Privacy Policy

Thank you for your interest in ExchangiFi, LLC (“ExchangiFi,” “we,” “us,” or “our”). ExchangiFi owns, licenses, and operates the website located at exchangifi.com and any related applications, platforms, and tools (collectively, the “Site” or “Platform”). This Privacy Policy describes how we collect, use, disclose, and protect information from and about you through our Site and any other interaction or communication that you may have with or through ExchangiFi (collectively, the “Services”).

The Platform is an educational technology platform designed to provide users with general information, educational content, and resources relating to Section 351 ETF exchange transactions. ExchangiFi is not a financial institution, investment adviser, broker-dealer, law firm, or tax advisory firm.

Please read this Privacy Policy carefully to understand how we handle your information. If you do not agree to this Privacy Policy, please do not use the Services.

1. Scope and key terms

This Privacy Policy applies to personal information that ExchangiFi processes during its business operations as a “data controller,” meaning activities for which we determine the purpose and means of processing such personal information.

For purposes of this Privacy Policy, “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device, or is otherwise afforded protection under a data protection law, statute, or regulation. It does not include anonymized or de-identified data that is not attributable to a particular individual or household.

“You” refers to any individual accessing or using our Services, including registered account holders, visitors to our Site, and any other person who interacts with us through the Platform or our contact channels.

2. The types and categories of personal information we collect

ExchangiFi collects personal information: (i) when you provide it directly to us; (ii) automatically through technology when you use the Services; and (iii) from other sources.

2a. Personal information you provide directly to us

You may choose to provide personal information as you use the Services, such as when you register for an account, contact us with questions, or use our educational tools. We may collect:

• Contact data, such as your name, postal address, email address, and telephone number
• Registration information, such as usernames and passwords created for the Platform
• Professional information, such as your employer’s name and address and your title
• Communications data, such as questions, comments, or feedback you send us
• Marketing preferences, such as your preferences for receiving educational materials or updates
• Any other information you voluntarily provide in connection with your use of the Services

2b. Personal information collected automatically

When you access our Site, we automatically collect certain data using technical means and tools:

• Usage and device data — traffic data, usage logs, browsing history, resources accessed, device identifiers, general location inferred from IP address, operating system, browser type, and mobile network information
• Cookies and tracking data — cookies and other tracking technologies, including web beacons; see ExchangiFi’s Cookie Policy for details

2c. Personal information collected from other sources

We may collect personal information from third parties, such as publicly available databases, analytics providers, advertising partners, and our service providers, or from other users of the Platform who reference or interact with you through the Services.

3. How we use your personal information

Generally, we use personal information to operate our Site, provide the Services, respond to your questions, comply with legal obligations, and promote our business interests, including to:

• Provide the Services — operate the Platform, deliver educational content and tools, and save your preferences
• Account management — create and manage your account and authenticate your identity
• Communications — respond to inquiries, send account and legal notices, and, where opted in, share educational materials or updates
• Improve our Services — develop, modify, analyze, and improve the Site and Services
• Security and fraud prevention — protect the Site, detect fraud and unauthorized access, and enforce our Terms of Service
• Legal and regulatory compliance — comply with applicable laws and respond to lawful requests
• Analytics — measure the effectiveness of educational content and understand platform usage
• Business operations — manage vendor relationships and conduct auditing and quality control
• Recruiting — for hiring and talent management if you apply for a position
• With your consent — for other purposes you have expressly authorized

We may aggregate or de-identify information so it can no longer be linked to you, and use or share such data for any lawful purpose.

4. How we disclose your personal information

• Affiliates and subsidiaries — to provide or improve our Services or support business operations
• Service providers — hosting, analytics, email, customer support, payment, and security vendors, contractually bound to use information only to perform services for us
• ETF sponsors and third-party data providers — limited information necessary to facilitate your interaction with ETF-related content
• Legal and compliance — where required by law, subpoena, court order, or regulatory inquiry, or to defend our legal rights
• Business restructuring — in connection with a merger, acquisition, or sale of assets
• Protection of rights and safety — to protect ExchangiFi, our users, or the public
• With your consent — when you have affirmatively directed disclosure

ExchangiFi does not sell your personal information to third parties for their own marketing or advertising purposes.

5. Cookies and tracking technologies

ExchangiFi uses cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver relevant content. Cookies are small text files that help us recognize returning visitors, remember preferences, and understand how users interact with our Platform.

You can control cookies at the browser level. If you reject cookies, some features or areas of the Site may be limited. ExchangiFi does not respond to “Do Not Track” signals at this time, as there is no agreed-upon industry standard for interpreting them.

For more information, see ExchangiFi’s Cookie policy.

6. Links to other websites

Our Site may include links to third-party websites, including ETF fund sponsor sites, regulatory agency sites, and other educational resources. This Privacy Policy does not apply to those sites, and ExchangiFi is not responsible for their privacy practices or content. Review the privacy policies of any third-party site you visit; you assume all risk in providing personal information via such links.

7. Data retention

We retain personal information for no longer than necessary for the purposes for which it is processed, or as required by applicable law. Retention periods depend on the purpose of collection and applicable legal or regulatory requirements.

We generally retain account and registration data for the duration of your account and a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce agreements. Usage and analytics data are retained for shorter periods consistent with their operational purpose. When information is no longer needed, we delete or anonymize it.

8. Security

We use appropriate technical, physical, and organizational measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction, including encryption of data in transit and at rest, access controls, and regular security assessments.

No security system is impenetrable, and we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately at [email protected].

9. International transfers

ExchangiFi is headquartered in Palm Beach Gardens, Florida, United States, and primarily retains and processes personal information in the United States. If you access our Services from outside the United States, your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence.

By using our Services, you consent to this transfer as described in this Privacy Policy. We comply with applicable legal requirements governing cross-border transfers of personal information.

10. Children’s privacy

The Services are intended for general audiences and not for children under the age of 16. We do not knowingly collect personal information from children under 16. If we learn we have inadvertently collected such information without verifiable parental consent, we will take reasonable steps to delete it. If you believe we may have collected personal information from a child under 16, contact us immediately at [email protected].

11. Marketing communications

If we send you marketing or promotional communications, you may opt out at any time by:

• Clicking the “unsubscribe” link in any marketing email
• Contacting us directly at [email protected]

Even after opting out of marketing, we may still send transactional or administrative communications, such as account notices, legal notices, and policy updates.

12. California residents — additional privacy rights

If you are a California resident, the CCPA and CPRA provide additional rights regarding your personal information.

Categories of personal information collected

• Identifiers, such as your name, email address, IP address, and device identifiers
• Internet or other electronic network activity information
• Professional or employment-related information you provide voluntarily
• Communications data, such as the contents of messages you send us

California privacy rights

• Right to know what we collect and why
• Right to access the personal information we hold
• Right to correction of inaccurate information
• Right to deletion, subject to certain exceptions
• Right to data portability
• Right to non-discrimination for exercising these rights

Do not sell or share. ExchangiFi does not sell your personal information, nor share it for cross-context behavioral advertising within the meaning of the CCPA/CPRA.

To exercise these rights, contact us using the information in Section 19. We will verify your identity and respond within the timeframes required by law.

13. Nevada privacy rights

ExchangiFi does not currently conduct “sales” of personal information under Nevada law. Nevada residents may still submit a request directing us not to sell their personal information by contacting us via Section 19.

14. European Union, Switzerland, and United Kingdom residents

If you are a data subject in the EU, Switzerland, or the UK, ExchangiFi provides additional information regarding your data protection rights and legal basis for processing.

Data protection rights

• Right to be informed about what personal information we collect and process
• Right of access to your personal information
• Right to rectification of inaccurate or incomplete information
• Right to erasure under certain circumstances
• Right to restriction of processing under certain circumstances
• Right to data portability in a structured, machine-readable format
• Right to object to processing based on legitimate interests
• Right to withdraw consent at any time, without affecting prior lawfulness

Legal basis for processing

Where applicable, we process personal information based on your consent, our legitimate interests (such as improving our Services and platform security), performance of a contract, or compliance with a legal obligation.

Complaints

You have the right to file a complaint with your applicable data protection authority. We would appreciate the chance to address your concerns first — please contact us using Section 19.

15. Other privacy rights

Individuals in other jurisdictions, including Canada, Australia, and Japan, may have rights to access, correct, or delete personal information, or to lodge a complaint with a data protection authority. To exercise applicable rights, contact us using the information in Section 19; we will respond based on the legal regime in your jurisdiction.

16. Social media

ExchangiFi may maintain a presence on social media platforms and may respond to you through the same channel you contact us on. Use of a social media platform is also subject to that platform’s own terms, which ExchangiFi does not control. Our Site may include social media features or widgets that collect your IP address and the page you are visiting, and may set a cookie.

17. Persons with disabilities

ExchangiFi strives to ensure everyone has access to the information on our Site, including this Privacy Policy. If you would like this policy in an alternative format or require other accessibility accommodations, contact us using Section 19 and we will make reasonable efforts to accommodate your needs.

18. Changes to this Privacy Policy

We may amend this Privacy Policy at any time to reflect changes in the law, our data practices, the features of our Services, or advances in technology. The revised policy will be posted on the Site with an updated “Last updated” date. For material changes, we will provide appropriate notice as required by applicable law. Continued use of the Services after changes are posted confirms your acceptance of the latest version.

19. Contact us

If you have questions regarding this Privacy Policy or our handling of your personal information, or would like to exercise a data privacy right, please contact us at: