PRIVACY POLICY

Effective Date: January 1, 2024

SUPREME.PM, INC. ("COMPANY," "WE," "US," OR "OUR") IS COMMITTED TO PROTECTING YOUR PRIVACY. THIS PRIVACY POLICY DESCRIBES HOW WE COLLECT, USE, DISCLOSE, AND PROTECT INFORMATION ABOUT YOU. BY USING OUR SERVICE, YOU CONSENT TO THE PRACTICES DESCRIBED IN THIS POLICY.

1. SCOPE AND CONSENT

1.1 Applicability. This Privacy Policy applies to information collected through the Supreme.PM platform, website, and services (collectively, the "Service").

1.2 Consent. By accessing or using the Service, you consent to the collection, use, and disclosure of your information as described herein.

1.3 Changes. We may update this Policy at any time. Continued use after changes constitutes acceptance.

2. INFORMATION COLLECTION

2.1 Information You Provide

We collect information you voluntarily provide, including:

•**Account Data:** Name, email address, encrypted password

•**Profile Data:** Investment preferences, risk tolerance (optional)

•**Payment Data:** Billing information (processed by third-party providers)

•**Communications:** Support requests, feedback, correspondence

2.2 Automatically Collected Information

We automatically collect:

•**Usage Data:** Features accessed, time spent, navigation paths

•**Device Data:** IP address, browser type, operating system, device identifiers

•**Cookies:** Session management, preferences, analytics

•**Log Data:** Server logs, error reports, performance metrics

2.3 Information We Do Not Collect

We do NOT:

•Access your brokerage accounts

•Store unencrypted payment card details

•Collect biometric information

•Track location beyond IP-based region

3. USE OF INFORMATION

3.1 Permitted Uses

We use collected information solely to:

•Provide and improve the Service

•Process transactions and send related information

•Send technical notices and support messages

•Respond to inquiries and provide customer service

•Monitor and analyze usage patterns

•Detect and prevent fraud or abuse

•Comply with legal obligations

3.2 Restrictions

We will NOT use your information to:

•Send unsolicited marketing without consent

•Sell or rent personal information

•Make automated decisions with legal effects

•Profile for discriminatory purposes

4. INFORMATION SHARING

4.1 No Sale of Personal Information

WE DO NOT AND WILL NOT SELL YOUR PERSONAL INFORMATION.

4.2 Limited Disclosure

We may share information only:

•**Service Providers:** With vendors under strict confidentiality agreements

•**Legal Compliance:** When required by law, subpoena, or court order

•**Protection of Rights:** To protect our rights, property, or safety

•**Business Transfers:** In connection with merger, acquisition, or asset sale

•**Consent:** With your explicit consent

4.3 Aggregate Information

We may share aggregated, de-identified information that cannot reasonably identify you.

5. DATA SECURITY

5.1 Security Measures

We implement industry-standard security measures including:

•AES-256 encryption for data at rest

•TLS 1.3 for data in transit

•Access controls and authentication

•Regular security assessments

•Incident response procedures

5.2 No Absolute Security

NO TRANSMISSION OVER THE INTERNET IS 100% SECURE. WE CANNOT GUARANTEE ABSOLUTE SECURITY.

5.3 Breach Notification

In the event of a data breach, we will notify affected users as required by applicable law.

6. DATA RETENTION

6.1 Retention Periods.: We retain information only as long as necessary for business purposes or legal compliance:

•Account data: Duration of account plus 3 years

•Usage logs: 2 years

•Payment records: 7 years

•Marketing data: Until opt-out plus 1 year

6.2 Deletion. Upon account termination, we will delete or anonymize your information, except as required for legal compliance.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Portability

You may request access to or a copy of your personal information.

7.2 Correction and Update

You may update your information through account settings or by contacting us.

7.3 Deletion

You may request deletion of your account and associated data.

7.4 Opt-Out

You may opt out of:

•Marketing communications

•Certain cookies (may impact functionality)

•Data analytics (may impact service quality)

7.5 Do Not Track

We do not currently respond to Do Not Track signals.

8. CALIFORNIA PRIVACY RIGHTS

California residents have additional rights under the California Consumer Privacy Act (CCPA):

•Right to know what information we collect

•Right to delete personal information

•Right to opt-out of sale (we do not sell information)

•Right to non-discrimination

To exercise these rights, contact [email protected].

9. INTERNATIONAL TRANSFERS

9.1 U.S. Processing. We process information in the United States. By using the Service, you consent to transfer of your information to the U.S.

9.2 Safeguards. We implement appropriate safeguards for international transfers as required by law.

10. CHILDREN'S PRIVACY

The Service is not intended for users under 18. We do not knowingly collect information from children. If we learn of collection from a child, we will delete such information.

11. THIRD-PARTY SERVICES

11.1 Payment Processors. We use PCI-compliant third-party payment processors. We do not store payment card details.

11.2 Analytics. We use privacy-focused analytics tools configured to minimize data collection.

11.3 Links. We are not responsible for the privacy practices of third-party websites linked from our Service.

12. LEGAL BASIS FOR PROCESSING (GDPR)

For European users, we process personal data based on:

•**Contract:** To provide services you requested

•**Legitimate Interests:** To improve and secure our services

•**Legal Obligation:** To comply with applicable laws

•**Consent:** For optional features and marketing

13. CONTACT INFORMATION

Privacy Officer

Supreme.PM, Inc.

Email: [email protected]

Data Protection Inquiries

Email: [email protected]

To exercise your privacy rights, contact us with:

•Your name and email address

•Description of your request

•Proof of identity if required

14. GOVERNING LAW

This Privacy Policy is governed by Delaware law without regard to conflict of law principles.

BY USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND CONSENT TO THE PRACTICES DESCRIBED HEREIN.