LAST UPDATED: February 25, 2026

ViaTerra Website Privacy Policy

Welcome to the ViaTerra website (www.ViaTerraFL.com or the “Website”), which showcases the ViaTerra master planned community which is owned by Lake Wales Property Holdings, LLC and its affiliates Lake Wales II Property Holdings, LLC and Lake Wales III Property Holdings, LLC (collectively, the “Landowner” or “Master Developer”). This Website is owned and operated by BTI Lake Wales Developer, LLC (“Consultant”), a development consultant the Landowner. This written policy (the “Privacy Policy”) is designed to tell you about practices regarding Consultant’s collection, use, and disclosure of information that you may provide via this Website and certain related services. Please be sure to read this entire Privacy Policy before using, or submitting information, to this Website.

Your Consent

This Privacy Policy sets forth the Website’s current policies and practices with respect to nonpublic personal information of the users of the Website. By using this Website, you agree with the terms of this Privacy Policy. Whenever you submit information via this Website, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

The following discloses our information gathering and dissemination practices for all Consultant web pages.

PLEASE READ THE FOLLOWING PRIVACY POLICY (OTHERWISE NOTED AS THIS “AGREEMENT”) CAREFULLY BEFORE USING THE WEBSITES BY USING THIS WEBSITE, YOU SIGNIFY YOUR ASSENT TO THIS AGREEMENT. IF YOU DO NOT ASSENT TO THIS AGREEMENT, PLEASE DO NOT USE THIS WEBSITE.

COLLECTION OF PERSONAL INFORMATION

We collect several types of information from and about users, including information:

• By which you may be personally identified, such as name, postal address, e-mail address or telephone number (“personal information”);
• That is about you but individually does not identify you, such as non-personal demographic information.
• About your internet connection, the equipment you use to access our Site and usage details.

Consultant recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Consultant has collected the following categories of personal information from consumers within the last twelve (12) months:

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and/or other tracking technologies.
• Through analysis of trends in what is reviewed and to see what may be purchased.

INFORMATION YOU PROVIDE TO US

The information we collect may include:

• Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our emails or text messages, posting material or requesting further services.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Site (i.e. whether you purchase from a developer that develops a portion of the ViaTerra project/community).
• Your search queries to the Site.
• Information provided to us through social networks or third-party platforms when you, for example, engage with our social media content, or communicate with us via social media (such as your name, email, profile picture, likes, location, friend list, photos or other information described by the applicable social network or platform).

What information is stored in the Consultant database?

User: Our secure database stores information provided by a user during the sign-up process (this includes your name, address, email address, telephone).

Site: Consultant monitors traffic visiting our Site. More detailed information is set forth in this Privacy Policy.

Access to stored information is limited to authorized individuals of the software provider.

Use of Information

We may use the information we collect in the following ways:

• Send you requested service information
• Provide you with a requested service
• Respond to customer service requests
• Respond to your questions and concerns
• Send you marketing communications or advertisements
• Share your information with certain 3rd parties for them to send marketing communications or advertisements as described in more detail below.*
• Improve our website or services in connecting potential purchasers with developers
• Personalize your web or service experience
• To protect against fraud, and insure confidentiality and security

*We may share the information provided through the Website with affiliated entities and projects for their use in the same ways as noted above.

We may share with the Master Developer of a particular project referenced on this Website, and we and they may share your contact information with developers and home developers that may purchase part of the master development project. We may also share with affiliated Master Developers or related parties of other similar projects who may share with developers and home developers that may purchase part of other master development projects.

As you navigate through and interact with our Website, or our advertising or applications on third-party websites and services, we may automatically collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
• Information about your computer or handheld device and internet connection, including your IP address, operating system and browser type.

The information we collect automatically is statistical data, and does not alone identify any individual. It helps us to improve our Site and to deliver a better and more personalized service by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. We may place the tags on our webpages called “web beacons.” These are computer instructions that link web pages to particular web servers and their cookies.

Sharing of Information

We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell, rent, trade, or otherwise share your personal information with third parties without first providing you notice and choice.

With Service Providers: We may provide your personal information to agents or service providers acting on our behalf for limited purposes. For example, we may share personal information with our agents or service providers to send you email on our behalf. These third parties are authorized to use your personal information only to perform the service they are providing for us.

Security/Fraud Protection: We may also share your information for the purposes of protecting against fraud, and insure confidentiality and security.

As Required By Law: We reserve the right to disclose your personal information as required by law (e.g., to comply with a subpoena, warrant, court order, or similar legal process served on our website) and when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, and/or respond to a government request. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Business Transition: In the event Consultant goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email and/or a prominent notice on our website of any such change in ownership or control of your personal information, as well as any choices you may have regarding your personal information.

Developers: We may share your information with the Master Developer of a particular project referenced on this Website, and we and they may share your contact information with individual developers and home developers (homebuilders) that may purchase part of the master development project. We may also share with affiliated Master Developers and consultants of other similar projects who may share with developers and home developers that may purchase part of other master development projects.

Targeted Advertising & Third-Party Advertiser Use of Cookies

Third-party advertisers, ad networks and ad servers may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about users of our website. This may include information about users’ behavior on our and other websites to serve them interested-based behavioral advertising. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

We may also use third-party platforms and technology, including platforms operated by social networks, such as Google and Facebook to show you interest-based ads. These companies have specific Interest-Based Ads programs that match people that have shown interest in Company or our projects through our websites, or other services with users on their platforms and properties. If we participate in these programs, we convert your personal information (which may include name, email address or telephone number) or other information into a unique value which can be matched by those third parties to a user on their platform or with other data they may have collected from you. This matching allows us to deliver interest-based ads to users of these platforms. To opt-out of these ads, you must change your advertising preferences for those third-party platforms.

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates. (Note: We do NOT share any banking information with such entities)
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Consultant’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Consultant is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Consultant, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

In the preceding twelve (12) months, Consultant has disclosed the following categories of personal information to the third parties listed above for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.

If we have collected or received your data in connection with a financial product or service, you may have additional rights regarding this sharing which are described below.

Sale of Personal Information

The CCPA similarly requires Consultant to provide you with a statement on the sale of personal information. In the preceding twelve (12) months, Consultant has not sold personal information.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us.

Promotional Offers from Consultant. If you do not wish to have your e-mail address, cell phone number or other contact information used by Consultant to promote our own or our third-party partner’s products or services, you can opt-out by sending us an e-mail stating your request to info@viaterrafl.com.

If we have sent you a promotional e-mail, you can tell us not to send you promotional e-mail by clicking on the unsubscribe link within the emails you receive from us. If you no longer wish to receive promotional text messages, you can text STOP.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about advertising networks and to opt out of interest-based advertising, visit the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.

REVIEWING, UPDATING AND MODIFYING PERSONAL INFORMATION

Subject to applicable law, you may have the right to request access to and receive details about the personal information we maintain about you, update and correct inaccuracies in your personal information, and have the information blocked or deleted, as appropriate. The right to access personal information may be limited in some circumstances by local law requirements. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to review, change or delete your personal information by sending an email to info@viaterrafl.com or clicking on our Data Request link.

THIRD-PARTY LINKS

Occasionally, we may link to third-party content, applications, or websites on our website. This third-party content has their own privacy practices. This Privacy Policy does not describe how these third parties collect and use the data.

Notice to Users Outside of the United States

This Online Privacy Policy is intended to cover collection of information on our Website from residents of the United States. If you are visiting our Website from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located, and our central database is operated. The data protection and laws of the United States and other countries might not be as comprehensive as those in your country. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy. This Website is NOT intended for residents of the European Union. Please do not use it if you reside there.

IP ADDRESS

We log all connections to our web servers. Those log files include your IP address. An IP address is NOT personally identifiable information, but general information about your location, connection to the Internet, and your Internet Service Provider. We use your IP address to help diagnose problems with our server and to administer the Sites. Additionally, we will use your IP address to track your navigation of the Sites and we may use your navigation history in current and future marketing efforts to you and to others.

SECURITY

We care about protecting the security of your personal information, and we have implemented security procedures to protect the personal information that you provide to us. However, no method of transmitting or storing electronic data is ever completely secure, and we cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this policy. Some of the measures we take are:

• Limiting access to personal information to those employees who are critical to communicating with you and/or processing contributions.
• Implementing appropriate physical, electronic and procedural safeguards to guard against unauthorized access or use.
• Requiring appropriate consents and protections from our business partners before we share any personally identifiable information.

While we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations of the internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party. Moreover, where you may be required to use passwords, or other special access features on this Website, it is your responsibility to safeguard them.

PASSIVE INFORMATION COLLECTION

As you navigate through a website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection.

This Website may use Internet Protocol (IP) addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our Website, and administer and improve services to our consumers.

A “cookie” is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences.

“Session cookies” are temporary bits of information that are erased once you exit your web browser window or otherwise turn your computer off. Session cookies are used to improve navigation on websites and to collect aggregate statistical information. This Website uses session cookies.

“Persistent cookies” are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., username), helping to determine what areas of the website visitors find most valuable, and customizing the website based on your preferences. This Website uses persistent cookies.

“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the website server information such as the IP address and browser type related to the visitor’s computer. This Website uses Internet tags. “Navigational data” (“log files,” “server logs,” and “clickstream” data) and “Internet Tags” are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. This Website uses navigational data.

LINKS

This Website may contain links to websites of third parties not affiliated with Consultant. This Privacy Policy will not apply to these third-party websites and the Website is not responsible for the privacy practices or the content on any of these other websites, even where these third-party sites indicate a special relationship or “partnership” with the Website. We do not disclose personally identifiable information to those responsible for the linked sites. The linked sites, however, may collect personal information from you when you link to their site. This collecting of information is not subject to the control of the Website. To ensure protection of your privacy, always review the privacy policies of the sites you visit by linking from this Website.

TESTIMONIALS

We may display personal testimonials on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name and city/state of residence. If you wish to update or delete your testimonial, you can contact us at info@viaterrafl.com.

CALIFORNIA DO NOT TRACK DISCLOSURES

How do we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services?

We currently do not respond to DNT signals in browsers because we do not track individual users across the web.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit www.viaterrafl.com?

No.

NOTICE TO CALIFORNIA RESIDENTS

With certain exceptions, residents of the State of California may request (a) disclosure of personal information collected, (b) disclosure of personal information sold or disclosed for a business purpose, (c) deletion of personal information, (d) to opt out of the sale of personal information, and (e) access and data portability. Moreover, we will not discriminate based on your exercise of such rights. If you are a California resident and want to make any such requests, please contact us through our website (www.viaterrafl.com), BTI Lake Wales Developer, LLC, Privacy Policy, 401 E. Las Olas Blvd., Suite 1870, Fort Lauderdale, FL 33301 or info@viaterrafl.com.

NOTICE TO VERMONT RESIDENTS

In response to Vermont regulations, we automatically treat accounts with Vermont billing addresses as if you requested that we do not share your information with nonaffiliated third parties and that we limit the information we share with our affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.

NOTICE TO NEVADA RESIDENTS

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing info@viaterrafl.com. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.

PROTECTING CHILDREN’S PRIVACY ONLINE

The Website is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Website. We do not knowingly collect information from children under 18 without parental consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA). If you believe that we have received information from a child or other person who is not of a majority age in their relevant jurisdiction, please contact us at our email or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information.

CHANGES TO THIS PRIVACY POLICY

This privacy policy describes the types of information we currently collect, and the ways we use and protect that information. From time to time, we may collect different types of information and use that information in different ways, for example, when we add features or services to Consultant. In these cases, we may edit this policy to explain the new practices. Because protecting your privacy is very important to us, we do not expect major changes in policy. However, if we do make significant changes in our practices, we will include announcements on the www.viaterrafl.com home page so that you will know to review the revised policy.

CONTACT US

Email us. E-mail us at info@viaterrafl.com

Call us. Our customer service team is available at (888) 919-5509 between the hours of 8 am – 5 pm EST Monday through Friday.

Write us. Update your communication preferences by mailing us a letter at:

BTI Lake Wales Developer, LLC
401 E. Las Olas Blvd., Suite 1870
Fort Lauderdale, FL 33301

If you have any questions regarding this Privacy Policy, or www.viaterrafl.com, don’t hesitate to contact us!

PLEASE PRINT AND RETAIN A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS.