Equity Shift, Inc.

Privacy Policy

Equity Shift, Inc. (the “Company,” “we” or “us”) and any of its pages, applications, services, groups, and networks (individually and collectively, the “Website”) are an important means of providing you with information related to our Company and about conducting one or more Securities Transactions with us.

By accessing and using the Website, you agree and certify that you have read, understand, and agree to this Privacy Policy (“Policy”), whether or not you register for a profile with the Website by providing us with your email address and other personal information as described herein (a “Registered Profile Holder”), or whether or not you purchase, acquire, or transfer the Securities through a Securities Transaction. All users that access the Website, whether or not you are a Registered Profile Holder, are referred to as “you” or “Users”.

We reserve the right, in our sole discretion, to change, modify, add, or delete portions of this Policy at any time without further notice and such modifications are, unless otherwise stated in this Policy, effective immediately. If this Policy is modified, such changes shall be posted on the Website and Company will make reasonable efforts to bring any modifications to the attention of User at the time of User’s access of the Website. Your continued use of the Website after any such changes constitutes your acceptance of the revised Policy. If you do not agree to this or any future Policy, you shall not use or access (or continue to use or access) the Website.

INFORMATION WE COLLECT FROM ALL USERS

We collect non-personally identifiable information from all Users, whether or not such Users are Registered Profile Holders. In order to provide a responsive and useful service, when you visit our Website, we collect certain non-personally identifiable information including the name of your Internet service provider, your IP address, the website from which you came to ours, the web pages you visit within our Websites, the time and length of your visit, and other information important to our marketing analysis and research. We may use cookies and active components (for example, JavaScript components) to collect aggregate information about the preferences of our visitors and optimize our Website accordingly. We may collect this non-personally identifiable information without providing further notice to you.

We may use cookies and other tools to collect and store your preferences, usage habits, and record session information. A “cookie” is a small data file that is transferred to your hard drive and used for record-keeping purposes. A cookie file can collect information such as the URL, computer IP address, domain type, browser type, the country, state, and telephone area code where your server is located, the pages of the Website viewed, and any search terms entered on the Website. Cookies and similar tools allow us and third parties to collect information about a user’s online activities over time and across different websites. These cookies allow us to customize the Website content to your preferences, profile, and/or demographic information. As technology changes, the use and function of cookies may change, and they may be replaced by other technologies. We have no obligation to update this Policy to reflect such changes. You may configure your internet browser or other settings to accept or reject all or some cookies, or notify you when a cookie is sent; however, you may be required to set your browser to enable cookies from us in order to use most functions on the Website. Even if your browser’s settings are set to send “do not track” signals or other mechanisms to prevent tracking by cookies and similar tools, we may collect information about you and your activity. Please note that we allow third party advertisers to place and access cookies on a User’s computer. Advertisers’ use of cookies is subject to their own policies, not this Policy.

INFORMATION WE COLLECT FROM REGISTERED ACCOUNT HOLDERS

In addition to the information we collect from all Users, we collect both personally identifiable information and other information that is not personally identifiable about individuals and entities that become Registered Profile Holders. Registered Profile Holders may be asked to give to us, or to confirm the accuracy of, personally identifiable information provided in the course of registration for a profile through the Website, or in connection with their purchase, acquisition, or transfer of the Securities via a Securities Transaction (such as name, tax identification number, social security number, postal and email addresses, date of birth, and other information). To become a Registered Profile Holder and to purchase Securities, you must provide us with an email address, which we will use to provide you with access to a private investment landing page associated with our Website (the “Private Investment Page”). The Private Investment Page will enable you to qualify to participate in Securities Transactions.

In registering to become a Registered Profile Holder, accessing your profile with the Website, or accessing your Private Investment Page, we use a two-factor authentication method. Using two-factor authentication and entering your credentials when prompted will provide a more secure means to both register with the Website in connection with becoming a Registered Profile Holder, access your profile as a Registered Profile Holder, and access your Private Investment Page, without the need for a password. Should you provide your credentials using this method, we will not have access to any additional personal information except as stated in this Policy. You are required to use two-factor authentication to become a Registered Profile Holder, access your profile as a Registered Account Holder, or access your Private Investment Page.

We may also obtain information from or about Registered Profile Holders in other ways. For example, we will receive and access certain of your personal information from a Verification Vendor (as defined below) and we may verify or combine your information with additional information we collect from other service providers, our affiliates and other third parties or sources, as authorized and permitted by law. Also, we collect the information you send to us such as correspondence, investor qualification surveys, and customer satisfaction surveys or customer service communications.

It is your option to provide the information requested, but declining to provide us with such information may prevent you from participating in Securities Transactions or may impact your rights with respect to the Securities you may own or transfer as a result of such participation.

YOUR PRIVACY AND SECURITY

We value the privacy and security of your personal information. We have implemented commercially-reasonable measures designed to keep your personal information safe from unintended disclosure, including physical, electronic, administrative, and procedural protections. Despite our efforts, however, factors beyond our reasonable control, such as a malicious breach by a “hacker”, may result in disclosure of your personal information. Accordingly, we are not in a position to guarantee that your information will be secure under all circumstances and we offer no warranties or representations with regards to the maintenance or non-disclosure of your information. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

USE OF INFORMATION AND INFORMATION SHARING

We use the information we collect from Registered Profile Holders to facilitate the Securities Transactions, to communicate with and provide notice to Registered Profile Holders, to provide Registered Profile Holders with information about the Issuers terms of any Securities they may own or transfer, and to update them on the current policies and procedures applicable to the Securities Transactions. We will use the information we collect to request your participation in investor qualification and participation surveys.

We may also use the information we collect from all Users to tailor and personalize our marketing, products and services, and to continually improve the Website. We may also use the information we collect to request your participation in surveys and promotions, and we may send you product information, updates or special offers. If you no longer wish to receive these kinds of promotional communications from us, you may opt out at any time by sending a request using email to: optout@equityshift.com.

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to optout@equityshift.com or write us at: 1 Glenwood Ave., Suite 04-111 Raleigh, NC 27603 The information we collect may be stored, processed, and passed on to third parties, such as service providers, direct marketing companies, or our joint marketing partners.

The reasons we may share your information include the following: to comply with applicable law, to process and coordinate your participation in the Securities Transactions; to maintain the personal information stored about you; to respond to legal investigations; to offer products and services to you, including the opportunity to participate in the Securities Transactions; to jointly market products and services with other companies; to market our affiliates’ products and services to you; and to market nonaffiliated third parties’ products and services to you. We may share your information within our organization, with affiliated persons and entities (such as Parent, is subsidiaries, affiliates and agents), and with nonaffiliated persons and entities. If you do not wish for us to share your personally-identifiable information with nonaffiliated third parties, you may opt out at any time by sending an email request to: optout@equityshift.com. Opting out of certain information sharing may prevent you from participating in the Securities Transactions.

Additionally, Registered Profile Holders may be required to submit personal information to one of more accredited investor verification service providers (each, a “Verification Vendor”). Declining to provide the Verification Vendor with your personally identifiable information (including certain financing information) can prevent you from participating in certain stages of the Securities Transactions. Any information you give to the Verification Vendor shall be subject to the Verification Vendor’s privacy policy and terms of use. Accordingly, we are not in a position to guarantee that the information shared with the Verification Vendor will be secure under all circumstances and we offer no warranties or representations with regards to the maintenance or non-disclosure of such information. We will not share any information we receive from you with any Verification Vendor, but we will receive certain personal information you submit to such Verification Vendor in connection with your registration to participate in the Securities Transactions.

We may also use, share, or transfer your personally-identifiable information and non-personally-identifiable information as required or permitted by applicable law. You agree to provide valid, accurate, and complete information as requested and to keep all such information complete and current.

UPDATING YOUR PERSONAL INFORMATION

Registered Profile Holders will be entitled to review, correct, or amend their personal information, or to delete that information where it is inaccurate, by accessing the profile on the Website. This right shall only be limited where the burden or expense of providing access would be disproportionate to the risks of your privacy, or where the rights of persons other than you would be violated.

If you unsubscribe from all of our services and/or decide not to participate in the Securities Transactions, we will retain your personal information as necessary to deter fraud, investigate illegal activities, respond to regulatory authorities, and comply with applicable laws and Company policies. However, if you discontinue participation in the Securities Transactions through our Website pursuant to this section, your personally identifiable information will not be used for marketing purposes, nor sold or shared with third parties, except as required by law, or in accordance with this Policy.

OTHER WEBSITES

Our Website may contain links to other websites which are not owned or controlled by us. If you follow a link to a third party’s website, we do not assume any liability for the performance, quality, accuracy, timeliness, reliability, or any other aspect of products or services on any other website and can make no representation or warranty with regard to such third-party sites. We are not responsible for third parties’ legal or privacy policies, nor for their processing of personal data.

OWNERSHIP AND ACCESS

Subject to your compliance with this Policy, we grant you a limited, revocable license to access and make personal use of the Website. You shall not modify the Website and shall not reproduce, duplicate, copy, sell, or resell the Website, any portion thereof, or any products, services, or other content on this Website. This limited license does not include any resale or commercial use of the Website or its products, services, or other content; any derivative use of this Website, its products, services, or other content; or any use of robots or other data mining, gathering, and extraction tools.

You may have the opportunity to upload personal information, personally identifiable information, documents, records, and other content (collectively, the “content”) on or through the Website. You understand and agree that we may, but are not required to, review and delete, without notice, any content that, in our sole judgment, violates this Policy or which might be offensive, illegal, or that might violate the rights, harm, or threaten the safety of you or others. By providing any content to us or through the Website, you grant to us an unrestricted, irrevocable, worldwide, royalty-free license to use, reproduce, display, transmit and distribute such information and materials, and you further agree that we are free to use any ideas, concepts or know-how that you or individuals acting on your behalf provide through the Website.

You understand and agree that all content and other personal information that you supply to us will be stored in and accessible from locations within and without the United States of America, for the purposes set forth herein, and may be subject to production or disclosure requirements by United States authorities in accordance with applicable United States laws. The Website is owned and operated by Equity Shift, Inc., and its addresses are www.equityshift.com and ats.equityshift.io. If you have any questions about this Policy, or you wish to amend, update, or verify the information on file, or to notify us that you want your information deleted from our files, please contact us. We can be reached at the above address, and by e-mail at info@equityshift.com.

CONFIDENTIALITY AND NONDISCLOSURE

In your capacity as a User, Registered Profile Holder and in connection with this Policy, your use of our Website, your participation in Securities Transactions, or your ownership of Securities, the Company may disclose or make available to you certain confidential information, including but not limited to technical, financial, purchasing, or business information (collectively, the “Confidential Information”). By using the Website as a User, Registered Profile Holder, you agree that you: (i) will use the Confidential information solely for the purpose(s) of participating in Securities Transactions; (ii) will take reasonable precautions to ensure the Confidential Information remains confidential; (iii) will not communicate, disclose, divulge, distribute reproduce, or transmit the Confidential Information to any person or entity, except as set forth herein; or (iv) will not use the Confidential Information to the detriment of the Company, or any User of this website, in any unlawful manor. The foregoing confidentiality obligations are unconditional and shall survive termination or amendment of this Policy or the termination of your relationship with the Company.

Notwithstanding the foregoing, you may reveal the Confidential information only as follows: (i) to individuals or entities on a need-to-know basis for the limited purpose of facilitating your participation in the Securities Transaction; (ii) to governmental regulatory agencies in the context of their regulatory jurisdiction over you or the Company; or (iii) pursuant to a court or regulatory agency order enforceable against you or the Company.

LIABILITY AND INDEMNITY

You, the User, agree that use of the Website is at your sole risk. The Website is provided on an “AS IS” and “AS AVAILABLE” basis, except as otherwise prohibited by applicable law. WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY OF ANY KIND, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT OF INTELLECTUAL PROPERTY. We do not guarantee any specific results from use of the Website or the purchase of any securities. No advice or information, whether oral or written, from or through use of the Website shall create any representation or warranty not expressly stated herein. We assume, and shall have, no responsibility for any error, omission, interruption, deletion, defect, delay in operation or transmission, communications line failure, theft or destruction or unauthorized access to, or alteration of, your communications, Data, or content. We are not liable for any problems or technical malfunction caused by any of the equipment or programming associated with or utilized by the Website. Except in jurisdictions where such provisions are restricted, in no event shall we be liable to you or any other person, entity, or organization for any indirect, consequential, exemplary, incidental, special or punitive damages, including for any lost profits or lost data arising from or in any way related to your use of the Website, your purchase or use of any of the products or services offered, advertised, or sold through the Website, or any of the Website content or other materials, even if arising from our negligence and even if we are aware or have been advised of the possibility of such damages. Notwithstanding anything to the contrary contained herein, our liability to you for any cause of action, claim, or liability whatsoever, and regardless of the form of the cause of action, claim or liability, shall at all times be limited to the amount paid, if any, by you directly to us for the specific product or service which is the subject of the claim, but in no event shall our liability to you exceed the actual amount you have paid directly to us. You acknowledge that if no fees are paid to us by you for any product or service, you shall be limited to injunctive relief only, unless otherwise permitted by law, and shall not be entitled to damages of any kind from us, regardless of the cause of action.

You, the User, agree to defend, indemnify, and hold us harmless from and against any and all loss, damage, claim judgment, demand, liability, or expense (including reasonable attorneys’ fees and expenses), in any way related to, arising out of, or connected with: (i) User’s content or data; (ii) User’s use of the Website; (iii) User’s providing of false, inaccurate, misleading, or fraudulent Data or other information to us; (iv) User’s connection to the Website; (v) User’s violation or breach of this Policy; (vi) User’s violation or breach of any representation or warranty made by User to us; (vii) User’s violation or breach of any third party right, including without limitation, any intellectual property right, defamation, breach of confidence, or privacy right; or (viii) Any claim that User’s content caused damage to a third party. User’s obligations shall survive the termination of User’s Private Investment Page and/or the termination of User’s use of the Website. User is solely responsible for his/her/its actions, and the actions of its agents, when using the Website.

SUCCESSORS

In the event that we are acquired by or merged with any third-party entity (including the sale of substantially all of our assets or of substantially all of any business unit), we reserve the right, in any of these circumstances, to transfer or assign your content, data, personal information, and the licenses obtained from you. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used. You understand this and agree to hold us harmless in such circumstances.

Changes To This Privacy Policy

This Policy was adopted on January 1, 2021.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the adopted date on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: info@equityshift.com.

© 2021 Equity Shift, Inc.