Privacy Policy

Last Updated: October 06, 2025

At Sbinala Ventures LLC ("we," "us," or "our"), we are committed to protect the privacy and security of your
personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information
when you engage with our services, including our retail investment strategies and portfolios. Please read this
policy carefully. By using our services, you consent to the practices described herein.

1. Information We Collect
We may collect the following types of information:

Personal Information: Name, contact details (email, phone, address), date of birth, Social Security

Number or Tax ID, financial information (e.g., income, net worth, investment history, wallet address), and
identification documents (e.g., passport, driver’s license) to comply with regulatory requirements.

Account Information: Details related to your investment accounts, including portfolio preferences,

transaction history, and account balances.

Usage Data: Information about how you interact with our website, mobile applications, or other

digital platforms, including IP address, browser type, device information, and pages visited.

Communications: Information you provide when contacting us, such as inquiries, feedback, or

customer service interactions.

2. How We Collect Information
We collect information:

Directly from you when you register for our services, complete forms, or communicate with us.
Automatically through cookies, web beacons, or similar technologies when you visit our website or use our digital platforms.
From third parties, such as financial institutions, credit bureaus, or regulatory bodies, to verify your identity or assess eligibility for our services.

3. How We Use Your Information
We use your information to:

Provide and manage our investment strategies and portfolios.
Process transactions and maintain your accounts.
Comply with legal and regulatory obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
Communicate with you about your investments, updates, or promotional offers.
Improve our services, website, and user experience.
Protect against fraud, unauthorized transactions, or other liabilities.

4. How We Share Your Information
We may share your information:

With service providers (e.g., custodians, brokers, or technology vendors) who assist in delivering our services, subject to confidentiality agreements.
With regulatory authorities or law enforcement to comply with legal obligations or respond to lawful requests.
In connection with a merger, acquisition, or sale of assets, with notice to you.
With your consent or as otherwise permitted by law.
We do not sell your personal information to third parties.

5. Data Security

We implement reasonable technical, administrative, and physical safeguards to protect your information from
unauthorized access, use, or disclosure. However, no system is completely secure, and we cannot guarantee
absolute security.

6. Your Choices
You may:

Update or correct your personal information by contacting us.
Opt-out of marketing communications by following unsubscribe instructions in our emails or contacting us directly.
Request deletion of certain data, subject to legal and regulatory requirements.

7. Data Retention

We retain your information for as long as necessary to provide our services, comply with legal obligations,
resolve disputes, or enforce agreements. When no longer needed, we securely delete or anonymize your data.

8. Third-Party Links

Our website or services may contain links to third-party sites. We are not responsible for the privacy practices
or content of these sites. Please review their privacy policies.

9. Children’s Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from
children. If we learn such information has been collected, we will take steps to delete it.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the
updated policy on our website or contacting you directly. Your continued use of our services after such changes
constitutes acceptance of the revised policy.

11. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact
us at info@sbinala-ventures.com

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