Privacy Policy

This Privacy Policy or “Policy”

This Privacy Policy or “Policy” explains how CygnusX Inc. and its subsidiaries, including the investment products it sponsors or manages from time to time (collectively, “CygnusX Inc.”, “we”, “our”, and “us”) collect and protect Personal Information (as defined below). If you have any questions that this Policy does not address, please contact us at the email address listed below. By creating an account on any CygnusX Inc. site, including without limitation www.cygnusx.co (the “CygnusX Inc. Sites”) or by otherwise submitting Personal Information to us, you give your consent to the collection and use of your Personal Information as explained in this Policy. This Policy is part of our Terms of Service, and all capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service.

CygnusX Inc.’s Policy applies to current and former CygnusX Inc. clients and any other users of the CygnusX Inc. Sites. The term “Personal Information” refers to non-public information that personally relates to or identifies you as an individual or entity.

Updates and Changes to Our Privacy Policy

Please note that, in the event of a change in policy, a revised Policy will promptly be posted to the CygnusX Inc. Sites. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. You agree to accept posting of a revised Policy electronically on the CygnusX Inc. Sites as actual notice to you. Any dispute over our Policy is subject to this notice.

How and Why We Gather Information

When you sign up to participate on the CygnusX Inc. Sites, you may be asked to provide information such as your full legal name, address, and date of birth, along with other Personal Information that is required to verify your identity and fulfill our legal and regulatory requirements. This information will also be used to transact your business and communicate with you. From time to time, we may request additional information to help us further assess your needs and preferences. We, or our analytics partners acting on our behalf, may gather your Personal Information from the activities of our partner analytics services.

We gather and process your Personal Information for a variety of reasons, depending on how you interact with our services, including:

• To facilitate account creation and authentication and otherwise manage your accounts.
• To deliver and facilitate delivery of our services to you.
• To respond to user inquiries/offer support.
• To send you administrative information (changes to our terms and policies, updates on products and services, etc.).
• To manage our working relationship with you.
• To request feedback and to contact you about your use of our products and services.
• To send you marketing and promotional communications. (You may opt out anytime.)
• To protect our services (fraud monitoring and prevention).
• To identify usage trends and improve our services.
• To determine the effectiveness of our marketing and promotional campaigns.

Types of Information We Collect

The information we or our business partners, on our behalf, collect and maintain about you is provided during the course of using your device, the CygnusX Inc. Sites, or third-party websites; when you sign up to receive additional information; or during your transactions with private issuers who have engaged CygnusX Inc. to provide certain services in the context of a private securities transaction through CygnusX Inc.. Personal Information may come from the following sources:

• Information you provide to us when you fill out documents, complete a form, or make a request for services, including but not limited to: name, address, age, investment objectives, job title, investment experience, assets and liabilities and/or income details (and documentation used to verify those details), telephone number, e-mail address, and similar information. We may collect certain sensitive information, including social security or taxpayer identification number and other financial information.

• Automatically collected information when using or navigating the CygnusX Inc. Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. Like many companies, we collect information through cookies and similar technologies for security, analytics, and reporting purposes.

• Information from other sources. In order to enhance our ability to provide relevant marketing, offers, and services to you, and to update our records, CygnusX Inc. and its subsidiaries may obtain information (including Personal Information) about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties.

How We Protect Your Information

Keeping Information Safe

We limit access to the Personal Information you provide us to those employees who need access to it in order to provide you with services related to the transactions you enter into through the CygnusX Inc. Sites. In keeping with industry standards and practices, we maintain appropriate physical, electronic, and procedural safeguards and controls designed to protect your Personal Information.

We have invested in software, systems, and procedures aimed at offering you a safe and secure transaction environment. While no security system is absolutely impenetrable, we continuously review, refine, and upgrade our security technology as new tools become available.

The Importance of Being Accurate

We have security standards and procedures in place designed to prevent unauthorized access to your Personal Information. A key part of this process helps ensure that the Personal Information we have about you is accurate and up to date. If you discover inaccuracies or if your Personal Information changes, please notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security.

Your Rights Over Personal Information

Subject to applicable laws, rules, and regulations, you have rights regarding your Personal Information, including access, rectification, erasure, blocking, restriction of use, objection to use, data portability, and lodging a claim with your local data protection authority, as applicable.

If you would like to discuss or exercise the above rights, please contact us using the details at the end of this Privacy Policy.

An Ongoing Commitment to Your Privacy

We are committed to protecting the privacy of our former clients as we are of our current clients. If you become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you dispose of your investments with us in any way, CygnusX Inc. will retain your information as required by regulatory compliance, internal record-keeping, and other legal purposes.

How Information Helps Both You and Us

Our mission is clear: to build transparent, familiar investment products that facilitate access to the digital asset class. Information about you and your accounts plays a key role in our ability to succeed in this mission. For example, we use information about you to:

• Respond accurately and efficiently to your requests for assistance; and
• Secure your investments and help protect both you and CygnusX Inc. from fraud.

Sharing Your Information with Unaffiliated Third Parties

We Limit the Sharing of Information

To protect your privacy, we limit the sharing of your Personal Information outside of CygnusX Inc.. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:

• We engage qualified and reputable third parties to help us carry out certain functions such as account processing, client services, and data collection. For example, when you invest through the CygnusX Inc. Sites, we share your Personal Information with third-party service providers to perform required background checks, facilitate document execution, or provide execution and clearing services on your behalf.

• As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Information may be part of the transferred assets.

• CygnusX Inc. may share information with our subsidiaries if the information is required to provide the services you request. A subsidiary is a company that we own or control.

• CygnusX Inc. also reserves the right to disclose your Personal Information where required by law or regulation to government entities, law enforcement, self-regulatory organizations, or regulatory bodies. We may also disclose your information to credit reporting or collection agencies, or to protect our rights or property.

• Notwithstanding the foregoing, all Personal Information shall be dealt with in accordance with any local legislation, including but not limited to the General Data Protection Regulation, to the extent CygnusX Inc. is or becomes subject to such regulation.

Reviewing, Changing or Correcting Information

You are responsible for helping us maintain the accuracy and completeness of your Personal Information and other data. We urge you to review your information regularly to ensure that it is correct and complete. If you would like to review your Personal Information or if you believe that any of your Personal Information is incorrect, or if you have any questions regarding your Personal Information or this Privacy Policy, please contact us at privacy@CygnusX Inc..com.

Third Party Sites

If at any time you choose to purchase a product or service offered by another company, any Personal Information you share with that company will be subject to the privacy policies of the applicable third party and not this Policy. Other than as described above, we are not responsible for the privacy policies or the content of third party sites and/or services (each, a “Third Party Service”) we link to, and have no control of the use or protection of information provided by you or collected by those Third Party Services. Whenever you elect to hyperlink to a Third Party Service, you may be asked to provide registration or other information. Please note that this information is going to a third party, and you should familiarize yourself with the privacy policy provided by that party.

Privacy and the Internet

The following additional information will be of interest to you if you access the CygnusX Inc. Sites or its subsidiaries’ products or services through one or more of the CygnusX Inc. Sites:

• The CygnusX Inc. Sites are built upon an infrastructure with multiple layers of protection. We use industry-standard encryption technologies to help safeguard your information.
• Security is a cooperative effort between us and the users of the CygnusX Inc. Sites. You are responsible for your user identification and password and should not share them with anyone. Please notify us if you suspect unauthorized access or use.
• Cookies are small text files that may be placed on your web browser when you visit the CygnusX Inc. Sites to help “remember” your identity and provide easier navigation. You can set your browser to inform you when cookies are set or to prevent cookies from being set, though doing so may reduce functionality.
• Web surfing data (e.g., your browsing behavior, page visits, and service preferences) may be collected by CygnusX Inc. or by our service providers. We use these data for administrative purposes, to assess the value and performance of our products, to improve your experience, or as otherwise permitted by law.
• The CygnusX Inc. Sites may include social media features and widgets (e.g., the Facebook “Like” button, “Share This” button, or similar features). These features may set cookies or collect your IP address. Your interactions with these features are governed by the privacy policy of the company providing it.

What Legal Bases Do We Rely On to Process Your Information?

If you are located in the EU or UK, this section applies to you.

We rely on the following legal bases to process your Personal Information:

• Consent. We may process your information if you have given us consent to use it for a specific purpose. You may withdraw consent at any time.
• Performance of a Contract. We may process your Personal Information as we believe is necessary to perform according to any contract with you, including providing our services or at your request prior to entering a contract.
• Legitimate Interests. We may process your information as we believe is reasonably necessary to achieve our legitimate business interests, so long as those interests do not outweigh your fundamental rights and freedoms. For example, we may process your Personal Information to send you information about our products, diagnose problems, or support our marketing activities.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as cooperating with law enforcement or regulatory agencies.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Statutory Disclosures

What categories of Personal Information do we collect?

We have or our analytics partners have collected the following categories of Personal Information in the past twelve (12) months:

We may also collect other Personal Information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our support channels;
• Participating in customer surveys; and
• Facilitating the delivery of our services and responding to your inquiries.

CygnusX Inc. has not sold any Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months. CygnusX Inc. has disclosed the following categories of Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers (e.g., name, postal address, contact info, unique personal identifier, IP address, email address, and account name).
• Category B. Personal Information as defined in the California Customer Records law (name, contact information, education, employment, etc.).
• Category C. Characteristics of protected classifications under California or federal law (gender or date of birth).
• Category D. Financial information (e.g., net worth, banking info, portfolio allocations, investment experience, annual income, tax documents).
• Category F. Internet or other electronic network activity information (e.g., browsing history, online behavior, interactions with our or other websites).
• Category G. Geolocation data (device’s geographic location).
• Category I. Professional or employment-related information (job title, work history, qualifications).

Your rights with respect to your Personal Information

Right to request deletion of the data — Request to delete

You can ask for the deletion of your Personal Information. If you ask us to delete your Personal Information, we will respect your request and delete your Personal Information, subject to certain exceptions provided by law, rule, or regulation, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal or regulatory obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• Whether we collect and use your Personal Information;
• The categories of Personal Information that we collect;
• The purposes for which the collected Personal Information is used;
• Whether we sell your Personal Information to third parties;
• The categories of Personal Information that we sold or disclosed for a business purpose;
• The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling Personal Information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so we can match it with information you have previously provided. Depending on the type of request, we may contact you through a communication method (e.g., phone or email) that you have previously provided. We may also use other verification methods as the circumstances dictate.

We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information. However, if we cannot verify your identity from information already on file, we may request that you provide additional information for verification and for security or fraud-prevention purposes.

Other privacy rights

• You may object to the processing of your Personal Information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf.
• You may request to opt out from the future selling of your Personal Information to third parties. Upon receiving an opt-out request, we will act upon it as soon as feasible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us at the email address below. If you have a complaint about how we handle your data, we would like to hear from you.

CalOPPA Disclosures

Do Not Track Signals

We do not currently respond to web browsers’ “Do Not Track” signals that provide a method to opt out of the collection of information about visitors’ activities on the CygnusX Inc. Sites or across other websites. If we do so in the future, we will provide all relevant information in this Privacy Policy.

Minors

We do not knowingly solicit data from or market to children under 18 years of age. By using the services, you represent that you are at least 18. If we learn that Personal Information from users less than 18 years of age has been collected, we will promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us at the email address below.

Third Party Data Collection

We may authorize certain third parties, including Google Analytics, to track usage and collect information about users and their activities on the CygnusX Inc. Sites or with other CygnusX Inc. assets.

Contact Us: If you have questions or comments about this Policy, you may email us at: privacy@cygnusx.co