COOKIE NOTICE V8

VERSION 8.0 | MARCH 2026

GROOVY COMPANY, INC. DBA OTCM PROTOCOL

Wyoming Corporation | CIK: 1499275 | OTC: GROO

12 Daniel Rd East, Fairfield, NJ 07004

SEC Category 1 Model B | Release No. 33-11412 (March 17, 2026)

The Groovy Company, Inc. dba OTCM Protocol website and platform (the “Site”), including otcm.io, cedex.otcm.io, otcm.network, and otcm.info, uses various cookies which allow us to distinguish you from other users. This helps us provide a good browsing experience, improve Site and platform functionality, personalize content and recommendations, analyze traffic patterns and usage, and support Category 1 Model B compliance operations including KYC/AML verification.

Your Rights and Consent

We use strictly necessary cookies to provide core content and functionality. With your permission, we also use cookies to personalize content, analyze traffic, share information with analytics partners, and support regulatory compliance operations.

Browsing Without Cookies

You do not need to allow cookies to visit most of the Site. However, enabling cookies is required for:

Feature	Requires Cookies
Wallet Connectivity	Maintaining Solana wallet connection status (Phantom, Solflare, Backpack, etc.)
CEDEX Trading	Full ST22 Digital Securities trading functionality on CEDEX
Account Features	Account management, preferences, and dashboard
Compliance Verification	KYC/AML/accreditation verification processes via Empire Stock Transfer
Real-Time Data	Market data, pricing, and oracle attestation displays

To manage your cookie preferences, use the “Cookie Settings” link in the footer of otcm.io. For questions, contact privacy@otcm.io.

2. What Are Cookies

Cookies are small data files containing a unique identifier placed on your computer or mobile device when you visit a website. They help us understand how our Site is being used, enable efficient navigation between pages, remember your preferences and settings, maintain your wallet connection status, improve your browsing experience, and support Category 1 Model B compliance verification.

3. Key Concepts

4. Changing Your Cookie and Advertising Choices

Access granular cookie controls via the “Cookie Settings” link in the footer of otcm.io. You can choose which cookie categories to enable or disable.

4.2 Browser Settings

Browser	Settings Location
Chrome	Settings → Privacy and Security → Cookies
Firefox	Settings → Privacy and Security → Cookies
Safari	Preferences → Privacy → Cookies
Edge	Settings → Cookies and Site Permissions
Brave	Settings → Shields → Cookies

Warning: Blocking all cookies may prevent access to wallet connectivity, CEDEX trading interfaces, account features, compliance verification (KYC/AML/accreditation), and real-time market data. Certain cookies are required for SEC Category 1 Model B compliance. Disabling these cookies may prevent you from accessing ST22 Digital Securities trading.

4.3 Advertising Choices

You may opt out of interest-based advertising through: DAA (U.S.) at optout.aboutads.info, EDAA (EU) at youronlinechoices.eu, or NAI at optout.networkadvertising.org. Use device settings to limit advertising ID usage. Apply opt-out settings on each device and browser. We cannot guarantee all partners participate in opt-out programs.

5.1 Strictly Necessary Cookies

Attribute	Description
Legal Basis	Legitimate interest in providing the service
Consent Required	No — these are essential for Site operation
Purpose	Core functionality, security, compliance, wallet connectivity, trading sessions
Can Disable	Disabling will break core features including ST22 Digital Securities trading

5.2 Performance, Functional, and Targeting Cookies

Attribute	Description
Legal Basis	Your consent (opt-in)
Consent Required	Yes
Purpose	Analytics, personalization, advertising, performance monitoring
Can Disable	Yes, through Cookie Settings without affecting core functionality

6. Withdrawing Consent

You may withdraw consent at any time through the “Cookie Settings” link in the website footer, by deleting or blocking cookies via browser settings (see Section 4), or by emailing privacy@otcm.io.

Important for ST22 Trading: If you disable strictly necessary cookies, you may be unable to complete KYC/AML verification or maintain accredited investor status verification required for ST22 Digital Securities trading under SEC Category 1 Model B requirements.

7.1 Strictly Necessary and Essential Cookies

Essential for Site operation. Legal basis: legitimate interest. Consent not required. Disabling will prevent core platform operation.

These cookies enable:

• Setting and maintaining your privacy preferences

• Authentication and account login

• Wallet connectivity (Phantom, Solflare, Backpack, Ledger)

• Transaction processing on CEDEX

• Platform security and fraud prevention

• KYC/AML verification via Empire Stock Transfer

• Accredited investor status verification (Reg D / Reg S)

• Managing secure trading sessions

• Supporting Category 1 Model B compliance operations

7.2 Performance and Analytics Cookies

Purpose: understanding Site usage and performance. Legal basis: your consent. Required: yes.

These cookies track which ST22 Digital Securities and pages are most visited, how users interact with CEDEX trading interfaces and the Global Unified CEDEX Liquidity Pool, trading patterns and volume metrics, platform performance and load times, and error messages and technical issues. If disabled, we cannot monitor Site performance or user experience.

7.3 Functional Cookies

Purpose: enhanced functionality and personalization. Legal basis: your consent. Required: yes.

These cookies enable remembering your trading preferences, storing your watchlist selections, maintaining dashboard customizations, remembering your preferred currency display, storing notification preferences, and enabling chat support features. If disabled, personalization features may not work properly.

7.4 Targeting and Advertising Cookies

Purpose: relevant advertising and recommendations. Legal basis: your consent. Required: yes.

These cookies help make our Site and advertising more relevant, show relevant ST22 Digital Securities opportunities, display targeted educational content, and provide personalized platform recommendations. These cookies do not store directly personal information but uniquely identify your browser and device. If disabled, you will experience less targeted advertising.

9. Other Technologies

Beyond cookies, our Site uses additional technologies:

Local Storage Technologies

Local storage and session storage are used to store larger amounts of data locally, improving performance and storing preferences.

Web Beacons (Pixel Tags)

Small transparent images embedded in pages and emails to track page views, email opens, and conversions.

Session-Replay Technologies

Anonymized recordings of user interactions to understand user experience and identify issues. Sensitive data is masked or excluded from recordings.

Chat Technologies

Live chat functionality for real-time customer support. Chat logs are retained per our Privacy Policy.

Blockchain Interaction Trackers

Technologies that track wallet connection status and monitor transaction status on the Solana blockchain, providing real-time trading feedback and supporting Transfer Hook verification. Blockchain transactions are recorded on the public Solana blockchain independently of our cookies. See our Privacy Policy for details on blockchain transparency.

10. Updates to This Cookie Notice

We may update this Cookie Notice when we change how we use cookies, our platform evolves, legal requirements change, or Category 1 Model B compliance requirements change. All changes will be reflected here with an updated “last updated” date.

For more information about how we process personal information collected from cookies, please refer to our Privacy Policy.

11. Contact Information

Contact	Information
Privacy / Cookie Inquiries	privacy@otcm.io
Cookie Settings	Cookie Settings link in website footer at otcm.io
Privacy Policy	Available at otcm.io/privacy
Mailing Address	12 Daniel Rd East, Fairfield, NJ 07004
Phone	1-404-734-3277

Document Information

Field	Value
Document Title	Cookie Notice
Version	8.0
Effective Date	March 2026
Legal Entity	Groovy Company, Inc. dba OTCM Protocol
Entity Jurisdiction	Wyoming Corporation
Regulatory Context	SEC Category 1 Model B — Release No. 33-11412 (March 17, 2026)

Certain cookies support SEC Category 1 Model B compliance operations including KYC/AML and accredited investor verification for ST22 Digital Securities trading. Groovy Company, Inc. dba OTCM Protocol is a Wyoming Corporation (CIK: 1499275).

Cookie Type	Description	Control
First-Party Cookies	Set directly by Groovy Company, Inc. dba OTCM Protocol for core platform functionality, user preferences, and compliance	Fully controlled by OTCM Protocol
Third-Party Cookies	Set by third-party services (analytics providers, compliance providers including Chainalysis and TRM Labs) for analytics, performance monitoring, and compliance verification	Subject to third-party privacy policies
Persistent Cookies	Remain on your device until expiration or deletion. Used to remember preferences across sessions.	Expiry varies by cookie type (see Section 8)
Session Cookies	Deleted when you close your browser. Essential for maintaining secure trading sessions on CEDEX.	Automatic deletion on browser close

Cookie Type	Retention Period
Session Cookies	Deleted when browser closes
Authentication Cookies	Up to 30 days (or until logout)
Preference Cookies	Up to 12 months
Analytics Cookies	Up to 24 months
Advertising Cookies	Up to 12 months
Compliance Cookies	As required by law (up to 5 years for KYC data per Bank Secrecy Act)