Modern Growth Exchange, LLC. Privacy Policy

Effective Date: May 1, 2025

1. Introduction

Welcome to Modern Growth Exchange ("we," "us," or "our"). We respect your privacy and are committed to protecting your personal data. This Privacy Policy (the "Policy") applies to information we collect, use, store, and share your information when you visit or use www.moderngrowthexchange.com (the "Site") and interact with us through the Site and through our email correspondence between you and the Site.

By using our Site, you agree to be bound by the Policy with regard to the collection and use of your information in accordance with this Policy. The Policy applies only to information we collect on or through the Site. The Policy does not apply to information we may collect offline, or that you provide to, or is collected by, any third party, which may have its own privacy policies and we encourage you to read before providing any information on or through it (See Paragraph 8). Please read the Policy carefully to understand our policies and practices regarding your information and how we will treat it. By using the Site, you further agree that we can communicate with you electronically regarding security, privacy and other administrative issues related to the Site and your use thereof. If you do not accept the terms of the Policy, you may not access or use the Site, and you should discontinue any use of it.

This Policy may change from time to time. Your continued use of the Site after we revise the Policy means that you accept those changes, so please check the Policy periodically for updates.

2. Information We Collect And How We Collect It.

1. Personal Information: We may collect personal information that you voluntarily provide when you register for an account, sign up for newsletters, fill out forms, or contact us. This may include your name, email address, postal address, phone number, and any other information you choose to provide.
2. Usage Data: We automatically collect certain information when you visit or use our Site. This may include your IP address, browser type, device identifiers, operating system, pages visited, time and date of visits, and other usage data.
3. Cookies and Similar Technologies: At this time, we do not use cookies, web beacons, and similar technologies to collect information about how you interact with our Site. Should this change, we will update this Policy in accordance with Paragraph 12.

3. How We Use Your Information

We use the information we collect for the following purposes:

1. To Communicate With You: We will only communicate directly with you if you contact us through info@moderngrowthexchange.com or in writing at our mailing address on our Site.
2. To Improve Our Site and Services: We analyze usage data to understand how our Site is being used and make improvements.

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4. How We Share Your Information

We may share your usage data in the following situations:

1. Legal Requirements: We may disclose your information if required to do so by law or in response to valid legal requests, such as subpoenas or court orders, or if necessary to protect our rights or property.
2. With Your Consent: We will share your information for any other purpose only with your explicit consent.
3. Third Parties. To contractors, service providers, and other third parties who support our business and are subject to a confidentiality obligation and use it only for the purposes for which we disclose it to them.
4. Our Employees. To our employees for the purposes of operating our business.
5. Other Purposes. For any other purpose disclosed by us when you use the Site.

5. Data Retention

We retain usage data only for as long as is necessary for the purposes set out in this Policy, unless a longer period is required by law. When we no longer need usage data, we will securely delete or anonymize it.

6. Security of Your Information

We implement appropriate technical and organizational measures designed to protect your usage data and any personal information that you may provide against unauthorized access, disclosure, alteration, or destruction. However, no method of data transmission or storage is 100% secure, and we cannot guarantee its absolute security.

7. Your Rights and Choices

State consumer privacy laws may provide their residents with additional rights regarding our use of personal information. For instance, California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia currently and, potentially other States in the future, provide their residents with rights that may allow them to:

1. Access and Update: You can request access to or correction of the personal data we hold about you.
2. Deletion: You can request the deletion of your personal data, subject to certain exceptions.
3. Opt-Out of Marketing Communications: You may opt out of receiving marketing or promotional emails by following the unsubscribe link or contacting us.
4. Cookies: You can manage or disable cookies within your browser settings. Please note that disabling cookies may affect the functionality of our Site. (Do we need, if we aren't using cookies?)

For any requests related to your personal data or rights, please contact us at info@moderngrowthexchange.com.

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8. California Privacy Notices

The following additional privacy notice ("California Notice") for California residents supplements the information contained in the other portions of the Policy and apply solely to residents who reside in the State of California ("California User"), We adopt this California Notice to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act and their related regulations ("CCPA") and other applicable California laws.

Overview of Consumer Rights Under the CCPA.

Under the CCPA, California Users have certain rights regarding their personal information including:

• The right to know the categories of personal information that we have collected and the categories of sources from which we obtained such information.
• The right to know our business purposes for sharing personal information.
• The right to know the categories of third parties with whom we have shared personal information.
• The right to know if we sold or disclosed personal information for a business purpose.
• The right to access the specific pieces of personal information we have collected.
• The right to correct personal information we have collected.
• The right to delete your personal information.
• The right not to be discriminated against if a California User exercises their rights under the CCPA.

A California User may exercise the above rights by contacting us as provided in this Policy. We will endeavor to respond to a verifiable California User's request within [forty-five] days of its receipt. If we require more time, we will inform the requester in writing and if we are unable to comply with the request, our response will explain the reasons for our inability to comply with the request.

Other California Privacy Related Disclosures

Sharing Personal Information For Direct Marketing Purposes. At the current time, we do not share personal information for direct marketing purposes. Should this change, we will, before sharing personal information of California Users with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California Users or provide such California Users with a method to opt out.

California Do Not Track Disclosures. At this time the Site is not set up to honor web browser do-not-track settings. Do-not-track is a privacy preference that users can set in their web browsers that offer this setting. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit allaboutdnt.org. (Keep, as we say that we don't have the capacity to honor "Do Not Track" settings)

Information on Marketing Disclosures. California Civil Code Section 1798.83 permits California Users to request and obtain from us, once a year, free of charge, information about personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the personal information that was shared and the names and addresses of all third parties with whom it was shared. If you are a California User and would like to make such a request, please submit your request in writing in accordance with this Policy.

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9. Third-Party Links

Our Site may contain links to third-party websites that we do not operate or control. This Privacy Policy does not apply to those third-party websites. We encourage you to review the privacy policies of any external sites you visit.

10. Security Measures

We have taken certain precautions that are intended to protect the users of the Site. However, notwithstanding our efforts, no data transmission over the internet or any wireless network can be guaranteed to be perfectly secure or private. Because of this, while we strongly try to protect any information you share with us, you transmit that information at your own risk.

11. Children’s Privacy

Our Site is not directed toward individuals under the age of 13 (or 16 in certain jurisdictions), and we do not knowingly collect personal data from children. If you believe we have inadvertently collected personal data from a child, please contact us, and we will take steps to delete such information promptly.

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12. International Data Transfers (Necessary for Usage Data only?)

If you are located outside of United States be aware that your usage data and any personal information that you may share with us may be transferred to and processed in a country different from your own. We will take steps to ensure your personal data receives an adequate level of protection where it is processed.

13. Changes to This Privacy Policy

We may update this Policy from time to time. The effective date at the top of this page indicates when this Policy was last revised. We encourage you to review this Privacy Policy periodically to stay informed about our information practices.

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14. Contact Us

If you have questions or concerns about our Policy or your personal information, please contact us at:

Modern Growth Exchange
300 Witherspoon Street
Suite 201
Princeton, NJ 06542
info@moderngrowthexchange.com