us through any of the following methods: