Aztlan Capital Privacy Policy
Last Updated April 19 2023

CATEGORIES OF PERSONAL DATA WE COLLECT

Below lists the categories of Personal Data that we might collect and may have collected over the past 12 months: • Contact Information (e.g. first and last name, email address) • Device/IP data (e.g. IP address) • Usage Analytics (e.g. interactions with our web site and newsletters) • Geolocation Data (e.g. IP-address-based location information) • Other Identifying information that You Voluntarily Provide (e.g. identifying information in emails or letters you send us) Sources of Personal Data We collect Personal Data about you from the following categories of sources: • You o When you provide such information directly to us. o When Personal Data about you is automatically collected in connection with your use of our Services (see the subsection titled “Information Collected Automatically” below). • Third Parties o Vendors: For example, we may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. o Advertising Partners: We may receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, advertisements or communications. Information Collected Automatically The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time. We use the following types of Cookies : • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable. • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. In addition to our own Performance/Analytical Cookies, the Services may contain Performance/Analytical Cookies from third party analytics services. You can learn more about these third parties in the “Personal Data Sales Opt-Out and Opt-In” section below. You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

HOW WE USE YOUR PERSONAL DATA

We process Personal Data to operate, improve, understand and personalize our Services. We collect and use Personal Data for the following purposes: • To meet or fulfill the reason you provided the information to us. • To communicate with you about the Services, including Service announcements, updates or offers. • To provide support and assistance for the Services. • To create and manage your account or other user profiles. • To personalize website content and communications based on your preferences. • To deliver our newsletters, emails and facilitate events. • To respond to user inquiries and fulfill user requests. • To improve and develop the Services, including testing, research, analysis and product development. • To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services. • To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use. • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. • For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice. As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at admin@aztlan.capital. We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

HOW WE SHARE YOUR PERSONAL DATA

We may pass your information to our related entities, affiliates, administration centers, third party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing our services to you. When we use any other third party service providers, we will disclose only the personal data that is necessary to deliver the service required and we will ensure that they keep your information secure and not to use it for their own purposes. In addition, we may transfer your personal data to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganization, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.

DATA SECURITY AND RETENTION

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or another sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. We retain Personal Data about you for as long as we have a business purpose to do so. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

PERSONAL DATA OF CHILDREN

We do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at admin@aztlan.capital.

INTERNATIONAL TRANSFERS

We are entitled to transfer your personal data to third parties abroad for the purposes of the data processing. The data that we collect from you may be transferred to, and stored at, a destination outside the British Virgin Islands, including without limitation the United States of America or any other country that may not offer an adequate level of data protection. The transfer shall be made on the basis of a previous agreement with the third-party processor. Users hereby consent to the international transfer of data as provided above.

YOUR RIGHTS

You have the following rights regarding your personal data: a) Access: to obtain free information about your personal data processed at any time and a copy of this information. b) Correct: to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you. c) Delete: to obtain from us the erasure of personal data concerning you as soon as possible. d) Restrict: in certain circumstances, to obtain from the Company restriction of processing your personal data. e) Object: to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you. f) Withdraw: to withdraw your consent to processing your personal data at any time. g) Opt-out: Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications. For purposes of exercising such rights please contact by email to admin@aztlan.capital. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at [___] or submit a complaint to the data protection regulator in your jurisdiction.

CHANGES TO THIS PRIVACY POLICY

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on our website, by sending you an email and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. Contact Information: If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: • admin@aztlan.capital

LEGAL NOTICES

You are responsible for all information, content, and materials you contribute, disclose, or share in any manner on or through the Services and you represent and warrant you have all rights necessary to do so. You are responsible for all your activity in connection with the Services. Nothing on the Services constitutes professional or financial advice of any kind (including business, employment, investment advisory, accounting, tax, and/or legal advice). Advice from a suitably qualified professional should always be sought in relation to any particular matter or circumstance. Nothing on the Services constitutes or forms a part of any offer for sale or subscription of, or any invitation to offer to buy or subscribe for, any securities, nor should it or any part of it form the basis of, or be relied upon in connection with, any contract or commitment whatsoever. You acknowledge and agree that neither Aztlan nor any other person (including, without limitation, any affiliate of Aztlan) is in any way obligated to invest in any business you are associated with or offer you to invest in any Aztlan entity or affiliate. THE SERVICES AND THE INFORMATION CONTAINED THEREIN ARE PROVIDED “AS IS.” NEITHER AZTLAN NOR ANY OF ITS AFFILIATES IS PROVIDING ANY WARRANTIES AND REPRESENTATIONS REGARDING THE SERVICES. AZTLAN AND ITS AFFILIATES DISCLAIM ALL WARRANTIES AND REPRESENTATIONS OF ANY KIND WITH REGARD TO THE SERVICES, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF THIRD-PARTY RIGHTS, OR FITNESS FOR A PARTICULAR PURPOSE. AZTLAN AND ITS AFFILIATES DO NOT WARRANT THE ACCURACY, ADEQUACY, OR COMPLETENESS OF THE INFORMATION AND MATERIALS CONTAINED ON THE SERVICES AND EXPRESSLY DISCLAIM LIABILITY FOR ERRORS OR OMISSIONS IN THE MATERIALS AND INFORMATION. To the fullest extent allowed by applicable law, under no circumstances and regardless of the form of action, whether in contract, warranty, tort (including negligence), strict liability, or otherwise, will Aztlan or its affiliates be liable to you or any other person for (i) any amount in excess of the amounts received from you in consideration for the Services or (ii) any consequential, incidental, special, punitive, or exemplary damages, regardless of whether Aztlan or its affiliates have been apprised of the likelihood of such damages occurring. To the fullest extent allowed by applicable law, you agree to indemnify and hold Aztlan, its affiliates, officers, agents, employees, and partners harmless from and against any and all claims, liabilities, damages (actual and consequential), losses and expenses (including attorneys’ fees) arising from or in any way related to any third-party claims relating to (a) your use of the Services (including any actions taken by a third-party using your account), and (b) your violation of these Terms. You and Aztlan agree that these Terms are the complete and exclusive statement of the mutual understanding between you and Aztlan and supersede all prior agreements and understandings relating to such subject matter. These Terms are governed by and will be construed under the laws of the British Virgin Islands, without regard to the conflicts of laws provisions thereof. Any disputes relating to these Terms shall be resolved exclusively in the competent courts located in Tortola, British Virgin Islands. These Terms are binding on you as well as your successors and permitted assigns. If any provision of these Terms is found to be unenforceable or invalid, that provision will be limited or eliminated, to the minimum extent necessary, so that these Terms shall otherwise remain in full force and effect and enforceable.