Privacy Notice | ZEDEN CAPITAL

This Privacy Policy explains how Zeden LLC (collectively, “Zeden”, “us” or “we”) collect and protect your personal information. If you have any questions that this policy does not address, please contact us at z@zeden.us.

We collect information from you in various ways when you interact with our products and services. By completing your account set-up on our website, you have consented to our collection and use of information as explained in this Notice and agree to be bound by our Terms of Use. Please note that if you choose to participate as investor, cohort, investor or service provider, you may be required to agree to a separate agreement, including, but not limited to, new or additional privacy notices or terms of use.

Lawful Basis

Our lawful basis for processing personal data from you is that it is necessary for our legitimate interests. These legitimate interests are running and growing our business, performing and developing our services for you, complying with applicable laws and regulations, preventing fraud, marketing, and IT security.

You have the absolute right to object to the processing of your personal data for direct marketing purposes. For instructions on how to object, please see below under “Opt-out Policy”.

Collection of Information

Non-Personally Identifiable Information: Zeden collects Non-Personally Identifiable Information (non-PII) from you regarding your usage of our services. Non-PII refers to data that does not, by itself, identify individual persons and may include, without limitation, website pages viewed, articles, presentation and videos viewed, time spent using certain features of the website, demographic data such as server locations, cookies existing on your devices used to access Zeden, search criteria used and results, date, time, connection speed, internet protocol ("IP") address, which may also be contained on server logs, and/or other information which does not specifically identify you. We collect this information using various technologies, including, but not limited to, cookies and server logs. "Cookies" are pieces of information that may be placed on your device by a website for the purpose of facilitating and enhancing your communication and interaction with that website. "Server logs" can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

Personally Identifiable Information: Zeden also collects Personally Identifiable Information (PII) from you when you interact with our products and services and communicate with a member of our team, including but not limited to, when you sign up for an account, verify your identity, provide payment instructions, or send us an email through the Zeden website. PII refers to information that allows us to identify you personally. Such information may include, but is not limited to, your email address, name, phone number, birthday, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, information from your transactions with us, information obtained from others (such as the Internal Revenue Service and credit reporting agencies), physical address (such as home or business address), or other information you provide or upload to the website (such as photographs, answers to questionnaires or surveys, or responses filled in on blank forms made available on the site).

We refer to PII and Non-PII collectively herein as "Personal Data". We may collect and store information, which could include Personal Data, locally on your computer or device using mechanisms such as browser web storage or application data caches. Our collection of Personal Data is necessary to our legitimate interests, which serves as our lawful basis for processing your Personal Data. Such legitimate interests are to run our business, keep our records updated, ensure legal and regulatory compliance, fulfill our obligations as a registered broker-dealer, develop our products/services, and inform our marketing strategy.

We will only retain your Personal Data for as long as necessary to fulfill certain legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

We use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the Zeden website. Google Analytics collects information including, but not limited to, the time of each of your visits to the Zeden website, whether you have visited the Zeden website before, what site referred you to the Zeden website, and what pages you viewed on the Zeden website.

This Privacy Policy does not cover the collection of information by cookies or other methods by third parties, such as our business partners. We do not control how such third parties collect information or by what means as such third parties may use their own cookies to collect information about you.

Use of Information

Zeden will use information you provide consistent with this Notice. Zeden will use information you provide to us to better serve you and enhance your experience with the Zeden website, among other things. This may include having to modify or copy such information, such as images or textual or narrative content you provide, in order to provide you with a seamless and enjoyable experience.

If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Zeden may also use your Personal Data to help us improve the content and functionality of our website, to better understand our users and to improve our services. Zeden may use this information to communicate with you regarding our services or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that as user of our services we will send you administrative communications that are reasonably necessary to our services, such as billing or service notifications.

Zeden may make your information available on its website and visible to other users of or visitors to the Zeden website. For instance, subject to certain preferences and permissions as to visibility you will be allowed to make, information you provide about yourself in response to questionnaires on our site may be made available to others, such as information concerning your status as an accredited investor. As such, other users of our website may be able to personally identify you based on your information made available on our site.

Zeden employs or contracts with other third parties, companies, or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification, accreditation/financial/credit verification, electronic document signing, payment storing and processing, sending postal mail and e-mail, engineering and product development, escrow services, disbursement of funds, analyzing data, providing marketing assistance, custodial services, broker dealer-related compliance services, and providing customer service. As such, these third parties, companies, or individuals may have access to your Personal Data as needed to perform their functions or services and may not use it for other purposes.

Zeden may also use and disclose your Personal Data: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our website or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of Zeden's business or assets. Any successor in interest to our business would acquire the information we maintain, including your Personal Data, and may alter the terms of this Privacy Notice.

We might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. We may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.

Zeden may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Zeden, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public against fraud or other harm, or (iv) protect against legal liability. Zeden does not and will not sell any of your Personal Data to any third party for purposes of advertising, soliciting, or telemarketing.

Transfers to Third Countries and International Organizations

We may share your Personal Data with certain international organizations or service providers if required by law, which may be based in various locations globally. Whenever we transfer your Personal Data, we ensure a similar degree of protection is afforded to it by only transferring your Personal Data to countries that provide an adequate level of protection for personal data compared to U.S. privacy and security standards.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data to third countries or international organizations.

Third Party Websites and Services

The Zeden website contains links to other websites and services not maintained by Zeden. In addition, other websites and services may also reference or link to the Zeden website. We encourage you to be aware when you enter or leave our website, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

We may share your Personal Data with third parties in the following categories, for purposes consistent with those listed above: payment service providers, identity verification service providers, operational service providers (such as for securities and funds custody, transfer agents, broker dealers, data storage, accounting, email, engineering and product development, IT, escrow processing, and invoicing), law enforcement agencies and regulators, and advertising or marketing service providers.

Messaging

The Zeden website permits users to communicate with companies and other users posting information on the website. We may read, collect and analyze information transmitted between users for regulatory compliance and marketing purposes. We do not guarantee that information provided by website visitors or investors is accurate or complete. Zeden assumes no liability or responsibility for any errors or omissions in the content of its website.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Zeden other than Personal Data collected through the website. This Privacy Policy shall not apply to any unsolicited information you provide to Zeden through this website or through any other means. This includes, but is not limited to, information posted to any public areas of the website, such as bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Zeden shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name and other information. If you wish to update or delete your testimonial, please contact us at info@zeden.us.

Social Media Features

Our website may also include Social Media Features such as the Facebook Like button, Twitter, and other social media functionality. These features are interactive mini-programs and may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

Opt-Out Policy

We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, or have your Personal Data used for any other direct marketing purposes, you have the right to opt-out and may unsubscribe completely by clicking the appropriate links at the bottom of the emails, managing your preferences on the website, or contacting us on the platform or over email. Please note that opt-out requests may take up to one (1) week to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.

If, after submitting a request to opt-out, you affirmatively subscribe to receive e-mails on individual offerings, issuers, or other focused subject matters, you will no longer be deemed to have opted out of those specific communications. You will, however, remain opted out for all other marketing and promotional e-mails.

We are not responsible for removing your Personal Data from the lists of any third party who has previously been provided your information in accordance with this notice.

Security

We protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

We utilize third party service providers who may store on their servers social security numbers, addresses, financial information, electronic signatures, and payment information. For your security, we only display the last four digits of your payment information when confirming an investment.

It is important for you to protect against unauthorized access to your password and to your computer/device. Be sure to log off when finished using a shared computer/device.

Children's Privacy Policy

The Zeden website is not intended for use by children under age eighteen (18 years of age). No one under age eighteen (18) years of age is allowed to use the site, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personal Data from children or teenagers under the age of eighteen (18).

Changes to This Privacy Notice

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this notice at any time. Any changes or updates will be effective immediately upon posting to the web site and/or sending a notification to all registered users via email regarding such update. You should review this notice regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our website, products, and services following the posting of any changes to this notice means you accept such changes.

Applicable Law and Jurisdiction

The Zeden website is maintained in the United States of America. By accessing the Zeden website or using any of our products or services, you consent to and authorize the export of Personal Data to the United States of America and its storage and use as specified in this Privacy Notice.

This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of Florida applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

If you are based in Europe, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

Effective Date

This Privacy Notice was last updated on March 19th, 2022.