Fine Treasure Privacy Policy

This Privacy Policy describes how Fine Treasure, LLC and Fine Treasure CF SPV, LLC (“we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you visit or use our Regulation Crowdfunding (“Reg CF”) investment landing page and related services (the “Site”) for our Reg CF offering (the “Offering”).

By visiting the Site, providing any of your identifying information to us, or starting or submitting an investment commitment, you consent to the collection, use, disclosure, and processing of your personal information as described in this Privacy Policy.

1. Scope of this Privacy Policy

This Privacy Policy applies to:

• Visitors to the Site (including people who only browse)
• Individuals who submit any personally identifiable information or contact information (e.g., to download an investor brief, join a waitlist, or subscribe to updates)
• Individuals who start, complete, or manage an investment through the Site

This Privacy Policy does not apply to:

• Your use of third-party websites, platforms, or services that we do not control, including the DealMaker platform and any funding portal or broker-dealer websites you may access via links or embedded widgets (see Third-Party Websites & Platforms below)

2. Information We Collect

We may collect the following categories of information about you.

2.1 Information You Provide Directly

• Contact details: name, email address, phone number, mailing address
• Investment details: your accreditation status, responses to investor questionnaires, volume of securities you seek to purchase
• Account Information: username and password, including from third-party sites
• Communications: any messages you send to us (e.g. via forms, email, Q&A forums, etc.)
• Marketing preferences: your choices about receiving updates, promotional emails, and other communications

2.2 Information Collected Automatically

When you visit the Site, we and our service providers may automatically collect:

• Device and usage information: IP addresses, browser type, operating system, device identifiers
• Visit details: pages viewed, links clicked, time spent on pages, referring/exit pages, and general location based on IP address
• Cookies and similar technologies: identifiers and usage data collected through cookies, pixels, tags and similar tools (see Cookies & Tracking Technologies below)

2.3 Information from Third Parties

We may receive information about you from:

• DealMaker and regulated intermediaries (e.g., broker-dealers, funding portals) in connection with your investment, identity verification (KYC), anti-money laundering (AML) checks, payment processing, or regulatory requirements
• Analytics and advertising partners that help us understand Site usage and Offering performance
• Other service providers who help us operate the Site, verify information, or provide customer support

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Operating the Site and the Offering

• Displaying content and providing you with access to the Offering
• Enabling you to start, complete, and manage an investment
• Coordinating with DealMaker and regulated intermediaries to process your investment

3.2 Regulatory and Compliance Purposes

• Verifying your identity (KYC) and complying with AML and other legal obligations
• Satisfying securities law requirements related to Reg CF offerings
• Maintaining records as required by applicable law and regulation

3.3 Communications

• Responding to your inquiries and requests
• Sending transactional or service-related messages regarding your investment or account
• Providing updates about the offering, including material developments, reports, and notices

3.4 Marketing & Investor Relations (where permitted)

• Sending you newsletters, investor updates, and promotional information about our business or future offerings, consistent with your preferences and applicable law
• Personalizing content and communications (e.g., tailoring follow-up based on your level of engagement)

3.5 Analytics, Performance, and Security

• Understanding how visitors use the Site to improve design, content, and user experience
• Monitoring and protecting the security and integrity of the Site, our systems, and our users
• Detecting, investigating, and preventing fraud, unauthorized activities, and other misuse

3.6 Legal, Risk Management, and Business Operations

• Enforcing our terms, policies, and agreements
• Complying with legal processes or governmental requests
• Supporting audits, due diligence, and potential transactions (such as financing, restructuring, or M&A)

4. Cookies & Tracking Technologies

We and our service providers may use cookies and similar technologies (e.g., pixels, tags, and local storage) to:

• Remember your preferences and settings
• Help you navigate the Site efficiently
• Measure Site performance and improve user experience
• Understand campaign performance and investor behavior in aggregate

You can typically control cookies through your browser settings. However, disabling certain cookies may affect Site functionality or limit your ability to use some features.

If we use cookies for advertising or retargeting, we will do so in accordance with applicable law. DealMaker does not provide a feature for you to opt out of this use of cookies and you must rely on your browser settings and features in order to opt out of cookies to the extent that your browser allows you to.

5. How We Share Your Information

We may share your information with the following categories of recipients, as required or permitted by law:

5.1 DealMaker, Broker-Dealers, and Funding Portals

• DealMaker and any registered broker-dealer or funding portal involved in hosting the Offering or processing your investment in the Offering

Their use of your information is governed by their own privacy policies and terms, which you should review carefully.

5.2 Service Providers

We may share information with third-party vendors who provide services such as:

• Website hosting and maintenance
• Data storage and backup
• Analytics and performance monitoring
• Email delivery and communication tools
• Compliance, KYC/AML, and fraud prevention services

These providers are authorized to use your information only as necessary to perform services on our behalf.

5.3 Affiliates and Related Entities

We may share information with our affiliates or controlled entities for purposes consistent with this Privacy Policy, such as investor relations, reporting, and business operations.

5.4 Legal and Compliance

We may disclose information:

• When required by law, regulation, subpoena, or other legal process
• In response to lawful requests by public authorities, including to meet national security or law enforcement requirements
• To protect our rights, property, safety, or that of our users, investors, or others

5.5 Business Transfers

If we are involved in a merger, acquisition, reorganization, sale of assets, securities offering, or similar transaction, your information may be transferred as part of that transaction, consistent with applicable law.

We do not sell your personal information in the traditional sense (i.e., for monetary payment) as that term is commonly understood, but certain data-sharing practices may be treated as a “sale,” “sharing,” or “targeted advertising” under some privacy laws. If applicable, we will provide additional notices and choices.

6. Third-Party Websites & Platforms

The Site may contain links to, or integrations with:

• The DealMaker investment platform
• Funding portals or broker-dealer websites
• Other third-party sites, tools, or services

We do not control the privacy practices of these third parties, and this Privacy Policy does not apply to them. Your use of those services is subject to their own terms and privacy policies, which we strongly encourage you to review. If you are looking for a list of which integrations the Site uses, so that you can identify whose privacy policy applies to such services, please reach out to us and we will inquire of DealMaker specifically which features are run by which third parties.

For example, your investment may be processed through the DealMaker platform, which is governed by DealMaker’s own Privacy Policy available at: https://www.dealmaker.tech/privacy

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law (for example, for tax, legal, or regulatory compliance purposes).

Because securities and investment records are subject to specific regulatory retention periods, certain information may be kept for a number of years after your investment or our relationship with you has ended.

8. Your Rights & Choices

Depending on where you live and applicable law, you may have certain rights regarding your personal information, such as:

• Access: Request confirmation of whether we hold your personal information and receive a copy
• Correction: Request that we correct or update inaccurate or incomplete information
• Deletion: Request that we delete certain personal information, subject to legal and regulatory obligations
• Restriction or objection: Object to or request that we limit certain uses of your information
• Marketing choices: Opt out of receiving promotional emails from us by following the unsubscribe instructions in those emails

We may need to retain or continue to process certain information even after a deletion or restriction request to comply with securities laws, KYC/AML rules, and other legal obligations.

To exercise your rights or update your preferences, please contact us using the details in Contact Us below. We may need to verify your identity before fulfilling your request.

9. Security

We take reasonable technical, administrative, and physical measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction.

However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you use the Site and provide information at your own risk.

10. Children’s Privacy

The Site and our Offering are intended only for individuals 18 years of age or older.

We do not knowingly collect personal information from children under 18. If we learn that we have inadvertently collected information from a child under 18, we will take reasonable steps to delete it as required by law. If you believe a child has provided us with personal information, please contact us promptly.

11. International Users

The Site is primarily directed to individuals located in the United States. If you access the Site from outside the U.S., you understand that your information may be transferred to, stored, and processed in the United States or other jurisdictions that may not provide the same level of data protection as your home country.

Where required by law, we will implement appropriate safeguards for such transfers.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page and may provide additional notice where required (such as a prominent notice on the Site or by email).

Your continued use of the Site after any changes becomes effective indicates your acceptance of the revised Privacy Policy.

13. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact us at:

Fine Treasure, LLC
7120 Rafael Ridge Way
Las Vegas, NV 89119
Email: privacy@finemgmt.com

If your question relates to the processing of your information by DealMaker, a funding portal, or broker-dealer used for this offering, please refer to their contact information and privacy policies as provided on their respective websites.