Privacy Policy

This Privacy Policy (“Policy”) outlines how Venbr, Inc and its subsidiaries—including the investment products it sponsors or manages (collectively, “Venbr,” “we,” “our,” or “us”)—collect and protect your Personal Information (as defined below). If you have questions not addressed in this Policy, please contact us at the email provided below. By creating an account on any Venbr website, including www.venbr.com (the “Venbr sites”), or by submitting Personal Information to us in any other way, you consent to the collection and use of your information as described in this Policy. This Policy forms part of our Terms of Service, and any capitalized terms not defined here have the meanings assigned in the Terms of Service. This Policy applies to current and former Venbr clients, as well as any users of the Venbr sites. “Personal Information” refers to non-public data that personally identifies you as an individual or entity.

Policy Updates

If we update this Policy, the revised version will be posted promptly on the Venbr sites. The "Revised" date will indicate the most recent version, which becomes effective immediately upon posting. Your continued use of the Sites constitutes acceptance of any changes. Any disputes related to this Policy are subject to the posted terms.

Collection and Use of Information

When you sign up or interact with the Venbr sites, we may collect information such as your full legal name, address, date of birth, and other data necessary to verify your identity and fulfill legal obligations. This information helps us conduct transactions, communicate with you, and better understand your needs. We or our marketing partners may also collect information from advertising activities. We collect and process Personal Information for purposes including:

• Creating and managing user accounts
• Delivering requested services
• Providing support and responding to inquiries
• Sending administrative communications
• Managing our relationship with you
• Requesting feedback on our products and services
• Sending marketing or promotional messages (opt-out available)
• Delivering targeted advertising
• Ensuring service security, including fraud prevention
• Analyzing usage trends to improve our services
• Evaluating marketing campaign effectiveness

Types of Information Collected

Information may be collected through:

• User-provided Information: This includes data you supply when filling out forms or documents, such as your name, address, age, job title, income, investment objectives, experience, contact details, and sensitive information like Social Security or tax ID numbers.
• Automatically Collected Data: This may include device and browser details, IP address, operating system, language, usage patterns, and location data. We collect this through cookies and similar technologies primarily for security and analytics.
• Third-party Sources: We may supplement our records with data from public databases, joint marketing partners, affiliate programs, data providers, or other third parties to enhance our marketing and service delivery.

How We Protect Your Information

Keeping Your Information Secure

We restrict access to your Personal Information to only those employees who require it to provide services related to your transactions or potential transactions on the Venbr sites. Consistent with industry standards, we maintain robust physical, electronic, and procedural safeguards to protect your Personal Information. Our investment in security includes advanced software, systems, and protocols designed to safeguard your personal, financial, and transactional data. While no system can guarantee absolute security, we regularly evaluate and upgrade our technologies to meet evolving threats.

Ensuring Accuracy

Maintaining accurate and up-to-date information is essential for both service quality and security. Our procedures are designed to prevent unauthorized access while promoting data accuracy. If your Personal Information changes or you notice inaccuracies, please notify us promptly so we can update our records accordingly. We use this information to verify your identity and ensure the integrity of your account.

Your Rights Regarding Personal Information

Subject to applicable laws, you have certain rights over your Personal Information. These may include the rights to:

• Access
• Rectify
• Erase or block
• Restrict processing
• Object to processing
• Data portability
• File a complaint with your local data protection authority

To exercise any of these rights, please contact us using the details provided at the end of this Privacy Policy.

Ongoing Commitment to Privacy

Our commitment to your privacy extends beyond the duration of your relationship with us. Even if you become an inactive client or terminate your investments, your Personal Information will remain protected under the principles outlined in the then-current version of this Policy. We retain your data as required by regulatory obligations, internal policies, and legal standards.

How Information Benefits You and Venbr

Accurate and complete information helps us deliver better service and protect your interests. We use your data to:

• Respond efficiently and accurately to your inquiries
• Protect your investments and assist in the prevention of fraud

This information is crucial to achieving our mission: to create transparent and accessible investment products within the digital asset space.

Sharing Your Information with Third Parties

Our Commitment to Limited Sharing

We take your privacy seriously and limit the sharing of your Personal Information outside Venbr. We do not disclose your data except as outlined below:

• Third-party service providers: We may engage reputable third parties to perform functions such as account processing, client support, identity verification, and document facilitation. For example, we may share your information with service providers for regulatory background checks or with custodians and clearing firms to execute transactions.
• Business transactions: In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Information may be transferred as part of the business assets.
• Affiliates and subsidiaries: We may share your data with our subsidiaries when necessary to provide the services you have requested.
• Legal and regulatory disclosures: We may disclose your Personal Information as required by applicable laws and regulations to government agencies, law enforcement, self-regulatory organizations, credit bureaus, or collection agencies, or to protect our legal rights.

Regardless of these circumstances, all Personal Information is handled in accordance with relevant local laws, including but not limited to the General Data Protection Regulation (GDPR), where applicable.

Third-Party Websites and Services

If you choose to engage with a product or service provided by another company, the Personal Information you share with that entity will be governed by its own privacy policy, not Venbr’s. Except as expressly stated in this Policy, Venbr is not responsible for the privacy practices, content, or security of any third-party websites or services (each a “Third Party Service”) linked from our platform. When you access a Third Party Service via a hyperlink on the Venbr sites, you may be asked to submit personal data to that third party. Please carefully review their privacy policies, as their data practices may differ from ours.

Privacy and the Internet

If you access Venbr sites or services through the internet, the following information may be relevant:

• Secure Infrastructure: Venbr sites operate on infrastructure designed with multiple layers of protection. We utilize industry-standard encryption technologies to safeguard your data.
• User Responsibility: Security is a shared responsibility. You are accountable for maintaining the confidentiality of your login credentials. Do not share your username or password with others. If you suspect misuse or unauthorized access, discontinue use immediately and contact us.
• Cookies: Cookies are small text files placed on your browser to enhance navigation, remember login information, and improve your user experience. Cookies are also used for authentication and performance tracking. You may configure your browser to notify you about or block cookies; however, doing so may impair site functionality or prevent access to secure areas of the Venbr sites.

Web Analytics and Tracking

We may collect web usage data—such as pages visited, frequency of access, and service preferences—using tools like cookies, web beacons, and page tags. This data may be used internally or by authorized third-party service providers to:

• Administer and improve the Sites
• Analyze site usage and performance
• Personalize your experience
• Recommend relevant services or products
• Comply with legal or regulatory requirements

Social Media Features

Venbr sites may include interactive elements like social media buttons (e.g., the Facebook "Like" button), widgets, or mini-programs. These features may collect data such as your IP address and the pages you visit, and may use cookies to function properly. Such tools may be hosted by third parties or directly by Venbr. Your interactions with these features are governed by the privacy policies of the respective providers.

What Legal Bases Do We Rely On?

If you are located in the European Union (EU) or the United Kingdom (UK), this section applies to you. Venbr relies on the following legal bases under applicable data protection laws to process your Personal Information:

• Consent: We may process your Personal Information where you have provided explicit consent for a specific purpose. You have the right to withdraw your consent at any time.
• Performance of a Contract: Processing may be necessary to fulfill our contractual obligations to you.
• Legitimate Interests: We may process your Personal Information where it is necessary to pursue our legitimate business interests, provided these interests are not overridden by your rights and freedoms.
• Legal obligations: In certain cases, we may be required to process your Personal Information to comply with legal and regulatory obligations.
• Vital Interests: We may process your information when it is necessary to protect your vital interests or those of another individual.

California Privacy Rights (CCPA/CPRA)

Venbr has disclosed the following categories of Personal Information to third parties for a business purpose in the past 12 months:

• Category A – Identifiers (Real name, IP address, email, etc.)
• Category B – California Customer Records (Contact, financial data, etc.)
• Category C – Protected Classification Characteristics (Gender, DOB)
• Category D – Financial Information (Net worth, investment details)
• Category F – Internet or Other Electronic Activity
• Category G – Geolocation Data
• Category I – Professional or Employment Information

Under the CCPA, you have the Right to Request Deletion, the Right to Know, and the Right to Non-Discrimination.

Do Not Track Signals

At this time, the Venbr sites do not respond to web browser “Do Not Track” (DNT) signals. If this changes in the future, we will update this Privacy Policy accordingly.

Minors

Our services are not directed to individuals under the age of 18. If we become aware that we have collected Personal Information from a user under the age of 18, we will take reasonable steps to delete such information.

Contact Us

If you wish to review or correct your Personal Information, or if you have questions regarding your data or this Privacy Policy, please contact us at:

Email: info@venbr.com