Last Updated: July 18, 2025

Steinwold & Co. LLC (“Steinwold & Co.,” “we,” “our,” or “us”) values your privacy and is committed to safeguarding your personal data. This Privacy Policy outlines how we collect, use, store, and share personal information across our website, www.steinwold.com, and any other websites or services we operate (collectively, the “Platform”). It also explains your rights regarding your personal data and how to exercise them.

Please note that this Policy does not apply to third-party websites or services linked from our Platform. Each third party operates under its own privacy policy, which we encourage you to review independently.

I. Information We Collect:

A. Information You Provide Directly

When you register for or use our services, you may voluntarily submit personal information. This can include, but is not limited to:

• Name, date of birth, and gender

• Email address and phone number

• Mailing address and account credentials

• Payment details and purchase history

• Digital asset information (wallet addresses, transaction history)

• Support-related communication

• Other identifiable details you choose to share

B. Payment Information

We rely on third-party payment processors to handle financial transactions. While they process your credit card or bank data securely, Steinwold & Co. may receive non-financial data like billing details and purchase confirmation.

C. Automated Data Collection

We may from time to time use cookies and similar technologies to track and improve user experiences. Automatically collected data may include:

• Device type, OS, browser, and IP address

• Pages visited and time spent on each

• Referring and exit URLs

• Advertising identifiers (e.g., IDFA, AAID)

• Error logs and diagnostics

• Interaction metrics within our services

II. How We Use Your Information:

We use your personal data only when legally permitted and typically for:

• Account registration and service delivery

• Improving our products and personalizing user experience

• Customer service and support communications

• Marketing communications, if opted in

• Analytics and performance tracking

• Security monitoring and fraud prevention

• Legal and regulatory compliance, including SEC requirements

• Managing business operations, transitions, and mergers

III. Information Sharing:

We may disclose personal information to the following:

• Internal staff and affiliated entities

• Service providers and contractors (e.g., IT support, hosting, marketing)

• Legal or regulatory authorities if required by law

• Parties involved in business transfers or mergers

• Credit bureaus or courts in case of non-payment

• Business partners assisting with promotions or support

IV. Security Measures:

We implement industry-standard safeguards to protect your personal data. Despite these efforts, no system is entirely secure, and data transmission over the internet carries inherent risk.

V. Data Retention:

We retain personal data only for as long as necessary to provide our services or meet legal obligations. If you close your account, we may retain limited information to comply with legal requirements or resolve disputes.

VI. Your Rights and Choices:

• Access and Correction: You may request to view or update your personal data.

• Marketing Preferences: You can opt out of promotional emails at any time.

• Cookies: You may disable cookies via your browser settings.

• Complaints: Contact us if you believe your data rights have been violated.

• Identity Verification: We may request documentation to verify any data access requests.

VII. Children’s Privacy:

Our services are intended for users aged 18 and older. We do not knowingly collect personal information from minors. If you believe a child has provided us with personal data, please contact us to request deletion.

VIII. Business Transitions:

In the event of a business acquisition, merger, or restructuring, user data may be part of the transferred assets. Any successor entity will be bound by this Privacy Policy or a comparable equivalent.

IX. International Users:

We may transfer and store your information in jurisdictions outside your own, including the United States and EU countries. We take reasonable steps to protect data in accordance with applicable law.

X. External Sites:

This Policy does not apply to third-party websites linked through our Platform. We are not responsible for their privacy practices.

XI. Updates to This Policy:

We reserve the right to update this Privacy Policy. If material changes occur, we will notify you either through the Platform or via email. Continued use of our services after updates constitutes your agreement to the new terms.

XII. California Residents (CCPA Notice):

If you live in California, you may request details on the personal information we’ve collected and shared over the past 12 months. Visit https://www.oag.ca.gov/privacy/ccpa for more details on your rights.

XIII. Nevada Residents:

Nevada law allows residents to opt out of the sale of their personal data. To do so, email us at info@steinwold.com with the subject line “Nevada Do Not Sell Request.”

XIV. GDPR Rights (EU Users):

European residents have specific rights under the GDPR, including the right to access, correct, delete, or restrict use of personal data. You can learn more about these rights at https://ec.europa.eu/info/law/law-topic/data-protection_en.

XV. Contact Us:

If you have questions or concerns about this Privacy Policy or how your data is handled, please contact us at:

Email: info@steinwold.com
Subject: Privacy Inquiry – Steinwold & Co. LLC