Privacy Policy - Medalist Diversified REIT

Medalist Diversified REIT, Inc.

Effective Date: January 16, 2026

Last Updated: January 16, 2026

Introduction

Medalist Diversified REIT, Inc. ("Medalist," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at www.medalistreit.com (the "Site") or interact with our services.

By accessing or using our Site, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this policy, please do not use our Site.

Information We Collect

Information You Provide to Us

We may collect personal information that you voluntarily provide when you:

Complete contact forms or request information about our investment offerings
Subscribe to our mailing list or newsletters
Request offering materials or Private Placement Memoranda
Submit accredited investor qualification documentation
Communicate with us via email, phone, or other channels
Apply to invest in a Delaware Statutory Trust offering

This information may include:

Name
Email address
Phone number
Mailing address
Accredited investor status and supporting documentation
Investment preferences and objectives
Financial information necessary to verify accredited investor status
Tax identification numbers (for investors)
Any other information you choose to provide

Information Collected Automatically

When you visit our Site, we may automatically collect certain information about your device and usage, including:

IP address
Browser type and version
Operating system
Device identifiers
Pages visited and time spent on pages
Referring website addresses
Date and time of visits
Clickstream data

We collect this information using cookies, web beacons, and similar tracking technologies. See the "Cookies and Tracking Technologies" section below for more details.

How We Use Your Information

We may use the information we collect for purposes including:

Responding to your inquiries and requests
Providing information about our DST investment offerings
Verifying your accredited investor status
Processing investment subscriptions
Sending newsletters, market updates, and promotional communications (with your consent)
Improving our Site and user experience
Analyzing Site usage and trends
Complying with legal and regulatory obligations
Protecting against fraud and unauthorized transactions
Communicating with you about your investments or account
Fulfilling any other purpose for which you provide information

How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers

We may share information with third-party vendors who perform services on our behalf, such as:

Website hosting and maintenance
Email delivery services
Customer relationship management
Payment processing
Legal and accounting services
Due diligence and verification services (such as FactRight)

Broker-Dealers and Financial Intermediaries

If you invest through a financial advisor, registered investment advisor, or broker-dealer, we may share information necessary to process your investment and provide ongoing investor communications.

Legal and Regulatory Compliance

We may disclose information when required by law, regulation, or legal process, including:

SEC reporting requirements
FINRA regulations
Court orders or subpoenas
Government investigations

Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.

With Your Consent

We may share your information for other purposes with your express consent.

Cookies and Tracking Technologies

Our Site uses cookies and similar tracking technologies to enhance your experience and collect information about how you use the Site.

Types of Cookies We Use

Essential Cookies: Necessary for the Site to function properly
Analytics Cookies: Help us understand how visitors interact with our Site
Functional Cookies: Remember your preferences and settings

Your Cookie Choices

Most web browsers are set to accept cookies by default. You can usually modify your browser settings to decline cookies if you prefer. However, this may affect your ability to use certain features of our Site.

Third-Party Links

Our Site may contain links to third-party websites, including:

NASDAQ investor relations platforms
SEC EDGAR filings
News and press release services
Social media platforms

We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, use, or disclosure. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Investor records may be retained for extended periods as required by securities regulations.

Your Privacy Rights

All Users

You may:

Request access to the personal information we hold about you
Request correction of inaccurate information
Request deletion of your information (subject to legal and regulatory retention requirements)
Opt out of marketing communications at any time
Withdraw consent where processing is based on consent

To exercise these rights, contact us using the information provided below.

California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

Right to Know: You may request information about the categories and specific pieces of personal information we have collected, the sources of that information, our purposes for collecting it, and the categories of third parties with whom we share it.
Right to Delete: You may request that we delete your personal information, subject to certain exceptions.
Right to Correct: You may request that we correct inaccurate personal information.
Right to Opt Out: You may opt out of the sale or sharing of your personal information. Note: We do not sell personal information.
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To submit a request, contact us at Solutions@MedalistREIT.com or call (949) 415-6633. We may need to verify your identity before processing your request.

Nevada Residents

Nevada residents may opt out of the sale of personal information. We do not currently sell personal information as defined under Nevada law.

Children's Privacy

Our Site and services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will post the updated policy on this page with a revised "Last Updated" date. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

Medalist Diversified REIT, Inc.

Email: Solutions@MedalistREIT.com

Phone: (949) 415-6633

Mailing Address: P.O. Box 8436 Richmond, VA 23226

Disclosures

Medalist Diversified REIT, Inc. is a publicly traded company listed on NASDAQ under the ticker symbol MDRR. Securities offered through Realta Wealth, LLC, Member FINRA/SIPC. Medalist Diversified REIT and Realta Wealth, LLC are not affiliated entities.

NASDAQ: MDRR