California Privacy Notice (CCPA/CPRA)

Table of Contents

Introduction

This California Privacy Notice supplements our main Privacy Policy and provides specific information required under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) for California residents.

This Notice should be read together with our main Privacy Policy, which contains comprehensive information about how we collect, use, and protect your personal information. This Notice provides additional details specific to California privacy law requirements.

Scope: This Notice applies to personal information of California residents that we collect and process in connection with our services.

Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information from California residents:

Identifiers

• Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers

Personal Information Categories Listed in Cal. Civ. Code § 1798.80(e)

• Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information

Protected Classification Characteristics

• Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)

Commercial Information

• Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Biometric Information

• Genetic, physiological, behavioral, and biological characteristics (we may collect biometric information for identity verification purposes, such as selfie photos or video verification)

Internet or Other Electronic Network Activity

• Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement

Geolocation Data

• Physical location or movements (e.g., IP-based geolocation)

Sensory Data

• Audio, electronic, visual, thermal, olfactory, or similar information (e.g., video recordings for identity verification)

Professional or Employment-Related Information

• Current or past job history or performance evaluations

Non-Public Education Information

• Education records directly related to a student maintained by an educational institution or party acting on its behalf

Inferences Drawn from Other Personal Information

• Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Sensitive Personal Information

Under CPRA, certain information is considered "sensitive personal information," including:

• Social Security number, driver's license, state identification card, or passport number
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Precise geolocation
• Racial or ethnic origin, religious or philosophical beliefs, or union membership
• Contents of mail, email, and text messages unless we are the intended recipient
• Genetic data
• Biometric information processed for the purpose of uniquely identifying a consumer
• Personal information collected and analyzed concerning a consumer's health or sex life or sexual orientation

Sources of Personal Information

We collect personal information from the following sources:

• Directly from You: Information you provide when creating an account, using our services, completing KYC/KYB verification, or communicating with us
• Automatically from Your Use of Services: Information collected automatically when you use our platform, such as usage data, IP address, and device information
• Third-Party Service Providers: Information from identity verification providers, payment processors, and other service providers
• Public Sources: Information from public records, blockchain data, and other publicly available sources
• Affiliates and Partners: Information from our affiliates and business partners (if any)

Business or Commercial Purposes for Collection

We collect and use personal information for the following business or commercial purposes:

• Providing Our Services: To provide, maintain, and improve our platform and services
• Legal Compliance: To comply with legal obligations, including KYC/AML requirements, tax reporting, and regulatory compliance
• Security and Fraud Prevention: To detect and prevent fraud, security threats, and illegal activity
• Communications: To communicate with you about your account, transactions, and our services
• Analytics and Improvement: To analyze usage patterns and improve our services
• Marketing: To send marketing communications (with your consent or where permitted by law)
• Enforcement: To enforce our Terms of Service and other agreements

Categories of Personal Information Shared

In the past 12 months, we have shared the following categories of personal information with third parties:

• Service Providers: We share personal information with service providers who perform services on our behalf, such as identity verification providers, cloud hosting providers, analytics providers, and payment processors
• Legal and Regulatory: We may share personal information with law enforcement, regulators, and other parties as required by law or to protect our rights
• Business Transfers: We may share personal information in connection with mergers, acquisitions, or other business transfers

We do not "sell" personal information in the traditional sense. However, under CCPA/CPRA, certain sharing of personal information with third parties (e.g., for analytics or advertising) may be considered "selling" or "sharing" of personal information. For more information, see "Do Not Sell or Share My Personal Information" below.

Do Not Sell or Share My Personal Information

Under CCPA/CPRA, California residents have the right to opt out of the "sale" or "sharing" of their personal information. We do not sell personal information for monetary compensation. However, we may share personal information with third parties (such as analytics providers or advertising partners) in ways that may be considered "selling" or "sharing" under CCPA/CPRA.

Your Right to Opt Out: California residents have the right to opt out of the sale or sharing of their personal information. To exercise this right, you may:

• Submit a request via email to privacy@becomingalpha.world with the subject line "California Opt-Out Request"
• Use any opt-out mechanism we provide on our website or platform (if available)

Authorized Agents: You may designate an authorized agent to submit opt-out requests on your behalf. See "Authorized Agents" below for more information.

Limit Use of Sensitive Personal Information: Under CPRA, you also have the right to limit the use and disclosure of your sensitive personal information to purposes necessary to provide our services. To exercise this right, please contact us at privacy@becomingalpha.world.

Your California Consumer Rights

Under CCPA/CPRA, California residents have the following rights regarding their personal information:

1. Right to Know

You have the right to know:

• What categories of personal information we collect
• What categories of personal information we sell or share (if any)
• What categories of personal information we disclose for business purposes
• The categories of sources from which we collect personal information
• The business or commercial purposes for collecting, selling, or sharing personal information
• The specific pieces of personal information we hold about you

2. Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions, such as when we need to retain information to:

• Complete a transaction or fulfill a contract
• Comply with legal obligations (e.g., AML/KYC retention requirements)
• Detect and prevent fraud or security threats
• Exercise free speech or other legal rights

3. Right to Correct

Under CPRA, you have the right to request correction of inaccurate personal information.

4. Right to Opt Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information (see "Do Not Sell or Share My Personal Information" above).

5. Right to Limit Use of Sensitive Personal Information

Under CPRA, you have the right to limit the use and disclosure of your sensitive personal information to purposes necessary to provide our services.

6. Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights. See "Non-Discrimination" below for more information.

How to Exercise Your Rights

To exercise your California consumer rights, please:

1. Submit a request via email to privacy@becomingalpha.world
2. Include the following information:
   • Your name and email address
   • Description of the right you wish to exercise
   • If requesting access or deletion, specify what information you are requesting

We will respond to your request within 45 days (may be extended by an additional 45 days for complex requests). We may need to verify your identity before processing your request.

Verification Process

To protect your privacy and security, we may need to verify your identity before processing certain requests. Verification may require:

• Providing information that matches our records (e.g., email address, account username)
• Answering security questions
• Providing government-issued identification (for certain sensitive requests)

We will only use information provided for verification purposes and will not use it for any other purpose.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. Authorized agents must:

• Provide proof of your written permission to act on your behalf
• Verify their own identity
• Provide information to verify your identity

We may deny requests from agents who do not provide adequate proof of authorization.

Non-Discrimination

We will not discriminate against you for exercising your privacy rights. This means we will not:

• Deny you goods or services
• Charge you different prices or rates
• Provide you a different level or quality of services
• Suggest that you may receive different treatment for exercising your rights

However, we may charge different prices or provide different levels of service if the difference is reasonably related to the value provided to us by your data, or if the service requires certain personal information to function.

Contact Information

For questions about this California Privacy Notice or to exercise your California consumer rights:

For comprehensive information about our data processing practices, please see our main Privacy Policy.

For more contact options and additional ways to reach us, please visit our Contact page.