EXCHANGIFI, LLC

PRIVACY POLICY

LAST UPDATED: February 25, 2025

2000 PGA Blvd.  |  Palm Beach Gardens, FL 33408  |  561-206-2416  |  [email protected]  |  https://exchangifi.com

Thank you for your interest in ExchangiFi, LLC (“ExchangiFi,” “we,” “us,” or “our”). ExchangiFi owns, licenses, and operates the website located at https://exchangifi.com and any related applications, platforms, and tools (collectively, the “Site” or “Platform”). This Privacy Policy describes how we collect, use, disclose, and protect information from and about you through our Site and any other interaction or communication that you may have with or through ExchangiFi (collectively, the “Services”).

The Platform is an educational technology platform designed to provide users with general information, educational content, and resources relating to Section 351 ETF exchange transactions. We are not a financial institution, investment adviser, broker-dealer, law firm, or tax advisory firm.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

1. SCOPE AND KEY TERMS

This Privacy Policy applies to personal information that ExchangiFi processes during its business operations as a “data controller,” meaning activities for which we determine the purpose and means of processing such personal information.

For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device, or is otherwise afforded protection under a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law.

The term “you” refers to any individual accessing or using our Services, including registered account holders, visitors to our Site, and any other person who interacts with us through the Platform or through our contact channels.

2. THE TYPES AND CATEGORIES OF PERSONAL INFORMATION WE COLLECT

ExchangiFi collects different types of personal information from you depending on the Services you use, how you use them, and the information you choose to provide us. We collect personal information: (i) when you provide it directly to us; (ii) automatically through technology when you use the Services; and (iii) from other sources.

2a. Personal Information You Provide Directly to Us

You may choose to provide personal information to ExchangiFi as you use the Services, such as when you register for an account, contact us with questions, or use our educational tools. Although you can choose not to provide personal information, in some cases this may result in our inability to provide you certain Services. Generally, we may collect the following categories of personal information directly from you:

• Contact data, such as your name, postal address, email address, and telephone number.
• Registration information, such as usernames and passwords created when you establish an account on the Platform.
• Professional information, such as the name and address of the company you work for and your title, where you choose to provide such information.
• Communications data, such as any questions, comments, or feedback you send us through our contact forms, email, or other channels.
• Marketing preferences, such as your preferences for receiving educational materials, newsletters, or updates from ExchangiFi.
• Any other information you voluntarily provide to us through the Site or in connection with your use of the Services.

2b. Personal Information Collected Automatically

When you access our Site, we automatically collect certain data using technical means and tools. This data relates to your device and your experience on our Site, including the following:

• Usage and Device Data: When you access and use our Site, we automatically collect details of your access and use, including traffic data, usage logs, browsing history on the Site, and the resources you access. We may also collect information about your device and internet connection, including the device’s unique identifier, general location inferred from IP address (city and state), operating system, browser type, and mobile network information.
• Cookies and Tracking Data: We use cookies and other tracking technologies within our Site. A cookie is a small file placed on your device. You may refuse cookies by activating the appropriate setting on your device; however, if you do so, some parts of our Site may become inaccessible or not function properly. Our Site may also use web beacons (also referred to as clear gifs or pixel tags) that allow us to analyze your use of our Site. For more information, please see our Cookie Policy at https://exchangifi.com/cookie-policy.

2c. Personal Information Collected from Other Sources

We may collect personal information from third parties, such as publicly available databases, analytics providers, advertising partners, and our service providers. We may also collect information about you from other users of the Platform who reference or interact with you through the Services.

3. HOW WE USE YOUR PERSONAL INFORMATION

Generally, we use the personal information we collect about you in order to operate our Site, provide the Services, respond to your questions and concerns, comply with our legal obligations, and promote our business interests, including:

• Provide the Services: To operate our Platform, provide educational content and tools, save your preferences and settings, and otherwise deliver the Services you have requested.
• Account Management: To create and manage your account, authenticate your identity, and maintain the security of your account.
• Communications: To communicate with you, including by responding to your inquiries, sending you information about your account, sending legal notices, and, where you have opted in, contacting you about educational materials, updates, or other information we believe may be of interest to you.
• Improve Our Services: To develop, modify, analyze, and improve our Site and Services, including enhancements to existing features, content, and tools.
• Security and Fraud Prevention: To protect the security and integrity of our Site and Services, detect and prevent fraud, unauthorized access, and other harmful or illegal activities, and enforce our Terms of Service.
• Legal and Regulatory Compliance: To comply with applicable laws, regulations, and legal processes, including responding to lawful requests from governmental or regulatory authorities.
• Analytics: To develop internal analyses, measure the effectiveness of our educational content, and understand how users interact with our Platform.
• Business Operations: To manage administrative and operational matters, administer our service provider and vendor relationships, and conduct auditing and quality control.
• Recruiting: For recruiting, hiring, and talent management purposes if you apply for a position with ExchangiFi.
• With Your Consent: For other purposes for which we have obtained your express consent.

We may also aggregate and/or de-identify information collected through our Services so that such information can no longer be linked to you or your device. We may use such aggregated or de-identified data for any lawful purpose, including research and product improvement, and may share such data with third parties.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information with certain organizations and third parties in accordance with applicable law, including as set out below:

• Affiliates and Subsidiaries: We may share personal information with our affiliates and subsidiaries in order to provide or improve our Services or support our business operations.
• Service Providers: We may disclose personal information with companies that provide services on our behalf, such as website hosting and analytics providers, email service providers, customer support tools, payment processors, and security vendors. These service providers are contractually obligated to use personal information only as necessary to perform services for us.
• ETF Sponsors and Third-Party Data Providers: To the extent you interact with or express interest in ETF-related content on the Platform, we may share limited information with the applicable ETF fund sponsors or third-party data providers as necessary to facilitate that interaction. Any such sharing will be limited to what is reasonably necessary for the purpose of the interaction.
• Legal and Compliance: We may disclose personal information if required by law or government order, or to comply with a legal process, such as a subpoena, court order, or regulatory inquiry. We may also disclose personal information to defend or protect our legal rights or in connection with a government investigation.
• Business Restructuring: In connection with any merger, acquisition, reorganization, sale of assets, or similar transaction, we may disclose personal information to the extent reasonably necessary to proceed with the transaction. In such circumstances, we will notify affected users as required by applicable law.
• Protection of Rights and Safety: We may disclose personal information when we believe such disclosure is necessary to protect the safety, rights, or property of ExchangiFi, our users, or the public.
• With Your Consent: We may disclose personal information to third parties when you have affirmatively consented to or directed such disclosure.

ExchangiFi does not sell your personal information to third parties for their own marketing or advertising purposes.

5. COOKIES AND TRACKING TECHNOLOGIES

ExchangiFi uses cookies and similar tracking technologies to enhance your experience on our Site, analyze usage, and deliver relevant content. Cookies are small text files stored on your device that help us recognize returning visitors, remember preferences, and understand how users interact with our Platform.

You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. We do not respond to “Do Not Track” signals from browsers at this time, as there is no agreed-upon industry standard for how such signals should be interpreted.

For more information about our use of cookies, please see our Cookie Policy at https://exchangifi.com/cookie-policy.

6. LINKS TO OTHER WEBSITES

Our Site may, from time to time, include links to third-party websites, including ETF fund sponsor websites, regulatory agency websites, and other educational resources. This Privacy Policy does not apply to such third-party websites. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party websites you visit. You assume all risks associated with providing any personal information to third parties via such links.

7. DATA RETENTION

We retain personal information for no longer than necessary for the purposes for which it is processed, or as required by applicable law. The length of time for which we retain information depends on the purposes for which we collected it and any applicable legal or regulatory retention requirements.

In general, we retain account and registration data for the duration of your account with us and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. We retain usage and analytics data for shorter periods consistent with their operational purpose. When personal information is no longer needed, we delete it or anonymize it in accordance with our data retention practices.

8. SECURITY

We use appropriate technical, physical, and organizational measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include, but are not limited to, encryption of data in transit and at rest, access controls, and regular security assessments.

However, no security system is impenetrable. We cannot guarantee the absolute security of your personal information. If you believe your account has been compromised, please contact us immediately at [email protected].

9. INTERNATIONAL TRANSFERS

ExchangiFi is headquartered in Palm Beach Gardens, Florida, United States. The personal information that we collect and process is primarily retained and stored in the United States. If you access our Services from outside the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence.

By using our Services, you consent to the transfer of your personal information to the United States as described in this Privacy Policy. We comply with applicable legal requirements governing the transfer of personal information across borders.

10. CHILDREN’S PRIVACY

The Services are intended for general audiences and not for children under the age of 16. We do not knowingly collect personal information from children under the age of 16. If we become aware that we have inadvertently collected personal information from a child under the age of 16 without verifiable parental consent, we will take reasonable steps to delete such information as soon as possible.

If you believe we may have collected personal information from a child under 16, please contact us immediately at [email protected].

11. MARKETING COMMUNICATIONS

If, in accordance with applicable legal requirements, we send you marketing or promotional communications regarding our Services or educational content, you may opt out of receiving such communications at any time by:

• Clicking the “unsubscribe” link in any marketing email we send you.
• Contacting us directly at [email protected] with your opt-out request.

Please note that even if you opt out of marketing communications, we may still send you transactional or administrative communications, such as account-related notices, legal notices, and updates to this Privacy Policy or our Terms of Service.

12. CALIFORNIA RESIDENTS — ADDITIONAL PRIVACY RIGHTS

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) provide you with certain additional rights regarding your personal information.

Categories of Personal Information Collected

Depending on how you interact with our Site and Services, we may collect the following categories of personal information:

• Identifiers, such as your name, email address, IP address, and device identifiers.
• Internet or Other Electronic Network Activity Information, such as browsing history on our Site, and your interactions with our Platform.
• Professional or Employment-Related Information, such as your title or employer name, where you provide this voluntarily.
• Communications Data, such as the contents of messages or inquiries you send to us.

This information is used and disclosed for the various business purposes and to the categories of third parties described in Sections 3 and 4 of this Privacy Policy.

California Privacy Rights

California residents have the following rights under the CCPA/CPRA:

• Right to Know: The right to know what personal information we collect about you, our intended use of it, and the purposes for collecting it.
• Right to Access: The right to access specific pieces of personal information we have collected about you.
• Right to Correction: The right to request correction of inaccurate personal information.
• Right to Deletion: The right to request deletion of your personal information, subject to certain exceptions.
• Right to Data Portability: The right to receive your personal information in a portable, commonly used format.
• Right to Non-Discrimination: The right not to be discriminated against for exercising your CCPA/CPRA rights.

Do Not Sell or Share My Personal Information

ExchangiFi does not sell your personal information to third parties, nor do we share your personal information for cross-context behavioral advertising purposes within the meaning of the CCPA/CPRA.

How to Exercise Your California Rights

To exercise any of the rights described above, please contact us using the information in Section 19 (Contact Us) of this Privacy Policy. We will verify your identity before responding to your request and will respond within the timeframes required by applicable law.

13. NEVADA PRIVACY RIGHTS

ExchangiFi does not currently conduct “sales” of personal information for purposes of Nevada law. Nonetheless, Nevada residents may submit a request directing us not to sell personal information we maintain about them. To exercise this right, please contact us in accordance with the Contact Us section of this Privacy Policy.

14. EUROPEAN UNION, SWITZERLAND, AND UNITED KINGDOM RESIDENTS

If you are a data subject in the European Union (“EU”), Switzerland, or the United Kingdom (“UK”), and you provide personal information directly to ExchangiFi, we are required to provide you with additional information regarding your data protection rights and our legal basis for processing.

Data Protection Rights

If you are located in the EU, Switzerland, or the UK, you have the following data protection rights:

• Right to be Informed: The right to be informed about what personal information ExchangiFi collects and processes about you.
• Right of Access: The right to ask us whether we process any of your personal information and, if so, to receive access to it.
• Right to Rectification: The right to have inaccurate or incomplete personal information corrected.
• Right to Erasure: The right to request deletion of your personal information under certain circumstances.
• Right to Restriction of Processing: The right to request that we limit the processing of your personal information in certain circumstances.
• Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: The right to object to the processing of your personal information where we process it on the basis of legitimate interests.
• Right to Withdraw Consent: Where we rely on your consent as the basis for processing, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Legal Basis for Processing

Where applicable, we process your personal information on the following legal bases:

• Consent: Where you have given us your consent to process your personal information for a specific purpose, such as subscribing to our communications.
• Legitimate Interests: Where processing is necessary for our legitimate interests, such as improving our Services, monitoring the security of our Platform, and understanding how users interact with our Site.
• Contract Performance: Where processing is necessary to fulfill a contractual obligation to you.
• Legal Compliance: Where processing is required to comply with a legal or regulatory obligation.

Complaints

If you have a concern about our data processing and are located in the EU, Switzerland, or the UK, you have the right to file a complaint with your applicable data protection authority. We would, however, appreciate the opportunity to address your concerns before you contact a data protection authority, and we invite you to contact us first using the information in Section 19 (Contact Us) of this Privacy Policy.

For EU data protection authorities, please see: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For Switzerland, please contact the Federal Data Protection and Information Commissioner at https://www.edoeb.admin.ch. For the UK, please contact the Information Commissioner’s Office at www.ico.org.uk.

15. OTHER PRIVACY RIGHTS

Individuals in certain other jurisdictions, including but not limited to Canada, Australia, Japan, and other countries with applicable data protection laws, may have certain rights regarding their personal information. These rights may include the right to access, correct, or delete personal information, and the right to lodge a complaint with a data protection authority. To exercise any applicable rights, please contact us using the information in Section 19 (Contact Us) of this Privacy Policy. We will consider your request and respond based on the applicable legal regime in your jurisdiction.

16. SOCIAL MEDIA

ExchangiFi may maintain a presence on social media platforms. If you contact us through a social media platform, we may respond through the same channel. Any use of a social media platform is also subject to the policies and terms of the relevant platform, and ExchangiFi has no control over that platform’s use of your information. Our Site may include social media features or widgets; these may collect your IP address and the webpage you are visiting, and may set a cookie. Such features are either hosted by a third party or hosted directly on our Site.

17. PERSONS WITH DISABILITIES

ExchangiFi strives to ensure that every person has access to the information provided on our Site, including this Privacy Policy. If you would like this Privacy Policy provided in an alternative format or require other accessibility accommodations, please contact us using the information in Section 19 (Contact Us) and we will make reasonable efforts to accommodate your needs.

18. CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible on the Site, and we will update the “Last Updated” date at the beginning of this document. If we make a material change to this Privacy Policy, we will provide you with appropriate notice as required by applicable law. By continuing to use the Services after changes are posted, you confirm that you have read and understood the latest version of this Privacy Policy.

19. CONTACT US

If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information, or would like to exercise a data privacy right, please contact us at:

ExchangiFi, LLC

Attn: Privacy Request

2000 PGA Blvd.

Palm Beach Gardens, FL 33408

Phone: 561-206-2416

Email: [email protected]

Website: https://exchangifi.com