Privacy Policy

Atlas Digital Equity, Inc.

Effective Date: June 2, 2026   Last Updated: June 2, 2026 (cookie disclosures)

1. Introduction

Atlas Digital Equity, Inc. ("Atlas," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit https://atlasdigitalequity.com, use our platform and related services (collectively, the "Platform"), or otherwise interact with us.

By using the Platform, you acknowledge the practices described in this Privacy Policy. If you do not agree, do not use the Platform.

This Privacy Policy is incorporated into our Terms of Service.

2. Information We Collect

We collect information in three ways: information you provide to us, information collected automatically, and information from third parties.

2.1 Information You Provide

Depending on how you interact with the Platform, we may collect:

• Identity and contact information: name, email address, mailing address, phone number, date of birth, and government-issued identification numbers (such as Social Security number or taxpayer identification number, or equivalent foreign identifiers).
• Verification information: copies of government-issued IDs, selfies or other biometric identifiers used for identity verification, proof of address, employment information, and source-of-funds documentation.
• Investor-qualification information: information about income, net worth, professional licenses, sophistication, beneficial ownership, and entity structure used to verify status as an accredited investor, qualified institutional buyer, qualified purchaser, or other category.
• Financial information: bank account numbers, wire instructions, brokerage account information, custodial account information, and Transaction history.
• Account information: username, password, multifactor authentication credentials, and account preferences.
• Communications: the content of messages, emails, support tickets, calls, and other communications with us.
• User Content: any content you submit through the Platform.

2.2 Information Collected Automatically

When you access the Platform, we and our service providers automatically collect:

• Device and connection data: IP address, device type, operating system, browser type and version, language settings, mobile network information, and unique device identifiers.
• Usage data: pages or screens viewed, features used, time spent, click paths, referring/exit pages, dates and times of access, and interaction events.
• Location data: approximate location derived from IP address. We do not collect precise GPS location unless you grant permission through your device settings.
• Cookies and similar technologies: see Section 6 below.

2.3 Information from Third Parties

We may receive information about you from:

• Identity-verification, KYC, AML, and fraud-prevention providers.
• Sanctions, politically-exposed-persons, and adverse-media screening providers.
• Banks, broker-dealers, custodians, and transfer agents in connection with your Transactions.
• Issuers whose Securities are made available on the Platform.
• Credit bureaus and financial-data aggregators (where applicable and authorized by you).
• Professional and social-media services when you connect them or log in through them.
• Co-investors, advisers, or representatives you authorize to provide information on your behalf.
• Public sources, including government databases and corporate filings.

3. How We Use Information

We use information for the following purposes:

• Provide the Platform: create and maintain your Account, authenticate you, process Transactions, communicate with you, and provide customer support.
• Verify identity and eligibility: perform KYC, AML, sanctions, and accredited-investor or other qualification checks.
• Compliance and risk management: detect, prevent, and investigate fraud, security incidents, abuse, and other unlawful activity; comply with legal obligations, court orders, regulatory examinations, audits, and internal policies; enforce our Terms of Service.
• Improve and develop the Platform: analyze usage, perform research, test, debug, and develop new features.
• Personalize: tailor content and communications to you.
• Marketing: send you information about Atlas and the Platform, subject to your preferences and applicable law.
• Corporate transactions: in connection with a merger, acquisition, financing, or sale of assets.
• Other purposes disclosed to you at the time of collection or for which you have consented.

We do not use information for automated decision-making that produces legal or similarly significant effects without appropriate human review.

4. How We Share Information

We may share information with:

• Service providers and processors: technology, hosting, analytics, identity-verification, payments, banking, custody, transfer-agent, communications, customer-support, and other vendors who process information on our behalf, subject to contractual confidentiality and security obligations.
• Issuers:when reasonably necessary to facilitate a Transaction or comply with the Issuer's transfer restrictions, governance rights, or recordkeeping requirements.
• Counterparties to Transactions: information reasonably necessary to consummate a Transaction.
• Affiliates: entities under common control with Atlas, who will use the information consistent with this Privacy Policy.
• Professional advisers: lawyers, accountants, auditors, and other professionals.
• Regulators and law enforcement: the SEC, FINRA, FinCEN, state securities regulators, banking regulators, tax authorities, courts, and other governmental authorities, in response to subpoenas, court orders, regulatory requests, or where required or permitted by law.
• Acquirers: in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business.
• With your consent or at your direction.

We do not sell your personal information for money.We may, however, share certain online identifiers and usage data with analytics or advertising partners in ways that may be considered "sharing" or "selling" under certain state privacy laws. See Section 9 for how to opt out.

5. Legal Bases for Processing (EEA/UK Residents)

If you are located in the European Economic Area, United Kingdom, or Switzerland, our legal bases for processing your personal information include:

• Performance of a contract (to provide the Platform and process Transactions);
• Legal obligation (to comply with securities, AML, tax, and other laws);
• Legitimate interests (to operate, secure, and improve the Platform, prevent fraud, and pursue corporate transactions), where not overridden by your rights;
• Consent (where required, such as for certain cookies or marketing); and
• Vital interests or public interest, where applicable.

You may withdraw consent at any time where processing is based on consent.

6. Cookies and Tracking Technologies

We use cookies and similar technologies (including browser local storage) to operate the Platform, keep it secure, and remember your preferences. We group them into the categories below. The first time you visit, a consent banner lets you accept all, reject all, or choose categories individually. You can change your choice at any time using the "Cookie preferences" link in the site footer.

We do not use advertising cookies, and we do not run third-party analytics or marketing trackers (such as Google Analytics, advertising pixels, or session-replay tools). Strictly necessary cookies do not require consent; non-essential cookies are not used unless you opt in. We honor Global Privacy Control (GPC) signals: where your browser sends a GPC signal, we treat it as a request to decline non-essential cookies. Disabling functional cookies may cause the Platform to forget your preferences.

You may also control cookies through your browser settings. Blocking strictly necessary cookies may prevent the Platform from working.

7. Data Retention

We retain personal information for as long as necessary to provide the Platform, comply with our legal and regulatory obligations (which may require multi-year retention under securities and AML laws, generally seven (7) years after the end of our relationship with you, or longer where required by applicable law), resolve disputes, and enforce our agreements. When information is no longer required, we securely delete or anonymize it.

8. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. These include:

• Encryption. Encryption of data in transit using industry-standard protocols (TLS) and encryption of sensitive data at rest.
• Access controls. Role-based access controls that limit personnel access to personal information on a need-to-know basis, with access reviewed and adjusted as roles change.
• Multifactor authentication. Multifactor authentication required for User account access and for administrative access to systems that process personal information.
• Logging and monitoring. Logging of system and account activity, with monitoring designed to detect and respond to anomalous or unauthorized behavior.
• Vendor management. Diligence and contractual safeguards for service providers that process personal information on our behalf.
• Secure development. Secure software development and change-management practices, including code review and dependency management.
• Personnel. Background checks where permitted by law, confidentiality obligations, and ongoing security and privacy training for personnel with access to personal information.
• Incident response. A documented process for identifying, escalating, and responding to suspected security incidents.

No system is perfectly secure. We cannot guarantee the security of information transmitted to or from the Platform, and you transmit information at your own risk. If we become aware of a security incident affecting your personal information, we will notify you and applicable authorities as required by law.

9. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

• Access the information we hold about you;
• Correct inaccurate or incomplete information;
• Delete your information, subject to legal-retention obligations;
• Portability: receive a copy of your information in a portable format;
• Restrict or object to certain processing;
• Opt out of "sales" or "sharing" of personal information and certain targeted-advertising or profiling activities (under U.S. state privacy laws);
• Withdraw consent where processing is based on consent;
• Appeal a decision we make about a rights request (under certain U.S. state laws); and
• Lodge a complaint with a supervisory authority (EEA/UK) or the attorney general of your state.

To exercise these rights, contact us at privacy@atlaseq.xyz. We will verify your identity before responding and will respond within the timeframe required by applicable law. You may use an authorized agent to submit requests where permitted.

We will not discriminate against you for exercising your privacy rights.

9.1 California Residents

If you are a California resident, you have rights under the California Consumer Privacy Act, as amended ("CCPA/CPRA"). The categories of personal information we collect, the sources, the business purposes, and the categories of third parties to whom we disclose information are described in Sections 2, 3, and 4 of this Privacy Policy. We have collected each of the following categories of personal information in the last 12 months: identifiers; California Customer Records information; commercial information; internet/network activity; geolocation data; professional or employment-related information; financial information; and inferences. We have disclosed each of these categories to the categories of recipients listed in Section 4 for business purposes. We do not knowingly sell personal information of consumers under 16.

9.2 Other State Rights

If you reside in Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Tennessee, Iowa, Indiana, New Jersey, Delaware, New Hampshire, Maryland, Minnesota, Nebraska, Rhode Island, or another state with a comprehensive privacy law, you may have similar rights. Contact us at privacy@atlaseq.xyz to exercise them.

10. International Data Transfers

Atlas is based in the United States, and we and our service providers process information in the United States and other countries. If you access the Platform from outside the United States, your information may be transferred to, stored, and processed in jurisdictions with different data-protection laws. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) for cross-border transfers.

11. Children's Privacy

The Platform is not directed to children under 18. We do not knowingly collect personal information from children under 18. If you believe we have collected information from a child under 18, contact us at privacy@atlaseq.xyz and we will delete it.

12. Third-Party Sites and Services

The Platform may contain links to, or integrations with, third-party websites and services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top indicates when it was last revised. Material changes will be communicated through the Platform or by email. Your continued use of the Platform after the change becomes effective constitutes acceptance of the updated Privacy Policy.

14. Contact Us

For privacy questions, complaints, or to exercise your rights:

Atlas Digital Equity, Inc. Attention: Privacy
10845 Griffith Peak Drive, 2nd Floor, Las Vegas, NV 89135
Email: privacy@atlaseq.xyz

© 2026 Atlas Digital Equity, Inc. All rights reserved.