## 1. INTRODUCTION Altworth Inc., a Delaware corporation ("Altworth," "Company," "we," "us," or "our"), is committed to protecting the privacy and security of the personal information of our users ("User," "you," or "your"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you access or use the Altworth platform, including our website, mobile applications, and all related services (collectively, the "Platform"). By using the Platform, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with the practices described herein, please do not use the Platform.

## 2. INFORMATION WE COLLECT ### 2.1 Information You Provide Directly We collect information that you voluntarily provide when you create an account, make purchases, use our services, or communicate with us, including: (a) **Account Information:** Name, email address, date of birth, phone number, mailing address, username, and password. (b) **Identity Verification:** Government-issued identification documents, proof of address, and other documentation required for identity verification, anti-money laundering (AML), and know-your-customer (KYC) compliance. (c) **Payment Information:** Payment card details, billing address, and bank account information. Note that full payment card information is processed and stored by our third-party payment processors and is not stored on Altworth's servers. (d) **Transaction Information:** Purchase history, sale history, Gacha Product purchases, Marketplace activity, buyback transactions, vaulting records, and redemption requests. (e) **Communications:** Messages, inquiries, and correspondence you send to us through the Platform, email, or other channels, including customer support interactions. (f) **User Content:** Photographs, descriptions, reviews, and other content you submit to the Platform. ### 2.2 Information Collected Automatically When you access or use the Platform, we automatically collect certain information, including: (a) **Device Information:** Device type, operating system, browser type, device identifiers, and mobile network information. (b) **Usage Information:** Pages viewed, features used, links clicked, time spent on the Platform, search queries, and interaction patterns. (c) **Location Information:** Approximate location based on IP address. We do not collect precise geolocation data without your explicit consent. (d) **Log Data:** IP address, access times, referring URLs, error logs, and server logs. (e) **Cookies and Tracking Technologies:** We use cookies, pixels, web beacons, and similar technologies to collect information about your browsing behavior and Platform usage. See Section 7 for more details. ### 2.3 Information from Third Parties We may receive information about you from third-party sources, including: (a) **Payment Processors:** Transaction confirmation and fraud prevention data. (b) **Identity Verification Services:** Results of identity and background checks conducted for KYC/AML compliance. (c) **Authentication Services:** Information from social login providers (e.g., Google, Apple) if you choose to register or log in using a third-party account. (d) **Analytics Providers:** Aggregated and de-identified usage data from analytics services. (e) **Vault Partners:** Information related to the storage, handling, and condition of your Vaulted Items.

## 3. HOW WE USE YOUR INFORMATION We use the information we collect for the following purposes: ### 3.1 Providing and Improving Our Services (a) Processing transactions, including Gacha Product purchases, Marketplace sales, buyback requests, and redemption orders. (b) Managing your vault account, including maintaining custodial records, tracking item ownership, and processing transfers. (c) Authenticating your identity and verifying your eligibility to use the Platform. (d) Providing customer support and responding to your inquiries. (e) Improving the Platform's functionality, performance, and user experience. (f) Developing new products, services, and features. ### 3.2 Pricing and Valuation (a) Operating and improving our pricing engine to provide fair market valuations for collectible and luxury goods. (b) Generating aggregate pricing data and market analytics. Such aggregate data does not identify individual Users. ### 3.3 Safety and Security (a) Detecting, investigating, and preventing fraud, unauthorized access, and other illegal or harmful activities. (b) Enforcing our Terms and Conditions and other policies. (c) Complying with anti-money laundering (AML), know-your-customer (KYC), and other legal and regulatory requirements. ### 3.4 Communications (a) Sending you transactional communications related to your purchases, account activity, and vaulting status. (b) Sending you promotional communications about new products, services, features, and offers, where you have opted in to receive such communications. You may opt out of promotional communications at any time (see Section 6). (c) Sending you administrative communications, such as changes to our Terms, Privacy Policy, or Platform features. ### 3.5 Analytics and Advertising (a) Analyzing usage trends and user behavior to improve the Platform and our marketing efforts. (b) Measuring the effectiveness of our advertising campaigns across third-party platforms, including through server-side analytics and conversion tracking. (c) Delivering targeted advertising on third-party platforms based on your interests and interactions with the Platform. You may opt out of targeted advertising as described in Section 7.

## 4. HOW WE SHARE YOUR INFORMATION We do not sell your personal information. We may share your information in the following circumstances: ### 4.1 Service Providers We share information with third-party service providers who perform services on our behalf, including payment processing, identity verification, cloud hosting, analytics, email delivery, customer support, and shipping. These providers are contractually obligated to use your information only for the purposes of providing services to Altworth and in accordance with this Privacy Policy. ### 4.2 Vault Partners We share necessary information with our Vault Partners (including Brink's and other insured vaulting facilities) to facilitate the storage, handling, insurance, and delivery of your Vaulted Items. Information shared with Vault Partners is limited to what is necessary to perform vaulting services and is subject to confidentiality obligations. ### 4.3 Marketplace Transactions When you engage in a Marketplace transaction, limited information may be shared between buyer and seller as necessary to complete the transaction. For Vaulted Item transactions, no personal information is shared between parties, as Altworth processes the transfer. ### 4.4 Legal and Compliance We may disclose your information where required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to: (a) comply with applicable law or regulation; (b) enforce our Terms and Conditions; (c) protect the rights, property, or safety of Altworth, our Users, or others; or (d) detect, prevent, or address fraud, security, or technical issues. ### 4.5 Business Transfers In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all of our assets, your personal information may be transferred as part of the transaction. We will notify you of any such transfer and any choices you may have regarding your information. ### 4.6 With Your Consent We may share your information for other purposes with your express consent.

## 5. DATA RETENTION ### 5.1 Retention Periods We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, accounting, or reporting obligations. Specific retention periods include: (a) **Account Information:** Retained for the duration of your account and for seven (7) years after account closure for tax and regulatory compliance. (b) **Transaction Records:** Retained for seven (7) years from the date of the transaction. (c) **Identity Verification Documents:** Retained for the period required by applicable AML/KYC regulations, typically five (5) to seven (7) years after the end of the business relationship. (d) **Custodial Records:** Records documenting ownership and chain of custody of Vaulted Items are retained for seven (7) years after the item leaves Altworth's custody. (e) **Communications:** Customer support records are retained for three (3) years. ### 5.2 Deletion When personal information is no longer needed for its original purpose and no legal obligation requires its retention, we will securely delete or anonymize it.

## 6. YOUR RIGHTS AND CHOICES ### 6.1 Access and Correction You may access and update your account information at any time through your account settings. You may also contact us to request access to or correction of your personal information. ### 6.2 Deletion You may request deletion of your personal information by contacting us at privacy@altworth.com. We will comply with deletion requests to the extent permitted by law, subject to our data retention obligations described in Section 5. Note that deletion of your account information will require redemption of all Vaulted Items prior to account closure. ### 6.3 Opt-Out of Marketing Communications You may opt out of promotional communications at any time by clicking the "unsubscribe" link in any promotional email or by updating your notification preferences in your account settings. Opting out of promotional communications does not affect transactional or administrative communications. ### 6.4 Cookie Preferences You may manage your cookie preferences through our cookie consent tool, your browser settings, or as described in Section 7. ### 6.5 Do Not Track The Platform currently does not respond to "Do Not Track" browser signals, as there is no industry-standard protocol for honoring such requests. ### 6.6 Additional Rights for Specific Jurisdictions Depending on your jurisdiction, you may have additional privacy rights, including the right to data portability, the right to restrict processing, or the right to lodge a complaint with a supervisory authority. If you are located in the European Economic Area (EEA), United Kingdom, or California, please see Section 10 for additional information about your rights.

## 7. COOKIES AND TRACKING TECHNOLOGIES ### 7.1 Types of Cookies We use the following types of cookies and tracking technologies: (a) **Essential Cookies:** Required for the Platform to function properly, including session management, authentication, and security. These cannot be disabled. (b) **Analytics Cookies:** Help us understand how Users interact with the Platform, including page views, session duration, and error tracking. We use services including Google Analytics 4 for this purpose. (c) **Advertising Cookies:** Used to deliver and measure the effectiveness of advertising campaigns across platforms including Google Ads, Meta, TikTok, and X. These cookies enable conversion tracking and audience targeting. (d) **Functional Cookies:** Enable enhanced functionality and personalization, such as remembering your preferences and settings. ### 7.2 Server-Side Tracking In addition to client-side cookies, Altworth uses server-side analytics tracking through Google Tag Manager and platform-specific conversion APIs. Server-side tracking processes conversion events on our backend infrastructure before forwarding data to advertising platforms. This enables accurate measurement of campaign performance regardless of client-side cookie or ad-blocker settings. ### 7.3 Managing Cookies You may manage your cookie preferences by: (a) using the cookie consent tool displayed when you first visit the Platform; (b) adjusting your browser settings to block or delete cookies; or (c) using platform-specific opt-out tools for targeted advertising (e.g., Google's Ad Settings, Meta's Ad Preferences). Note that blocking essential cookies may impair Platform functionality.

## 8. DATA SECURITY ### 8.1 Security Measures We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and employee training. ### 8.2 No Guarantee While we take reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your personal information. ### 8.3 Breach Notification In the event of a data breach that affects your personal information, we will notify you and applicable regulatory authorities in accordance with applicable law.

## 9. CHILDREN'S PRIVACY The Platform is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe that a child under 18 has provided us with personal information, please contact us at privacy@altworth.com.

## 10. JURISDICTION-SPECIFIC PROVISIONS ### 10.1 California Residents (CCPA/CPRA) If you are a California resident, you have additional rights under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including: (a) **Right to Know:** You have the right to request the categories and specific pieces of personal information we have collected about you, the sources of collection, the business purposes for collection, and the categories of third parties with whom we share your information. (b) **Right to Delete:** You have the right to request deletion of your personal information, subject to certain exceptions. (c) **Right to Opt-Out of Sale/Sharing:** We do not sell your personal information. If we share your personal information for cross-context behavioral advertising, you may opt out by contacting us at privacy@altworth.com. (d) **Right to Non-Discrimination:** We will not discriminate against you for exercising your privacy rights. To exercise these rights, contact us at privacy@altworth.com or call (219) 342-3851. We will verify your identity before processing your request. ### 10.2 European Economic Area and United Kingdom (GDPR/UK GDPR) If you are located in the EEA or UK, the following additional provisions apply: (a) **Legal Basis for Processing:** We process your personal data on the following legal bases: (i) performance of our contract with you (processing transactions, managing your vault); (ii) compliance with legal obligations (AML/KYC, tax reporting); (iii) our legitimate interests (fraud prevention, security, Platform improvement); and (iv) your consent (marketing communications, non-essential cookies). (b) **International Data Transfers:** Your personal data may be transferred to and processed in the United States and other countries outside the EEA/UK. We implement appropriate safeguards for such transfers, including Standard Contractual Clauses approved by the European Commission or UK Information Commissioner's Office. (c) **Additional Rights:** You have the right to: (i) access your personal data; (ii) rectify inaccurate data; (iii) erase your data (subject to legal retention obligations); (iv) restrict processing; (v) data portability; (vi) object to processing based on legitimate interests; and (vii) withdraw consent at any time. (d) **Supervisory Authority:** You have the right to lodge a complaint with your local data protection supervisory authority. (e) **Data Protection Officer:** For inquiries related to GDPR or UK GDPR, contact us at privacy@altworth.com.

## 11. THIRD-PARTY LINKS AND SERVICES The Platform may contain links to third-party websites, services, or applications. This Privacy Policy does not apply to third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access through the Platform.

## 12. 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 revised Privacy Policy on the Platform, updating the "Last Updated" date, and, where appropriate, sending you an email notification. Your continued use of the Platform following any modification constitutes acceptance of the revised Privacy Policy.

## 13. CONTACT US If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: **Altworth Inc.** Email: privacy@altworth.com Phone: (219) 342-3851 Address: 1111B S Governors Ave STE 40977, Dover, DE 19904 For privacy-related complaints, please contact us first so that we can attempt to resolve the issue. If we are unable to resolve your complaint, you may have the right to lodge a complaint with a data protection authority in your jurisdiction.

*This Privacy Policy was last updated on March 4, 2026.*