Privacy policy

Effective Date: March 19, 2026  |  Last Updated: March 19, 2026

Chairman Club ("Chairman Club," "we," "us," or "our") is committed to protecting the privacy and security of all personal information we collect, process, and maintain. This Privacy Policy ("Policy") governs how we collect, use, share, retain, and protect information obtained through our website located at ChairmanClub.com (the "Site"), our proprietary pre-IPO data hub platform, any related applications, tools, services, or communications (collectively, the "Services"). By accessing or using the Services in any manner, you ("User," "you," or "your") unconditionally agree to the terms of this Policy. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE ALL USE OF THE SERVICES.

This Policy applies to all visitors, registered members, prospective members, investors, partners, and any other individuals who interact with us in connection with the Services. We reserve the right to amend this Policy at any time at our sole discretion with or without prior notice. Continued use of the Services following any amendment constitutes your binding acceptance of the revised Policy.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

We collect information you voluntarily submit to us, including but not limited to:

• Full legal name, business name, and professional title

• Email address, telephone number, and mailing address

• Financial and investment information, including accreditation status, investment history, and net worth ranges

• Identification documents required for KYC/AML compliance

• Login credentials and account preferences

• Communications, inquiries, feedback, and any other content you submit to us

• Payment information processed through our third-party payment processors

1.2 Information Collected Automatically

When you access the Services, we and our authorized third-party partners automatically collect certain technical and usage data, including:

• IP address, device identifiers, browser type and version, and operating system

• Clickstream data, pages viewed, time spent, referral URLs, and navigation paths

• Cookie identifiers and similar tracking technologies

• Geolocation data derived from IP address or device settings

• Log files and error reports

1.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Data brokers, public databases, and commercially available sources

• Identity verification and KYC/AML service providers

• Financial institutions, broker-dealers, and investment platforms

• Business partners and referral sources

• Social media platforms and professional networks (where permitted by their terms)

• Regulatory bodies and government databases, as permitted by law

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes, which we deem necessary for the legitimate operation of our business:

• To verify your identity and determine eligibility for membership and access to the Services

• To provide, operate, maintain, improve, and personalize the Services

• To facilitate pre-IPO investment opportunities, data access, and related financial services

• To communicate with you regarding your account, transactions, updates, and promotional materials

• To comply with applicable laws, regulations, and legal obligations, including securities laws, KYC, and AML requirements

• To detect, investigate, and prevent fraud, unauthorized access, and other prohibited activities

• To enforce our Terms of Service, this Policy, and any other agreements

• To conduct analytics, research, and product development to improve our Services

• To protect the rights, property, and safety of Chairman Club, our members, partners, and the public

• For any other purpose disclosed at the time of collection or with your subsequent consent

We reserve the right to use de-identified, aggregated, or anonymized data for any lawful business purpose without restriction, including commercial purposes, without notice or compensation to you.

3. LEGAL BASES FOR PROCESSING (EEA/UK USERS)

To the extent applicable under the General Data Protection Regulation ("GDPR") or UK GDPR, we process your personal data under the following legal bases:

• Contractual necessity: Processing required to perform our agreement with you or to take steps at your request prior to entering a contract

• Legal obligation: Processing necessary to comply with applicable laws and regulations

• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, network security, and improving our Services, provided such interests are not overridden by your rights

• Consent: Where we have obtained your explicit consent, which you may withdraw at any time without affecting the lawfulness of prior processing

• Vital interests: In rare circumstances, to protect the vital interests of any person

4. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, pixel tags, local storage, and similar tracking technologies (collectively, "Cookies") to operate and improve the Services, personalize your experience, and serve targeted content.

4.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Services to function and cannot be disabled

• Performance and Analytics Cookies: Collect information about how you use our Services to help us improve functionality

• Functional Cookies: Remember your preferences and personalize your experience

• Targeting and Advertising Cookies: Track your activity across sites to deliver relevant advertising and measure campaign effectiveness

4.2 Cookie Management

You may adjust your browser settings to refuse or delete certain Cookies. However, disabling Cookies may impair or prevent access to certain features of the Services. We are not responsible for any loss of functionality resulting from your Cookie preferences. Our use of analytics and targeting services, including but not limited to Google Analytics and similar platforms, is governed by those providers' respective terms and privacy policies.

5. DISCLOSURE AND SHARING OF INFORMATION

We do not sell your personal information to third parties for their independent marketing purposes. However, we may share your information in the following circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party vendors and partners who perform services on our behalf, including hosting, payment processing, identity verification, analytics, legal and compliance services, and marketing. These parties are contractually obligated to use your information only as directed by us and in accordance with this Policy.

5.2 Investment and Financial Partners

To facilitate pre-IPO investment opportunities and related financial services, we may share information with co-investors, fund managers, broker-dealers, transfer agents, and other financial industry participants. You acknowledge and consent that such sharing is inherent to the nature of the Services.

5.3 Legal and Regulatory Disclosure

We reserve the right to disclose your information to governmental authorities, regulators, law enforcement, courts, or other third parties when we reasonably believe such disclosure is required or permitted by law, including in response to subpoenas, court orders, regulatory inquiries, or to protect our legal rights.

5.4 Business Transfers

In the event of a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction involving Chairman Club, your information may be transferred to the acquiring or successor entity without additional notice or consent, subject to applicable law.

5.5 Protection of Rights

We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service or this Policy, threats to the safety of any person, or as otherwise required to protect our rights and property.

5.6 Consent

We may share your information with additional third parties with your explicit consent.

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes described in this Policy, comply with our legal obligations (including securities and financial recordkeeping requirements, which may mandate retention for five (5) years or more), resolve disputes, enforce our agreements, and as otherwise required by applicable law or regulation.

Upon expiration of applicable retention periods, we will securely delete or anonymize your information. Notwithstanding the foregoing, we reserve the right to retain de-identified or aggregated data indefinitely.

7. DATA SECURITY

We implement and maintain commercially reasonable administrative, technical, and physical safeguards designed to protect your information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls, and regular security assessments.

HOWEVER, NO SECURITY MEASURE IS PERFECT OR IMPENETRABLE. WE CANNOT AND DO NOT GUARANTEE ABSOLUTE SECURITY OF YOUR INFORMATION. BY USING THE SERVICES, YOU ACKNOWLEDGE AND ACCEPT THIS RISK. IN THE EVENT OF A SECURITY BREACH, OUR LIABILITY TO YOU SHALL BE LIMITED TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

You are responsible for maintaining the confidentiality of your account credentials. You agree to immediately notify us of any unauthorized use of your account or any other breach of security.

8. YOUR RIGHTS AND CHOICES

8.1 Access and Correction

Subject to applicable law, you may request access to or correction of your personal information by contacting us at the information provided in Section 13 below. We will respond to verifiable requests within the timeframes required by applicable law. We reserve the right to deny requests that are repetitive, burdensome, or otherwise permissible to deny under applicable law.

8.2 Deletion

In certain jurisdictions, you may have the right to request deletion of your personal information. Such rights are subject to significant limitations, including our right and obligation to retain data for legal, regulatory, compliance, fraud prevention, and legitimate business purposes. We will inform you of applicable exceptions when responding to your request.

8.3 Opt-Out of Marketing

You may opt out of receiving marketing communications from us by following the unsubscribe instructions in such communications or by contacting us directly. Please note that even if you opt out, we may continue to send you transactional, legal, or administrative communications necessary in connection with your account or the Services.

8.4 California Residents

California residents may have additional rights under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, delete, correct, and opt out of the sale or sharing of personal information. To submit a request, contact us using the information in Section 13. We will not discriminate against you for exercising your rights. Financial services data and other data exempt under the CCPA/CPRA is not subject to these rights.

8.5 EEA/UK Residents

Individuals in the European Economic Area or United Kingdom may have rights under the GDPR or UK GDPR, including rights of access, rectification, erasure, restriction, portability, and objection. To exercise these rights, contact our Data Protection Officer at the address in Section 13. Note that these rights are not absolute and are subject to legal exceptions. We will respond within thirty (30) days, with the right to extend this period by an additional two (2) months where necessary.

9. INTERNATIONAL DATA TRANSFERS

Chairman Club is headquartered in the United States. By using the Services, you acknowledge and consent that your information may be transferred to, stored, and processed in the United States or any other country in which we or our service providers operate, which may have data protection laws different from or less protective than those in your home jurisdiction.

For transfers from the EEA or UK to countries not recognized as providing an adequate level of protection, we rely on appropriate safeguards including Standard Contractual Clauses approved by the European Commission or UK Information Commissioner's Office, or other lawful transfer mechanisms.

10. CHILDREN'S PRIVACY

The Services are not directed to, nor do we knowingly collect personal information from, children under the age of eighteen (18) or such higher age as may be required under applicable law. If you believe we have inadvertently collected information from a minor, please contact us immediately and we will take prompt steps to delete such information. Access to the Services and participation in any investment opportunity requires accredited investor status, which by definition excludes minors.

11. THIRD-PARTY LINKS AND SERVICES

The Services may contain links to third-party websites, platforms, or applications. This Policy does not apply to such third-party services. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party services. We strongly encourage you to review the privacy policy of any third-party service you visit. Your interactions with third-party services are governed solely by their respective terms and policies.

12. CHANGES TO THIS POLICY

We reserve the right to modify this Policy at any time and at our sole discretion. Changes will be effective immediately upon posting to the Site unless otherwise stated. We may, but are not obligated to, provide notice of material changes via email or a prominent notice on the Site. Your continued use of the Services following any change constitutes your binding acceptance of the revised Policy. We encourage you to review this Policy periodically.

The date at the top of this Policy indicates when it was last updated. Prior versions of this Policy may be available upon written request, subject to our reasonable discretion.

13. CONTACT AND DATA PROTECTION

For any questions, concerns, or requests regarding this Policy or our privacy practices, please contact us at:

Chairman Club

3250 NE 1st Ave, Unit 305

Miami, FL 33137

United States

Email: Chairman@chairmanclub.com

Phone: (833) 880-8127

Website: ChairmanClub.com

For EEA/UK residents, the above contact information also serves as the point of contact for our Data Protection Officer (DPO) for the purposes of the GDPR and UK GDPR.

14. LIMITATION OF LIABILITY AND DISCLAIMER

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, CHAIRMAN CLUB, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, LICENSORS, AND PARTNERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF OR RELATED TO THIS POLICY OR OUR HANDLING OF YOUR INFORMATION, INCLUDING LOST PROFITS, DATA LOSS, OR BUSINESS INTERRUPTION, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

ANY CLAIM ARISING UNDER THIS POLICY MUST BE BROUGHT WITHIN ONE (1) YEAR OF THE DATE THE CAUSE OF ACTION ACCRUES. CLAIMS BROUGHT AFTER THIS PERIOD ARE PERMANENTLY BARRED. THIS POLICY SHALL BE GOVERNED BY THE LAWS OF THE STATE OF FLORIDA, WITHOUT REGARD TO CONFLICT OF LAW PRINCIPLES. ANY DISPUTES SHALL BE RESOLVED EXCLUSIVELY IN THE STATE OR FEDERAL COURTS LOCATED IN MIAMI-DADE COUNTY, FLORIDA.

15. ENTIRE AGREEMENT

This Policy, together with our Terms of Service and any other agreements incorporated by reference, constitutes the entire agreement between you and Chairman Club with respect to the subject matter hereof and supersedes all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, with respect to such subject matter.

If any provision of this Policy is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. Our failure to enforce any right or provision of this Policy shall not constitute a waiver of such right or provision.