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PRIME TRUST PRIVACY NOTICE

Updated January 22, 2023. Previous versions can be located here. Your continued
use of our websites and services is your agreement to the updated policy.


INTRODUCTION

At Prime Trust, LLC (“Prime Trust,” “we,” “our,” or “us”), we understand and
respect our users’ need for privacy. This Privacy Notice (“Notice”) describes
how we collect, use, share, and process personal information; what rights and
choices you may have with respect to your information; how you may contact us,
and how we protect your personal information when you:

 1. Visit Prime Trust’s websites, such as https://www.primetrust.com or
    https://www.fundamerica.com (our “Sites”);

 2. Access or use products, services, and related applications offered by Prime
    Trust (collectively, the “Services”) or third party applications relying on
    such an API as an issuer, integrator, or an end user (collectively,
    “Customer”), such as managing your account or participating in a
    crowdfunding campaign on our platform; and     

 3. Interact with us in any way, including registering for, attending, or
    otherwise partaking in our events, tutorials, or webinars (collectively,
    “Marketing Activities”).

This Notice does not cover:

 * Job applicants – To learn more about our privacy practices related to
   personal information for recruiting purposes, please see our Job Applicant
   Privacy Notice.    


ABOUT PRIME TRUST PRODUCTS AND SERVICES     

Prime Trust is a full-service company with financial infrastructure API products
that allow financial technology and digital asset companies to offer access to
digital assets with qualified custody, payment rails, indemnity, liquidity,
compliance, and settlement APIs, as well as debit cards for custodial spending.
We also offer an all-in-one financial infrastructure platform designed to help
crowdfunding portals, platforms, issuers, and broker dealers raise money online.
For more information about our Services, please visit https://www.primetrust.com
and https://www.fundamerica.com.


INFORMATION WE COLLECT

The information we collect depends on the context of your interactions with
Prime Trust and the choices you make (including your privacy settings, the
products and features you use, your location, and applicable law). In some
cases, we receive information directly from you, such as your name and email
address when you create an account. In other cases, we receive information
through your use of our Services.

A. Information You Provide Directly to Us

We collect the following information when you use our Sites and Services. 

 * Contact information – We collect your contact information when you use our
   Services or engage in our Marketing Activities. For example, when you sign up
   to create a Prime Trust account, we collect your full name, address,
   telephone number, and email address.

 * Professional information –We collect professional information about you when
   you submit an inquiry through our Contact Us form, including company name,
   job title, role type, company website.

 * Identity information – We collect information about your identity when you
   create a Prime Trust account, including social security number and date of
   birth, as well as if you choose to conduct financial transactions through
   Prime Trust, including gender and supporting documentation to show proof of
   identity (e.g., driver’s license number, passport, birth certificate,
   marriage license, deed, or other government-issued identification). 

 * Beneficiary information – We collect information about the beneficiary or
   beneficiaries of the trust when you create a trust through your Prime Trust
   account. This information includes your relationship with the beneficiary and
   the beneficiary’s contact information, gender, social security number, and
   date of birth.

 * Entity information – If you create an account on behalf of an entity (e.g., a
   company, partnership, trust), we collect relevant transaction information
   related to the Services, including the entity name, Employer Identification
   Number (EIN), entity address and entity documents.

 * Bank account information – If you choose to conduct a financial transaction
   or create a custodial account through Prime Trust, we collect your bank
   information to process your deposits (e.g., bank routing numbers, bank
   account numbers, wire instructions, and credit or debit card information).

 * Investment information – If you choose to use Prime Trust’s investment
   services, we collect details about your investments, including your
   investment profile (e.g., financial advisor name, investment preferences,
   goals, and risk tolerances) and investor reports (e.g., transactor id,
   investment amount, investment ID, security count shares, email alias, US
   citizen or resident confirmation).

 * Account information – We collect information about you and your account
   (e.g., username, user ID, password, details for Services purchased or
   subscribed to, date of account creation, purchase price, payment information,
   and billing address).

 * Marketing information – When you engage with our Marketing Activities, we
   collect information provided by you, including through form submissions,
   email communications, or phone calls to inquire about Prime Trust and our
   Services. We also collect information you provide to us when you participate
   in a survey, interact with us virtually or in person at an event, or via a
   phone call with one of our sales or customer support representatives (e.g.,
   the nature of your communication, of your communication, your contact
   preferences, and any information you choose to provide to us when completing
   any “free text” boxes in our forms).

 * Social media account information – We use social media features, such as the
   Twitter “Tweet” button and other sharing widgets (“Social Media Features”),
   and we receive information about you if the Social Media Features are hosted
   directly on our Site.      

 * Troubleshooting and support information– We collect information about your
   account preferences or data you provide when you contact Prime Trust for help
   (e.g., the solution you use, contact or authentication data, the content of
   chats and other communications with Prime Trust, and other details that help
   us provide support).

 * Any information you voluntarily provide to us,such as when you submit an
   inquiry through our support portal (e.g., contents of a message or
   attachments that you send to us). 

B. Information We Collect from Third Parties

We receive information about Customers from third parties that provide services
or support Prime Trust’s business operations, such as payment processors. We
limit our use of your personal information to the purposes described in this
Notice. Personal information we receive from third parties includes:

 * Contact information, such as name, address, date of birth, tax ID number, and
   social security number;

 * Financial information, such as bank account information;

 * Organization information, such as company name, job
   title, and company address; and

 * Social Media information related to our Marketing Activities, such as URLs,
   profile pictures, and profile ID

C. Information We Collect Automatically

When you use or interact with the Sites and Services, we automatically collect
or receive certain information about your device and usage of our Sites and
Services. This information includes:

 * Usage information – We collect information about your usage and behavior on
   our Sites and Services. This information includes browser type and settings,
   usage details (e.g., timestamps, frequency, and use pattern), language
   preferences, and device event information (e.g., system activity and hardware
   settings, application version, and amount of time spent on our Sites),
   information about how you interact with our Services, Marketing Activities
   and Sites, (e.g., clicks, scrolls, mouseovers, internal links, pages viewed,
   searches, page response times, download errors, and date/time stamps
   associated with your usage), request information (e.g., speed, frequency),
   the site from which you linked to us (“referring page”), and the name of the
   website you choose to visit immediately after ours (“exit page”), and
   information about other websites you have recently visited and the web
   browser used.

 * Device information – We collect information about your device automatically
   when you use our Sites and Services. This information includes web browser
   and device characteristics, operating system, IP address, location, device
   type, Internet service provider, mobile network, system configuration
   information, model, model number, push notification tokens, and unique device
   identifiers, (e.g., your username and password).

 * Anonymized Statistical information – We collect anonymized statistical
   information (e.g., contact ID, funds transfer ID, funds transfer method ID),
   information about devices used to access our Services, or other aggregated,
   de-identified information about how you use our Sites and Services.

Some information collected within the Services, whether alone or together with
other data, may personally identify you. Depending on the Services provided, we
collect this information on behalf of our Customers and/or requested by the
Customer and under the direction of our Customers. In such instances, if you are
an end user and would like to understand what information our Customers collect,
please contact the entity that you interact with directly.


HOW WE USE INFORMATION

Prime Trust uses collected information in the following ways:

 * Communicate with you about our Services – We use your personal information to
   communicate with you about your access to and usage of our Services, which
   includes sending you technical notices, updates, security alerts, and support
   and administrative messages, (e.g., notification of changes to our terms and
   conditions and notices, invitations to join the service, or requests to
   contribute to a trust).

 * Provide our Sites and Services – We use your information to operate and
   administer our Sites, and to provide, operate, monitor, and maintain our
   Services, including processing financial transactions (e.g., verification and
   authorization checks, sending invoices, purchase confirmations, and
   receipts).

 * Provide and improve functionality – We use your information to analyze how
   you use our Sites and Services to improve functionality, quality, and user
   experience of our Sites and Services.

 * Provide customer support to Customers and end users – We use your information
   to fulfill your requests and communicate with you. We also process your
   personal information to respond to your comments, questions, and requests,
   and provide customer service and support via email, chat, or phone.

 * Develop and improve our Marketing Activities and Services – We use your
   personal information to review and analyze trends, usage, and interactions
   with our Services, Sites, and perform other Marketing Activities to
   personalize and improve our Marketing Activities and the Services. We also
   use your information to provide content and/or features that match your
   interests and preferences or otherwise customize our Marketing Activities and
   your experience with the Services. To learn more about how we track and use
   your information, see our Cookie Notice.

 * Send marketing communications – We use your personal information for
   marketing purposes according to your preferences, such as to communicate with
   you via email, surveys, promotions, or events that we think may be of
   interest to you and/or provide other news or information about Prime Trust
   and/or our select partners. Please see the “Your Privacy Choices and Rights”
   section below to learn how to manage your communication preferences.

 * Promote the safety and security of our Sites and Services – We use your
   information to investigate and prevent fraudulent transactions, unauthorized
   access to the Services, and other malicious, deceptive, fraudulent, or
   illegal activity.

 * Legal and regulatory compliance purposes – We process your information to
   comply with applicable laws or regulations and to review compliance with
   Prime Trust usage terms, as well as audits, security, and fraud monitoring
   and prevention.     

 * Facilitate corporate acquisitions, mergers, or transactions - We may process
   any information regarding your account and use of our Services as is
   necessary in the context of corporate acquisitions, mergers, or other
   corporate transactions.

 * Other purposes – We process your information for other purposes about which
   we notify you in advance, or for which we provide notice of or receive your
   consent.


HOW WE SHARE INFORMATION

Prime Trust shares Customer personal information with third parties as required
by law and as needed to deliver our Services, subject to appropriate safeguards
and contractual arrangements.      

A. Customers

We share end user information with our integrator and issuer Customers when end
users use certain Services. For example, when a Customer end user closes their
FundAmerica account we share an investor report (which includes the Customer end
user’s name, date of birth, address, phone number, email alias, and U.S.
citizenship or resident confirmation) with that issuer Customer so the Customer
can store the report in their records.

B. Third-Party Service Providers

We share your information with third-party service providers that require access
to your information to support our operations and delivery of Services. The
third parties that Prime Trust shares your information with include:

 * Marketing partners for our Marketing Activities, such as developing,
   providing, and sending promotional and advertising materials that we think
   may be useful, relevant, valuable, or otherwise of interest to you. We may
   also publicly display comments and testimonials we receive from users. 

 * Auditors, consultants, and outside counsel to enhance security, compliance
   with applicable laws and regulations, fraud monitoring and prevention.

 * Billing and payment providers to authorize, record, settle and clear
   transactions.

 * Cloud hosting providers to provide data storage and processing services.

 * Corporate and information technology services to facilitate business
   operations and user communications.

 * Identity verification providers to conduct anti-money laundering and credit
   risk checks.

 * Credit card processors to administer transactions and provide customer
   support.

 * Analytics companies to perform analysis on our Marketing Activities and
   Services. 

These service providers are authorized to use your personal information only as
necessary to provide Services to Prime Trust. We may use and disclose aggregate
information that does not identify or otherwise relate to an individual for any
purpose unless we are prohibited from doing so under applicable law. 

C. Law Enforcement, Officials, or Others  

We disclose your personal information to regulators, law enforcement or others:
     

 * In response to a legal request (like a search warrant, court order or
   subpoena) if we have a good faith belief that the law requires us to do so.

 * When we have a good-faith belief it is necessary to detect, prevent and
   address fraud, unauthorized use of the Services, violations of our terms or
   policies, or other harmful or illegal activity; to protect ourselves
   (including our rights, property or Services), you or others, including as
   part of investigations or regulatory inquiries; or to prevent death or
   imminent bodily harm. 

D. Corporate Affiliates

We may share or transfer your information to any person or entity which directly
or indirectly controls, is controlled by or is under common control with Prime
Trust, whether by ownership or otherwise (“Corporate Affiliate”).Any information
relating to you that we provide to our Corporate Affiliates will be treated by
those Corporate Affiliates in accordance with the terms of this Notice.

E. New Owner and other Corporate Transactions

We disclose or transfer your personal information to relevant third parties in
the event of, or as part of the due diligence for, any proposed or actual
reorganization, sale, merger, consolidation, joint venture, assignment,
transfer, or other disposition of all or part of our business, assets, or stock
(including in connection with any bankruptcy or similar proceeding). If a
corporate transaction occurs, we will provide notification of any changes to the
control of your information, as well as choices you may have, through the email
address associated with your account.

F. Advertising Partners 

We may partner with third-party advertising networks, exchanges, and social
media platforms (e.g., LinkedIn) to display advertising on our Sites or to
manage and service advertising on other sites and we may share personal
information with them for this purpose. Please see our Cookie Notice for more
information about how you can turn off tracking technologies.


COOKIES AND OTHER TRACKING TECHNOLOGIES

When you visit our Sites or interact with our Marketing Activities, we use
cookies and similar technologies such as web beacons and web server logs, alone
or in conjunction with cookies, to automatically collect certain technical
information from your browser or device. For more information about how we use
cookies and to learn how to manage cookies, please see our Cookie Notice.


HOW WE TRANSFER AND STORE INFORMATION 

We use data hosting service providers in the United States to store your
information, and we use reasonable technical measures to secure your
information. Prime Trust may also transfer, process, or store your personal
information outside of your country of residence, which may have different data
protection laws than the country in which you initially provided the
information, to provide our Services. To the extent required by applicable law,
whenever we transfer your information, we take the appropriate steps to protect
your information.


HOW LONG WE RETAIN INFORMATION

Prime Trust retains Customer information as necessary to fulfill our legal and
contractual obligations, support business operations, develop Sites and
Services, resolve disputes, enforce our rights, for legitimate business purposes
outlined in this Notice, and as recommended by industry standards.


HOW WE PROTECT YOUR INFORMATION 

We use reasonable and appropriate administrative, technical, and physical
safeguards to protect the information that we have about you from loss, theft,
and unauthorized use, access, modification, or destruction. We also require
third-party service providers acting on our behalf or with whom we share your
information to maintain security measures in accordance with industry standards.

Notwithstanding our security safeguards, it is impossible to guarantee absolute
security in all situations. If you have any questions about the security of our
Sites and Services, please contact us as described in the “Contact Us” section.
For your own security, please do not send any confidential personal information
to us outside of our Services. It is also important that you maintain the
security and control of your account credentials, and not share your password
with anyone.


THIRD-PARTY SERVICES, APPLICATIONS, AND WEBSITES

Our Sites and Services may contain links to other websites not operated or
controlled by Prime Trust. Certain third-party services, applications, or
websites used to navigate to and from our Sites and Services have separate user
terms and privacy notices that are independent of this Notice. 

Prime Trust requires third-party service providers acting on our behalf or with
whom we share your information to provide appropriate security measures in
accordance with industry standards and in compliance with this Notice, their
privacy and security obligations, and any other appropriate confidentiality and
security measures. However, we are not responsible for the content, accuracy or
opinions expressed in such websites, or the privacy and data security practices
of third parties outside of the personal information we receive from or transfer
to them. Such websites are not investigated, monitored, or checked for accuracy
or completeness by us. We recommend carefully reviewing the terms and privacy
notices of each third-party service, website, and/or application prior to use. 


YOUR PRIVACY CHOICES AND RIGHTS

A. Privacy Choices

You have certain choices and rights when it comes to how we collect and use your
personal information. Below is a summary of those choices and rights, and how to
exercise them.

 * Opt-out of marketing communications: You may opt-out of receiving any
   marketing communications from us in the following ways:
   
   * Email: Click the “Unsubscribe” link within each email or by contacting us
     as provided in our "Contact Us" section. If you are a Customer and opt out
     of receiving marketing messages, you will continue to receive transactional
     communications from us regarding our Services.
   
   * Direct mail: Follow the opt-out process described in the direct mail
     communications, or by contacting us directly as provided in our "Contact
     Us" section.

 * Account deletion: If you discontinue using our Services, we can delete
   certain information upon request. Please note some latency in deleting this
   information from our servers and back-up storage may occur if necessary to
   comply with our legal obligations, resolve disputes, manage security risks,
   or enforce our agreements. If you are an end user and wish to delete your
   account with a Customer, please contact that Customer directly.

 * Managing Cookies and Other Tracking Technologies: Relevant browser-based
   cookie controls are described in our Cookie Notice. Our Services participate
   in the Network Advertising Initiative (“NAI”) and Digital Advertising
   Alliance (“DAA”) programs to opt-out of customized or targeted advertising
   online. If you sign up for either of these programs, you will not see
   targeted ads from us on other websites based on your browsing history or
   other online activities. To learn more about preference-based advertising,
   change your preferences or to opt-out visit: 
   
   * NAI opt-out: https://optout.networkadvertising.org/?c=1 
   
   * DAA opt-out: https://optout.aboutads.info/?c=2&lang=EN 

To learn more about how to manage your cookie settings on our Site, please visit
our Cookie Settings.

B. Privacy Rights

Depending on where you are located, you may have certain rights in connection
with your personal information that we obtain. These rights vary depending on
your jurisdiction. To learn more about your rights, see: 

 * Appendix A for CCPA rights if you are a California resident.

 * Appendix B for VCDPA rights if you are a Virginia resident.

 * Appendix C for GDPR rights if you are a resident of the EEA or UK.


MINIMUM AGE REQUIREMENTS TO USE OUR SERVICES

Prime Trust Sites and Services are not directed to children under 13. To use
Prime Trust’s Sites and Services, you must be old enough to consent to the
processing of your personal information in your jurisdiction. We do not
knowingly collect personal information from anyone under the age of 13. If you
are under the age of 13, please do not provide personal information to us. If
you are a parent or guardian and you are aware that your child has provided us
with personal information, please contact us. If we become aware that we have
collected personal information from anyone under the age of 13 without
verification or parental consent, we take steps to remove such information.


CHANGES TO OUR PRIVACY NOTICE

We periodically review and update this Notice to describe new Services or
changes to our practices. You can determine when this Notice was last revised by
referring to the “Updated” date at the top of this Notice. We encourage you to
review the Notice whenever you interact with us to stay informed about our
privacy practices and the ways that you can help protect your privacy.

If we make significant changes to this Notice, we will notify you through a
prominent notice on our Site or Services, release updates, or via email address
associated with your account. If you do not agree with the privacy practices
disclosed in the Notice, we recommend you stop using our Sites and Services.


CONTACT US

To submit questions about this Notice or to update or request changes to your
personal information, please contact us at privacy@primetrust.com or write to
us: 

Prime Trust
Attn: Jennifer Blanco
330 S Rampart Blvd Ste 260, 
Las Vegas, NV 89145

Appendix A: California Consumer Privacy Act (“CCPA”)
Updated: January 22, 2023

Additional provisions applicable to processing personal information of
California residents. 


SCOPE AND APPLICABILITY

This Appendix A (“Appendix A”) applies to California residents and outlines your
rights and choices with respect to the processing of your personal information
under the California Consumer Privacy Act (“CCPA”). This Appendix A controls to
the extent it conflicts with any provision in the main body of the Privacy
Notice (“Notice”). Capitalized terms not defined in this Appendix are defined in
our Notice. 


DATA COLLECTION, USE AND SHARING

The CCPA requires that we tell you whether we collect any categories of personal
information as classified under the CCPA, and whether we share this
information with selected recipients for specific purposes. 

A. Categories of Information

We collect the following categories of personal and sensitive personal
information as classified under CCPA:

 * Personal identifiers – We collect your name, phone number, email address,
   billing addresses, login credentials, and IP address. 

 * Personal information – We collect your date of birth, financial history,
   social security number, and credit card number.

 * Characteristics of protected classifications – We collect your date of birth,
   but do not use this information to infer whether you belong to a protected
   age group. Similarly, we collect your gender. When you communicate with
   us using your social media account, you may share with us, or direct others
   to share with us, your gender and other protected information that we do not
   request. 

 * Commercial information – We collect information about the products you
   request and records of Services purchased.

 * Internet or other network activity information – We collect browsing and
   search history, information collected from cookies and similar technologies,
   and analytics data.

 * Other inferences drawn from personal information – We draw inferences from
   the categories of information collected to understand a consumer’s
   preferences, characteristics, or predispositions. 

Please see the “Information We Collect” section in our Notice to see the full
description of the information that we collect.

Publicly Available Information: Personal information does not include publicly
available information. For purposes of this paragraph, “publicly available”
means information that is lawfully made available from federal, state, or local
government records.

B. Sharing Information

We share the information collected with third-party service providers such
as suppliers, vendors, business partners (e.g., advertising partners,
consultants) to operate our business and provide you with our Sites and
Services.

We partner with third parties, e.g., Google, to help us with our Marketing
Activities. These third-party partners may use tracking technologies, such as
cookies, to gather information about your activities on our Site to deliver our
Marketing Activities to you.

C. Using Information

We collect and use your personal information to:

 * Interact with Customers

 * Facilitate transactions

 * Provide our Services 

 * Conduct internal research and development

 * Improve the quality and safety of our Sites and Services

 * Detect security incidents and prevent fraud.

Please see the “How We Use Information” section in our Notice for a full
description of how we use your personal information. 


YOUR CCPA RIGHTS

The CCPA grants California consumers certain rights in connection with the
personal information we collect, as described below. 

 * Right to Know: You have the right to know the categories and specific pieces
   of your personal information we have collected in the previous 12 months. 

 * Right to Deletion: You have the right to request that we delete any of your
   personal information we have collected. 

 * Right to Request Information: You have the right to request information about
   the collection, sale, and disclosure of your personal information from the
   previous 12 months. 

 * Right to Opt-out of the Sale of Information: You have the right to opt-out of
   the sale of personal information we have collected about you. 

 * Right to Non-Discrimination: You have the right to not receive discriminatory
   treatment for exercising any of your CCPA rights. We do not treat Customers
   differently for exercising any of the rights described above. 


EXERCISING YOUR RIGHTS 

If you wish to exercise any of the above rights, see the “Contact Us” section in
this Appendix A. You may also authorize an individual to submit a verifiable
consumer request relating to your personal information. 

We verify your request using your email address. If you have created an account
with us, we also verify your request using the information associated with
your account, including billing information. Government identification may be
required. We cannot respond to your request if we cannot verify your identity
and/or authority to make the request on behalf of another and confirm the
personal information relates to you. Making a verifiable consumer request does
not require you to create an account with us. 

If you wish to use an authorized agent to submit a request to opt-out on your
behalf, you must provide the authorized agent written permission signed by you,
the consumer. We may deny a request from an authorized agent if the agent cannot
provide Prime Trust your signed permission demonstrating that the agent is
authorized to act on your behalf. 

We fulfill requests within 45 days of receiving your request. Please note that
your request may be limited in certain cases, for example if complying with your
request would conflict with: 

 * Ability to complete the transaction for which the personal information was
   collected or provide a good or service requested by the consumer;

 * Help to ensure security and integrity to the extent the use of the consumer’s
   personal information is reasonably necessary and proportionate for those
   purposes;

 * Debug to identify and repair errors that impair existing intended
   functionality;

 * Federal, state, or local law; 

 * Regulatory inquiries; 

 * Subpoenas; or 

 * Exercising or defending legal claims. 


CONTACT US

To submit questions about this Notice or to update or request changes to your
personal information, please contact us at privacy@primetrust.com or write to
us: 

Prime Trust
Attn: Jennifer Blanco
330 S Rampart Blvd Ste 260, 
Las Vegas, NV 89145

Appendix B: Virginia Consumer Data Protection Act (“VCDPA”)

Updated: January 22, 2023

Additional provisions applicable to processing personal information of Virginia
residents. 


SCOPE AND APPLICABILITY

This Appendix B (“Appendix B”) applies to Virginia residents and outlines your
rights and choices with respect to the processing of your personal information
under the Virginia Consumer Data Protection Act (“VCDPA”). This Notice does not
apply to Prime Trust employees or job applicants. This Appendix B controls to
the extent it conflicts with any provision in the main body of the Privacy
Notice (“Notice”). Capitalized terms not defined in this Appendix are defined in
our Notice. 


DATA COLLECTION, USE AND SHARING

The VCDPA requires that we tell you whether we collect any categories
of personal information as classified under the VCDPA, and whether we share this
information with selected recipients for specific purposes. 



A. CATEGORIES OF INFORMATION

We collect the following categories of personal and sensitive information as
classified under VCDPA:

 * Personal data – We collect your name, phone number, email address, billing
   addresses, login credentials, and IP address. 

 * Personal information – We collect your date of birth, financial history,
   social security number, and credit card number.

 * Characteristics of protected classifications – We collect your date of birth,
   but do not use this information to infer whether you belong to a protected
   age group. Similarly, we collect your gender. When you communicate with
   us using your social media account, you may share with us, or direct others
   to share with us, your gender and other protected information that we do not
   request. 

 * Commercial information – We collect information about the products you
   request and records of Services purchased.

 * Internet or other network activity information – We collect browsing and
   search history, information collected from cookies and similar technologies,
   and analytics data.

 * Other inferences drawn from personal information – We draw inferences from
   the categories of information collected to understand a consumer’s
   preferences, characteristics, or predispositions. 

Please see the “Information We Collect” section in our Notice to see the full
description of the information that we collect.

Publicly Available Information: Personal information does not include publicly
available information. For purposes of this paragraph, "Personal data" does not
include de-identified data or publicly available information.


B. SHARING INFORMATION

We share the information collected with third-party service providers such
as suppliers, vendors, business partners (e.g., advertising partners,
consultants) to operate our business and provide you with our Sites and
Services.

We partner with third parties, e.g., Google, to help us with our Marketing
Activities. These third-party partners may use tracking technologies, such as
cookies, to gather information about your activities on our Site to deliver our
Marketing Activities to you.


C. USING INFORMATION

We collect and use your personal information to:

 * Interact with Customers

 * Facilitate transactions

 * Provide our Services 

 * Conduct internal research and development

 * Improve the quality and safety of our Sites and Services

 * Detect security incidents and prevent fraud.

Please see the “How We Use Information” section in our Notice for a full
description of how we use your personal information. 


YOUR VCDPA RIGHTS

The VCDPA grants Virginia consumers certain rights in connection with the
personal information we collect, as described below. 

 * Right to Know: To confirm whether or not we are processing your personal data
   and to access such personal data. 

 * Right to Correct: To correct inaccuracies in your personal data, taking into
   account the nature of the personal data and the purposes of the processing of
   the personal data

 * Right to Deletion: You have the right to request that we delete personal data
   provided by or obtained about you

 * Right to Request Information: To obtain a copy of the personal data that you
   previously provided in a portable and, to the extent technically feasible,
   readily usable format. 

 * Right to Opt-out: You have the right to opt-out of the targeted advertising,
   the sale of personal information we have collected about you and profiling in
   furtherance of decisions that produce legal or a similarly significant
   effects.

 * Right to Non-Discrimination: You have the right to not receive discriminatory
   treatment for exercising any of your VCDPA rights. We do not treat Customers
   differently for exercising any of the rights described above. 


EXERCISING YOUR RIGHTS 

If you wish to exercise any of the above rights, see the “Contact Us” section in
this Appendix B. You may also authorize an individual to submit a verifiable
consumer request relating to your personal information. 

We verify your request using your email address. If you have created an account
with us, we also verify your request using the information associated with
your account, including billing information. Government identification may be
required. We cannot respond to your request if we cannot verify your identity
and/or authority to make the request on behalf of another and confirm the
personal information relates to you. Making a verifiable consumer request does
not require you to create an account with us. 

If you wish to use an authorized agent to submit a request to opt-out on your
behalf, you must provide the authorized agent written permission signed by you,
the consumer. We may deny a request from an authorized agent if the agent cannot
provide Prime Trust your signed permission demonstrating that the agent is
authorized to act on your behalf. 

We fulfill requests within 45 days of receiving your request. Please note that
your request may be limited in certain cases, for example if complying with your
request would conflict with: 

 * The ability to administer benefits for another individual where you are named
   as a beneficiary and used for the purposes of administering those benefits;

 * Provide a product or service specifically requested by you, perform a
   contract to which you are party;

 * Prevent, detect, protect against, or respond to security incidents, identity
   theft, fraud, harassment, malicious or deceptive activities, or any illegal
   activity; preserve the integrity or security of systems; or investigate,
   report, or prosecute those responsible for any such action;

 * Assist another controller, processor, or third party with any of the
   obligations under the VCDPA;

 * Federal, state, or local law; 

 * Regulatory inquiries; 

 * Subpoenas; or 

 * Exercising or defending legal claims.


CONTACT US

To submit questions about this Notice or to update or request changes to your
personal information, please contact us at privacy@primetrust.com or write to
us: 

Prime Trust
Attn: Jennifer Blanco
330 S Rampart Blvd Ste 260, 
Las Vegas, NV 89145

Appendix C: General Data Protection Regulation (“GDPR”)

Updated: January 22, 2023

Additional provisions applicable to the processing of personal information of
individuals based in the European Economic Area (“EEA”) and the United Kingdom
(“UK”). 


SCOPE AND APPLICABILITY 

This Appendix C (“Appendix C”) applies to individuals based in the EEA and UK
and outlines your rights and choices regarding the processing of your personal
information under the General Data Protection Regulation (“GDPR”). This Appendix
C controls to the extent it conflicts with any provision in the main body of the
Notice. Capitalized terms not defined in Appendix C are defined in our Notice. 


DATA COLLECTION, USE AND SHARING  

Prime Trust acts as a data controller for personal information collected about
you while using our Site or interacting with our Marketing Activities as
described in the Privacy Notice.

We act as a data processor on behalf of our Customers for most of the personal
information we process through our Services. This means it is primarily our
Customer that controls what personal information we collect and process through
the Service and how we use it, and we only process the information in accordance
with their instructions.

This Appendix C does not apply to any personal information that we process as a
processor, as we only process that information on behalf of the Customer and in
accordance with our Agreement with them. A Customer that has entered into an
agreement to use our Services (e.g., an API integrator or platform user)
controls its instance of the Service and any associated data.

We collect and process personal information about you only where we have a legal
basis for doing so under applicable data protection laws. Our legal bases
include processing personal information under:

 * Your consent: Where appropriate or legally required, we collect and use
   information about you subject to your consent. For example, we collect your
   email address when you sign up for marketing emails and updates on our Site. 

 * Performance of contract: We collect and use information about you to contract
   with you or to perform a contract that you have with us. For example, we
   collect your name, email, and billing addresses when you purchase our
   Services and to process transactions.

 * Legitimate interests: We collect and use information about you for our
   legitimate interests to improve our Services, deliver content, optimize your
   experience, and market our Services. For example, we collect your IP address
   and device information when you use our Services to prevent malicious
   activity and fraudulent transactions. 

 * Compliance with laws: We may also collect and use information about you:
   
   * As required by law, such as to comply with a subpoena or similar legal
     process;
   
   * When we believe in good faith that disclosure is necessary to protect our
     rights or property, protect your health and safety or the health and safety
     of others, investigate fraud, or respond to a government request; or
   
   * If we participate in a merger, acquisition, or sale of all or a portion of
     its assets.


TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES 

When you use our Services and provide personal information to us, we use data
hosting service providers in the U.S. to store information we have about you. 

We also transfer personal information we have about you to third parties as
described in the “How We Transfer Information” section above. These third
parties may be located outside of the EEA. In circumstances that require us to
transfer your information to third parties outside the EEA, we will only
transfer such information where we have adequate measures in place to provide
appropriate safeguards such as standard contractual clauses produced by the EU
Commission. 

Although the data protection laws of various countries may differ from those in
your own country, we take appropriate steps to ensure that your personal
information is processed as described in this Notice and under the law. 


DATA SUBJECT RIGHTS 

You have certain rights related to your personal information when you use Prime
Trust Services. Some of these rights only apply in certain circumstances, as set
out below. We also describe how to exercise these rights in the “Exercising your
Rights” section of this Appendix C.

Depending on the Services provided, end users seeking to access, correct, amend,
or delete personal information should contact the integrator Customer (the data
controller) which has transferred such data to us for processing. If the
integrator Customer receives a data subject request and sends the request to us,
we will respond to the integrator Customer’s request within the agreed timeframe
outlined in our integrator Customer agreements. The integrator Customer is
responsible for responding to its end user data subject requests as determined
under the applicable local data protection law. 

The GDPR provides data subjects with the following rights: 

 * Right of Access: You have the right to request access and receive certain
   information about how we use personal information about you and who we share
   it with. 

 * Right to Rectification: You have the right to request correction of personal
   information we hold about you where it is inaccurate or incomplete. 

 * Right to Data Portability: You have the right to request a copy of data we
   hold about you in a structured, machine-readable format, and to ask us to
   share this information with another entity. 

 * Right to Erasure: You have the right to request deletion of the personal
   information we hold about you: 

 * Where you believe that it is no longer necessary for us to hold your personal
   information; 

 * Where we are processing your personal information based on legitimate
   interests and you object to such processing and we cannot demonstrate an
   overriding legitimate ground for the processing; 

 * Where you have provided your personal information to us with your consent and
   you wish to withdraw your consent and there is no other ground under which we
   can process your personal information; or 

 * Where you believe your personal information is being unlawfully processed by
   us. 

 * Right to Restriction of Processing: You have the right to ask us to restrict
   (stop any active) processing of your personal information: 

 * Where you believe your personal information is inaccurate and while we verify
   accuracy; 

 * Where we want to erase your personal information as the processing is
   unlawful, but you want us to continue to store it; 

 * Where we no longer need your personal information for our processing, but you
   require us to retain the data for the establishment, exercise, or defense of
   legal claims; or 

 * Where you have objected to us processing your personal information based on
   our legitimate interests and we are considering your objection. 

 * Right to Object: You can object to our processing of your personal
   information based on our legitimate interests. We will no longer process your
   personal information unless we can demonstrate an overriding legitimate
   purpose. 

 * Objection to Marketing, Automated Decision Making, and Profiling: You have
   the right to object to our processing of personal information for marketing
   communications, automated decision making and profiling. We will stop
   processing the data for that purpose. 

 * Withdrawal of Consent: Where you have provided your consent for us to process
   your personal information, you can withdraw your consent by emailing
   Privacy@primetrust.com. 

Please note that before we respond to requests for information, we will require
that you verify your identity, or the identity of any data subject for whom you
are requesting information. Our verification methods may include requesting that
you log into your Prime Trust account, confirm your contact information or email
address, and/or provide documents for identity verification. 


EXERCISING YOUR RIGHTS 

To exercise any of the rights above, please contact us as noted in the “Contact
Us” section in this Appendix C. If you are an integrator end user, contact the
integrator acting as the data controller directly to fulfill any requests.

We will fulfill your request within 30 days of receipt. Please note that the
above rights may be limited in the following situations: 

 * Where fulfilling your request would adversely affect other individuals,
   company trade secrets or intellectual property; 

 * Where there are overriding public interest reasons; or 

 * Where we are required by law to retain your Personal Information. 

If you have unresolved concerns, we encourage you to come to us in the first
instance, but you are entitled to address any grievance directly to the relevant
Supervisory Authority. If you are an integrator end user, we encourage you to
reach out to the relevant integrator Customer first to address any complaints.


CONTACT US  

To submit questions about this Appendix C or to update or request changes to
your personal information, please contact us at Privacy@primetrust.com, call us
at (702) 840-4000, or write to us:

Prime Trust
Attn: Jennifer Blanco, 
330 S Rampart Blvd Ste 260
Las Vegas, NV 89145


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