Privacy and Cookies Notice

Sidewalk Infrastructure Partners, LLC and its affiliates, including SIP OperationsCo, LP and SIP ManagementCo, LLC (together, “SIP,” “we,” “our,” or “us”) is committed to comply with all applicable data privacy laws, including protecting the security and confidentiality of any personally identifiable information (“PII”). SIP’s Privacy and Cookies Notice is comprised of two parts: (1) the SIP Privacy Notice for Third Parties, which sets forth how we process the personal data of third parties, including website visitors and potential partners and stakeholders, and (2) the SIP Privacy Notice for Job Applicants, Employees, Interns, Contractors, and Other Personnel, which sets forth how we process the personal data of job applicants and any SIP personnel. Each Privacy Notice also provides information on your data privacy rights, if applicable, in the jurisdiction in which you reside, and how to exercise them.

SIP is a consolidated holding company that builds innovative technology-enabled infrastructure companies and projects that deliver positive social and environmental impact. SIP’s platforms are next-generation infrastructure developers with proprietary technologies, all uniquely positioned at the intersection of technology and infrastructure. SIP’s platforms are focused on the future of: the electrical grid, roads, wireless networks, data centers, and recycling.

SIP is organized in the state of Delaware and is headquartered at 10 Jay Street, 10th floor, Brooklyn, NY 11201. Questions about data privacy, including a request to exercise any data privacy right, should be addressed to legal@sidewalkinfra.com with “privacy” in the subject line.

SIP Privacy Notice for Third Parties

LAST UPDATED: JULY 2025

This SIP Privacy Notice for Third Parties applies to third parties, including website visitors, individuals who receive our newsletter and other materials, and potential investors and other stakeholders (in this context of this Privacy Notice, “you” or “your”) and describes how your personal data may be processed by Sidewalk Infrastructure Partners, LLC and its affiliates (together, “SIP,” “we,” “our,” or “us”). It also sets forth your rights with respect to your personal data if you are located in certain jurisdictions.

If you have questions about this Privacy Notice, the processing of your personal data, or want to exercise any applicable privacy right, you may contact us at legal@sidewalkinfra.com.

Collection of Personal Data

We may collect the following categories of information about you:

Identifiers, such as name and contact information (phone number, email, address)
Information related to your visit to our website (such as pages visited or your location)
Information related to your thoughts and opinions on SIP, including SIP’s mission and its operating companies, and its business activities
Information related to your views and demographics, which, depending on the jurisdiction, may be defined as sensitive personal data (such as race, religion, union membership, political activities or contributions)
For potential vendors, third-party service providers, investors or other stakeholders, Information about your reputation, financial background, experience (such as work history), past and current political contributions and activities, and other information acquired upon similar due diligence
For visitors to our offices, video footage in our common office space areas for security reasons

SIP does not utilize automated decision-making for the personal data described in this Privacy Notice for Third Parties.

Note that SIP’s website is only intended for adults and it does not knowingly or intentionally market any products or services to any individuals under the age of eighteen.

How We Collect Personal Data

We typically collect personal data via the following methods:

Our website
Questionnaires, surveys, interviews, emails, and other similar forms of communication
Directly from you or from our other investors, partners, other key stakeholders, vendors and/or service providers
Publicly available information from third party sources
Cookies and web beacons
At conferences and other industry events
For visitors to our offices, video footage in our common office space areas for security reasons
Other standard business methods, such as requests for proposals and business referrals

Purpose of the Processing and Legal Basis for Doing So

We process personal data for the following reasons:

To promote and market SIP’s mission and SIP’s operating companies’ products and services to you, including new developments via newsletters and similar materials and invitations to events
To gain insights about website visitors, our business partners and stakeholders, the communities we serve, and their respective needs
To improve our and our operating companies’ products and services
To facilitate business transactions, such as evaluating new investors or vendors, via due diligence
In the course of regular business activities, including invoicing, facilitating introductions and other networking activities within our industry, and engaging in transactions including a transfer or sale of business assets
For security purposes
To ensure compliance with applicable laws and our internal policies
In the event of a dispute and/or litigation, to defend and protect SIP and its operating companies

Under the United Kingdom (“UK”), European Union (“EU”), and Swiss General Data Protection Regulation (collectively, “GDPR”), we rely on the following legal bases for processing your personal data:

Legitimate interest, as is the case for our standard business activities, such as contacting you for direct marketing, business outreach, and due diligence
Necessary for the performance of a contract, where we have entered into a contract with you
Where we have a legal obligation to do so (for example, in a situation where we have received a subpoena)
In limited cases, consent, which you may withdraw at any time after you have provided it by contacting legal@sidewalkinfra.com (note that where you have provided consent, and it is necessary for us to provide you with a service or product, if you then withdraw that consent we will no longer be able to provide you with that service or product)

Who We Share Your Personal Data With

We share personal data with our operating companies and affiliates. We may also share your personal data with the following types of third parties:

Our partners, investors, directors, and other key stakeholders
Our advisors such as law firms, auditors, and consultants
Vendors and other third-party service providers such as marketing companies and event partners
Other business contacts where doing so facilitates usual business activities (e.g., introductions, events, travel)
Google products and tools, including Google suite
Business software tools, which may process your contact information and other business-related information

SIP reserves the right to disclose your personal data as required by law, when SIP believes that disclosure is reasonably necessary to establish, exercise, defend or otherwise protect its rights (including in any legal or equitable claim) and/or comply with a judicial proceeding, court order, request from a regulator, national security agency, for the purposes of public importance or any other legal or investigatory process involving SIP, including any confidential alternative dispute resolution process. Should SIP, or any of its affiliated entities, be the subject of a divestment, acquisition or other business sale, SIP may disclose your personal data to the potential buyers and/or new owners of the relevant business and their advisors.

Data Transfers and Data Storage

SIP is based in the United States (“U.S.”) and its business information, including personal data, is stored on servers located in the U.S.

SIP processes the personal data of website visitors, business partners, investors, and other individuals interested in learning about SIP or becoming partners with SIP who may be residents of the UK, EU, or Switzerland. We do so only in the limited contexts set forth above (see “Collection of Personal Data,” “How We Collect Personal Data,” “Purposes of Processing and Legal Basis for Doing So,” and “Who We Share Your Personal Data With.”)..

SIP processes this personal data in reliance on the EU-U.S., UK Extension to the EU-U.S., and Swiss-U.S. Data Privacy Framework (“DPF”). The DPF was developed by the U.S. Department of Commerce, the European Commission, the UK Government, and the Swiss Federal Administration to provide a reliable transfer mechanism for personal data transferred to the U.S. from the EEA, UK, and Switzerland while ensuring data protection that is consistent with EU, UK, and Swiss law. As a company certified to the DPF, we are subject to the jurisdiction of the U.S. Federal Trade Commission.

We are committed to following DPF Principles for all personal data transferred from the EU, UK, and Switzerland. If there is any conflict between the terms in this Privacy Notice and the DPF, the DPF will govern. To learn more about the DPF, please visit https://www.dataprivacyframewo... To view our certification on the Data Privacy Framework List, please visit https://www.dataprivacyframewo....

In adherence to the DPF Principles, SIP is responsible for personal data it receives from the EEA, UK, and Switzerland, including any personal data that it subsequently transfers to a third party acting as an agent on our behalf. With respect to personal data received or transferred pursuant to the DPF, SIP is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SIP may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with DPF requirements, SIP commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Di... for more information or to file a complaint. The services of JAMS are provided at no cost to you. Note that in certain conditions, it is possible to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Data Retention

SIP retains personal data only as long as necessary for the purpose for which it was collected. For example, we will retain your email address for as long as it is active and you do not request to have it deleted. Financial information, which may contain personal data (for example, invoice records), is held for ten years.

Data Security

SIP utilizes industry accepted security measures to protect against loss, misuse, unauthorized access, disclosure, alteration, and destruction of data submitted to our systems, both during transmission and when we receive it. Access to your personal data is limited to only those persons who need access to perform or provide their job or service, both internally and with our third-party service providers. We have put in place, and require vendors to put in place, appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In the event of a data security breach, you will be notified as required under applicable law.

Cookies

A cookie is a small file of letters and numbers that is downloaded onto your computer when you visit a website. Cookies are used by many websites and can do a number of things, including remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website. SIP utilizes web logging and cookies to gather data about visitors to our site in order to gather insights and improve our services.

We may use Google Analytics and similar tools to help analyze how users interact with our website and to display customized ads and other content to our users during a current browsing session or in the future when the user is online. These analytics are performed by using the technological means described above to monitor a user’s interactions with the website and do not involve the collection of any additional Information.

Most browsers are initially set up to accept cookies, but users can reset their browsers to refuse all cookies or to indicate when a cookie is being sent or to refuse online tracking. To disable and reject certain cookies, follow the instructions associated with your Internet browser. If you would like to clear, delete, or block your cookies, you can do so via settings on your webpage browser. Please visit the following pages to learn more about how to control cookies: Microsoft Edge cookies information, Internet Explorer cookies information, Chrome cookies information, Firefox cookies information, Safari mobile device information, and Safari desktop information. Our website, as with most websites, does not currently recognize opt-out preference signals (and we are not required to do so under applicable laws).

Even where you reject a cookie, you may still use the website, but your ability to use certain features or offerings may be impaired. For example, if you return to the website, you may have to re-enter Information you previously supplied to us. We may retain cookie data indefinitely.

Your Data Privacy Rights

SIP and its operating companies respect the privacy of all individuals. You may access, correct, and control your personal data that SIP processes, in each case to the extent provided by applicable law. If you have a question or concern about how your personal data is being processed, or would like to correct your personal data, you may contact legal@sidewalkinfra.com.

If you are located in the UK, EEA, or Switzerland, you have the following data privacy rights under the GDPR:

The Right to Information and Transparency. Individuals have the right to know how their personal data will be used and processed and, if applicable, to provide informed consent before such processing occurs.
Right of Access. Individuals can request to access the personal data that organizations hold about them.
Right of Rectification. Individuals can request that personal data about them be corrected.
Right to Erasure. Also known as the “Right to be Forgotten,” an individual can request that their personal data be deleted.
Right to Object to or Restrict Processing. Individuals can request a limitation on the processing of their personal data in certain situations, including opting out of the sale of their personal data.
Right to Data Portability. Individuals can request to receive their personal data from us in a machine-readable, commonly used format of our choosing.
Right to not be the subject of automated individual decision-making, including profiling. Individuals have the right not to be subject to a decision based solely on automated processing, including profiling, except as allowed under applicable data protection laws. (Note that we do not engage in automated decision-making for any individuals subject to this Privacy Notice.)

You also have the right to lodge a complaint with a supervisory authority. UK residents may contact the Information Commissioner's Office: https://ico.org.uk/make-a-comp.... Residents of EEA member states may reference this list to find their appropriate supervisory authority: https://www.edpb.europa.eu/abo.... Swiss residents may contact the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edo....

If you are in a jurisdiction that grants you specific privacy rights that you wish to exercise, please contact legal@sidewalkinfra.com with your request, noting the jurisdiction in which you reside.

SIP may need to request specific information from you to help it confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. SIP may also contact you to ask you for further information in relation to your request to speed up its response.

Changes to Processing

The most current version of this Privacy Notice is on SIP’s website. We will use your personal data only for the purposes for which we collected it and have disclosed to you within this Privacy Notice. If we need to use your personal data for an unrelated or new purpose, we will update this Privacy Notice, notify you of the change, and (if applicable) explain the legal basis that allows us to do so.

SIP SIP Privacy Notice for Job Applicants, Employees, Interns, Contractors, and Other Personnel

LAST UPDATED: JULY 2024

This SIP Privacy Notice for Job Applicants, Employees, Interns, Contractors, and Other Personnel applies to all job applicants, employees, interns, temps, and other contractors performing work for or on behalf of SIP (in this context of this Privacy Notice, “you” or “your”) and describes how your personal data may be processed by Sidewalk Infrastructure Partners, LLC and its affiliates (together, “SIP,” “we,” “our,” or “us”). It also sets forth your rights with respect to your personal data if you are located in certain jurisdictions.

If you have questions about this Privacy Notice, the processing of your personal data, or want to exercise any applicable privacy right, you may contact us at legal@sidewalkinfra.com.

Collection of Personal Data

We may collect the following categories of information about you:

Identifiers, such as name, contact information (phone number, email, address), social security number
Information related to your education and employment history
Information related to the work you perform during your employment with SIP, such as performance reviews and evaluations, disciplinary records, training records, metadata relating to the use of SIP equipment and tools, your location when you are traveling on behalf of SIP or using SIP equipment
Information related to your visit to our external website and internal Intranet
Information gathered via your use of SIP equipment and tools, such as computer log-in and email
Potentially sensitive personal data, if provided by you during the application process or during your work with SIP, such as your race, gender, or health information
Video footage in our common office space areas for security reasons
Any other personal data that is relevant to your job application and/or employment or contracts with SIP

Note that for healthcare insurance purposes, SIP’s healthcare insurance vendor directly collects healthcare-related information from employees and is subject to the Health Insurance Portability and Accountability Act (“HIPAA”) and other federal and state privacy laws requiring that your personal data be kept secure. SIP administers this plan for relevant personnel, but does not have direct access to any personal health information that might be provided to the vendors or medical providers under this plan.

How We Collect Personal Data

We typically collect personal data via the following methods:

The application and recruitment process, including applications through our website, using external recruiters, sites such as LinkedIn, and referrals from SIP personnel and SIP stakeholders
Our internal employment evaluation process
Interviews, surveys, ad hoc emails and information that are related to SIP or its operating companies’ employment-related matters
SIP equipment and tools (for example, location data through a SIP-issued device or email sent via company email addresses)
Our external websites (including cookies and beacons) and our internal Intranet
Video footage in our common office space areas for security reasons
Background check agencies, references you provide, and publicly available sources

Purpose of the Processing and Legal Basis for Doing So

We process your personal data in order to make employment-related and business decisions, including hiring and promotions, understanding and meeting personnel needs (for example, processing payroll or granting reasonable accommodations if requested), to ensure compliance with applicable laws and our internal policies, to protect SIP and its operating companies in the event of a potential or actual dispute or lawsuit, in the event of a transfer or sale of our business assets, and, if required, to comply with any requests from regulators or courts of law.

Under the United Kingdom (“UK”), European Union (“EU”), and Swiss General Data Protection Regulation (collectively, “GDPR”), we rely on legitimate interest as the legal basis for processing your personal data. In some cases we also process your personal data where it is necessary for the performance of a contract or where we have a legal obligation to do so.

In the limited circumstance where we request consent for processing personal data, and where you have provided such consent, you have the right to withdraw your consent at any time by contacting legal@sidewalkinfra.com. Please note that withdrawing your consent in such cases might mean we cannot provide you with the service for which we are collecting the personal data. This also applies to any instance where the basis for processing is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Who We Share Your Personal Data With

We may share your personal data with the following types of third parties:

External recruiters
Background check service providers
References provided by candidates in the recruitment process
Google products and tools, including Google suite
Payroll and health insurance vendors
SIP’s 401k platform
SIP’s whistleblower platform, for example, if you submit a report to the platform (any such reported personal data is not shared with SIP)
Advisors such as law firms, auditors and consultants
SIP’s operating companies, affiliates, investors, and any other business-related contacts
Business software tools, which may process your contact information and other business-related information
Travel or event partners (e.g., event spaces, hotels or airlines in connection with work-related travel or activities)

Data Transfers and Data Storage

If you are applying to, are employed by, or are performing work as an intern, contractor, or other type of personnel for one of SIP’s operating companies, your information may be transferred to SIP, which is located in the United States, and stored on servers located in the United States. SIP has entered into data processing agreements with its operating companies and any vendors who may receive information from residents of the UK, European Economic Area (“EEA”) or Switzerland. SIP utilizes the European Union Commission's Standard Contractual Clauses (“SCCs”) and the UK’s International Data Transfer Agreement (“IDTA”) as a valid transfer mechanism. If you are a resident of the UK, EEA, or Switzerland and would like a copy of the SCCs and IDTA, please email SIP’s CLO at legal@sidewalkinfra.com.

Automated Decision-Making

SIP may work with external recruiters who rely on limited automated decision-making when reviewing job applications. In such instances, the criteria must be objectively applied and not implicate any categories of sensitive personal data. An example of this criteria might be whether the applicant has a college degree or has listed any experience relevant to the posted job title. The consequences of such decision-making is intended to ensure that applicants are not contacted about employment for opportunities for which they do not fit the predetermined objective hiring criteria.

Data Retention

SIP retains personal data only as long as necessary for the purpose for which it was collected. If you are an applicant, SIP retains applicant personal data for a period of up to two years after you apply to a role at SIP. If you are an employee, intern, contractor or other SIP personnel, SIP retains personal data for a period of up to seven years after the end of your employment or engagement with SIP. Financial information, which may contain personal data (for example, payroll records), is held for ten years. Note that in some cases, we may retain personal data for longer if necessary to demonstrate compliance with applicable laws and regulations, in relation to a cause of action, or for other legitimate business purposes.

Data Security

SIP utilizes industry accepted security measures to protect against loss, misuse, unauthorized access, disclosure, alteration, and destruction of data submitted to our systems, both during transmission and when we receive it. Access to your personal data is limited to only those persons who need access to perform or provide their job or service, both internally and with our third-party service providers. We have put in place, and require vendors to put in place, appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In the event of a data security breach, you will be notified as required under applicable law.

Cookies

A cookie is a small file of letters and numbers that is downloaded onto your computer when you visit a website. Cookies are used by many websites and can do a number of things, including remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website. SIP utilizes web logging and cookies to gather data about visitors to our site in order to gather insights and improve our services. This may include job applications and SIP personnel who visit our site.

We may use Google Analytics and similar tools to help analyze how users interact with our website and to display customized ads and other content to our users during a current browsing session or in the future when the user is online. These analytics are performed by using the technological means described above to monitor a user’s interactions with the website and do not involve the collection of any additional Information.

Most browsers are initially set up to accept cookies, but users can reset their browsers to refuse all cookies or to indicate when a cookie is being sent or to refuse online tracking. To disable and reject certain cookies, follow the instructions associated with your Internet browser. If you would like to clear, delete, or block your cookies, you can do so via settings on your webpage browser. Please visit the following pages to learn more about how to control cookies: Microsoft Edge cookies information, Internet Explorer cookies information, Chrome cookies information, Firefox cookies information, Safari mobile device information, and Safari desktop information. Our website, as with most websites, does not currently recognize opt-out preference signals (and we are not required to do so under applicable laws).

Even where you reject a cookie, you may still use the website, but your ability to use certain features or offerings may be impaired. For example, if you return to the website, you may have to re-enter Information you previously supplied to us. We may retain cookie data indefinitely.

The Right to Information and Transparency. Individuals have the right to know how their personal data will be used and processed and, if applicable, to provide informed consent before such processing occurs.
Right of Access. Individuals can request to access the personal data that organizations hold about them.
Right of Rectification. Individuals can request that personal data about them be corrected.
Right to Erasure. Also known as the “Right to be Forgotten,” an individual can request that their personal data be deleted.
Right to Object to or Restrict Processing. Individuals can request a limitation on the processing of their personal data in certain situations, including opting out of the sale of their personal data.
Right to Data Portability. Individuals can request to receive their personal data from us in a machine-readable, commonly used format of our choosing.
Right to not be the subject of automated individual decision-making, including profiling. Individuals have the right not to be subject to a decision based solely on automated processing, including profiling, except as allowed under applicable data protection laws. (Note that we do not engage in automated decision-making for any individuals subject to this Privacy Notice.)

You also have the right to lodge a complaint with a supervisory authority. UK residents may contact the Information Commissioner's Office: https://ico.org.uk/make-a-comp.... Residents of EEA member states may reference this list to find their appropriate supervisory authority: https://www.edpb.europa.eu/abo.... Swiss residents may contact the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edo....

If you are in a jurisdiction that grants you specific privacy rights that you wish to exercise, please contact legal@sidewalkinfra.com with your request, noting the jurisdiction in which you reside.

SIP may need to request specific information from you to help it confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. SIP may also contact you to ask you for further information in relation to the request to speed up its response.

Changes to Processing

The most current version of this Privacy Notice is on SIP’s website. We will use your personal data only for the purposes for which we collected it and have disclosed to you within this Privacy Notice. If we need to use your personal data for an unrelated or new purpose, we will update this Privacy Notice, notify all relevant personnel of the change, and (if applicable) explain the legal basis that allows us to do so.