ClearTrust

Privacy Policy

Last updated: October 16, 2026

ClearTrust ("Company", "we", "our", or "us") respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you through our website and any other online services that link to this policy (our "Services") and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries) that does not link to this policy; or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Services.

By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children's and Minors' Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

"Personal data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual.

The Website is informational, and you are not required to register for an account or provide any personal information to access and use it. The types and categories of data we collect or process are limited to:

• Device and usage information that we collect automatically, such as the type of device you use, your browser type, your IP address, and information about how you access and use the Website, including through cookies and similar technologies.
• Contact information that you choose to provide, such as your name and email address, only if you voluntarily contact us (for example, by email).

We do not collect the following categories of information through the Website: your date of birth, government-issued identification numbers, tax information, or details about your accounts or transactions. We also do not intentionally collect any sensitive personal data through the Website.

We may also derive non-personal statistical or aggregated data from the information described above. Statistical or aggregated data does not directly identify a specific person; for example, we may aggregate usage data to calculate the percentage of users who access a particular part of the Website. If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

How We Collect Your Personal and Other Data

You Provide Information to Us. The Website does not require you to provide personal information. If you choose to contact us voluntarily, for example by email, we collect the information you provide (such as your name and email address) and the content of your message so that we can respond.

Automatically Through Our Services. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies, including details of your interactions with our Services, such as traffic data, logs, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking).

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

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

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by contacting us using the details in the Contact Information section below. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and the content, features, and information we make available through the Services.
• Respond to your inquiries, comments, or requests and otherwise communicate with you.
• Send you updates, newsletters, or other communications you have requested.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information, to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• Fulfill any other purpose for which you provide the information.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

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

We may also use your information to contact you about content, updates, or services that may be of interest to you. If you do not want us to use your information in this way, please contact us using the details in the Contact Information section below.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

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

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data 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 ClearTrust's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by ClearTrust is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal data:

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

The categories of personal data we may disclose include:

• Device and usage information.
• Contact information you voluntarily provide to us and the content of any communications you send to us.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.
• Promotions by the Company. If you do not wish us to use your information to promote our own or third parties' products or services, you can opt out by adjusting your account settings and preferences or by contacting us using the details in the Contact Information section below.
• Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target audience preferences, you can opt out by contacting us using the details in the Contact Information section below.

Location data choices:

• Location Data. You can choose whether or not to allow the Services to collect and use information about your device's location through the device's privacy settings. If you block the use of location information, some Services features may become inaccessible or not function properly.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Using Personal Data for Sales, Targeted Advertising, and Profiling for Certain Legal or Similarly Significant Decisions. You may request that we do not use your personal data for these purposes. Some states may also grant you the ability to learn more about or challenge those automated decisions.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please contact us using the details in the Contact Information section below. To appeal a decision regarding a consumer rights request, contact us using those same details, and we will respond as required by applicable law.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data "sales" as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt-out rights may submit a request to us using the details in the Contact Information section below. However, please note that we do not currently sell data triggering that statute's opt-out requirements.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

ClearTrust
1607 Capitol Ave suite 320 Cheyenne WY 82001
info@cleartrust.io

Capability, market and structure availability is subject to qualification and the applicable operating context.