OTC Meme Corp. Privacy Policy

🛡️ Privacy Policy

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✅ SEC CATEGORY 1 COMPLIANT | Issuer-Sponsored Tokenized Securities pursuant to SEC Division of Corporation Finance, Division of Investment Management, and Division of Trading and Markets Joint Statement dated January 28, 2026

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🛡️ Our Commitment to Your Privacy

At OTCOTCM MemeProtocol, Corp.Inc., we are serious about protecting your privacy.privacy while maintaining compliance with federal securities laws and Category 1 regulatory requirements. You don't have to take our word for it though - though—you can read below to understand how we treat your Personal Data.Data.

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✅ Your Agreement

When you use our Services, we require that you:

• Requirement	Description
  📋 Acknowledge	Acknowledge and agree to our Privacy Policy
  🤝 Understand	Understand and consent to our Privacy Policy
  ✅ Accept	Accept that we will collect, use, and share information as outlined below
  ⚖️ Regulatory Consent	Consent to data collection required for Category 1 compliance, KYC/AML, and accredited investor verification

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  📜 Related Documents

  Remember that your use of our Website and Services are subject to:

  • 📋 Our Terms of Use
  • 📋 Our Terms of Service (which incorporates this Privacy Policy)
  • 📋 Our Risk Disclosure
  • 📋 Our Cookie Notice

  Note: Capitalized terms in this Policy have the definitions given to them in the Terms of Use and Terms of Service, unless first defined in this Policy.

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  🎯 Why We Have A Privacy Policy (And What It Covers)

  💡 Purpose

  Our Privacy Policy helps you understand:

  • Topic	Description
    🔍 Collection & Use	Our collection and use of information
    ⚖️ Your Rights	Your rights regarding your data
    🏛️ Regulatory Requirements	How Category 1 compliance affects data handling

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    🛡️ Coverage

    Our Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services.

    ⚖️ Special Notice: Category 1 Compliance Data

    OTCM Protocol operates SEC Category 1 compliant infrastructure for tokenized securities. This requires collection and retention of certain data for regulatory compliance purposes, including:

    Data Category 📖	Regulatory DEFINITION:Purpose
    🪪 "Personal Data" Any information relating to an identified or identifiable individual, protected similarly as Personal KYC Data	Know orYour personallyCustomer identifiableverification informationrequired underby applicableBank Secrecy Act
    💰 Accreditation Data	Accredited investor verification required by SEC Rule 506(c)
    🚫 OFAC Screening Data	Sanctions compliance required by U.S. Treasury
    📊 Transaction Records	Securities transaction records required by federal securities laws
    🏦 Custody Records	Records coordination with SEC-registered transfer agent

    ⚠️ Important: Certain data protectioncollection laws.is

    mandatory for Category 1 compliance. You cannot use ST22 Tokenized Securities services without providing required KYC and accreditation verification data.

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    🏢 Third Party Data

    If your Personal Data is lawfully given to any company that we don't own or control,control, or to people we don't directly oversee,oversee, then their privacy policy applies,applies, not this Privacy Policy.

    🏦 Key Third-Party Data Sharing (Category 1 Requirements)

    Third Party	Data Shared	Purpose
    🏦 Empire Stock Transfer	Identity, ownership records	SEC-registered transfer agent for custody and shareholder registry
    🔐 KYC/AML Providers	Identity verification data	Regulatory compliance verification
    📊 Accreditation Verification	Financial qualification data	SEC Rule 506(c) compliance
    🚫 OFAC Screening Services	Identity data	Sanctions compliance
    🏛️ Regulatory Bodies	As required by law	SEC, FinCEN, and other regulatory reporting

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    📋 Key Areas We'll Cover

    • Section	Topic
      📥	How we obtain your Personal Data
      📊	The types of Personal Data we collect
      🔧	How we use your Personal Data
      🤝	Sharing your Personal Data
      ⚖️	Your rights with respect to your Personal Data
      🏛️	Category 1 regulatory data requirements

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      🚨 Questions or Concerns?

      If any part of this Privacy Policy is unclear or if you believe your Personal Data is being misused, please contact us immediately so we can investigate and remedy the situation.

      Contact: privacy@otcm.io

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      ⛓️ Blockchain Transparency Notice

      Please understand that our Services utilize Solana blockchain smart contract technology. Informationfor Category 1 compliant tokenized securities trading.

      📊 What Is Public on theBlockchain

      Data Type	Visibility	Notes
      🔗 Wallet Addresses	Public	Visible on Solana blockchain
      💰 is Transaction oftenHistory	Public	All ST22 and OTCM token transfers visible
      📊 Token Balances	Public	Holdings visible at wallet level
      🪪 Identity Data	Private	NOT stored on blockchain
      📋 KYC/Accreditation	Private	Stored off-chain with compliance providers

      ⚠️ Privacy Limitation: Blockchain transactions are permanent and public. While we do not private;publish however,your weidentity on-chain, sophisticated analysis may potentially link wallet addresses to identities. We take reasonable steps to anonymizeprotect thisyour publicprivacy, informationbut soblockchain ittransparency cannotis be personally tiedinherent to youthe or your Personal Data.technology.

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      📥 Here Is How We Gather Personal Data

      🎯 Primary Collection Method

      Methods

      For our Services, the main way we obtain your Personal Data isthrough directlymultiple fromchannels:

      you!

      1. 👤 Directly From You

      As a user, you will:

      • Action	Data Collected
        ✅ Be Account requiredCreation	Name, toemail, providecontact Personalinformation
        🪪 Data KYC directlyVerification	Government toID, us address verification, date of birth
        💰 Accreditation Verification	Financial documentation (for ST22 securities)
        💳 Payment Information	Payment details for minting fees
        📊 May Service provideUsage	Additional additional Personal Datadata as you use our Services (as necessary to provide Services and comply with laws)

        🤝2. 🏦 From Third PartyParties Sources(Category 1 Requirements)

        From time to time, Third Parties (companies we don't own/control or people we don't directly oversee) may provide us with Personal Party	Data about you.Received	Examples:Purpose 📊 Analytics service providers to help us understand how you use our Services
        🏦 Third parties like  Empire Stock Transfer	Custody confirmations, shareholder records	Category 1 custody verification
        🔐 KYC Providers	Verification results	Identity confirmation
        📊 Accreditation Services	Verification status	SEC Rule 506(c) compliance
        🚫 OFAC Screening	Sanctions check results	Compliance verification
        📈 Analytics Providers	Usage patterns	Service improvement

        3. ⛓️ From Blockchain

        Data Type	Collection Method
        🔗 Wallet Addresses	When you connect wallet to helpplatform
        💰 provide Transaction ancillaryHistory	Public servicesblockchain data
        📊 Token Holdings	Public blockchain data

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        🍪 We Automatically Collect Certain Information

        📋 Cookie Disclosure

        When you use our Services, you will be shown a cookie disclosure with details on:

        Information	Description
        🍪 Cookie 🍪 Types	What cookies/pixels/tags we use
        🎯 Purposes	Purposes for each type
        ⚙️ Management	How to control cookie preferences

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        🔧 Tracking Technologies

        Our Site may use Cookies or similar methods:

        Technology	Purpose
        🍪 // Tracking Technologies Used: 🍪Session Cookies	Maintain login state
        📊 Pixel Analytics tagsCookies	Understand 🔍usage Webpatterns
        🔐 beacons Security ✨Cookies	Fraud Clearprevention
        🎯 GIFs Preference 💻Cookies	Remember JavaScriptyour settings

        🎯 Purpose of Cookies

        These Cookies help us:

        • 🔍 Recognize you (your web browser, phone, etc.)
        • 📊 Understand how and when you visit the Site
        • 📈 Analyze trends to learn and improve our Services
        • 🔄🔐 SupplementMaintain withsecurity otherand third-partyprevent informationfraud
        • ⚖️ Support Category 1 compliance monitoring

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        🚫 "Do Not Track" Limitations

        Browser Setting	Our Response
        🚫 DNT Signal	We honor DNT signals where technically feasible
        ⚠️ IMPORTANT: Limitations	Some Wetracking arerequired currentlyfor unableCategory to1 honorcompliance "Do Not Track" requests. If you ask us not to track, we may notcannot be abledisabled

        to

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        fulfill the Services for you.

        ⚙️ Cookie Management

        • Option	Description
          🔧 You Browser can accept/Settings	Accept/reject Cookies through browser settings
          🗑️ You Delete can deleteCookies	Delete existing Cookies on your device
          ⚠️ Functionality Impact	Some functions may not work if you disable Cookies
          🔄 Your Preference preferencesReset	Preferences may need readjustment when you visit

          📚 Learn MoreMore: About Cookies

          Interested in learning more? Check outVisit AllAboutCookies.org tofor findcomprehensive –cookie well – All About Cookies!information.

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          📊 This isIs theThe kindKind of Personal Data We Collect

          👤 Information thatThat Identifies You Personally

          Standard Personal Data

          • Data Type	Purpose
            📛 Your Full fullName	Account name identification, regulatory compliance
            📬 Addresses	Mail, billingbilling, and email addresses
            🌐 Online identifiersIdentifiers	Usernames, orwallet usernames addresses
            🌍 Internet IP ProtocolAddress	Security, geolocation compliance
            📱 Phone Number	Account security, communications

            Category 1 Compliance Data (IP)Required address

          • for ST22 Securities)

            Data Type	Purpose	Regulatory Basis
            🪪 Government ID	KYC verification	Bank Secrecy Act
            📅 Date of Birth	Identity verification, age compliance	BSA, securities laws
            🏠 Residential Address	Identity verification, jurisdiction compliance	SEC regulations
            💰 Financial Information	Accredited investor verification	SEC Rule 506(c)
            📊 Tax identificationIdentification	Tax numbersreporting, (usedregulatory onlycompliance	IRS torequirements
            🏢 identify Employment youInformation	Accreditation verification	SEC Rule 501
            💎 Net Worth Documentation	Accreditation verification	SEC Rule 501

            ⚠️ Mandatory Collection: Category 1 compliance requires collection of KYC and ensureaccreditation properdata. taxationThis ofdata earnedcollection compensation)

          is

          not optional for ST22 Tokenized Securities services.

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          📋 Customer and User Records

          Information that may include customer and user records identified by applicable law:

          Record Type	Contents
          📝 Personal Account Records:Records	Registration •data, Fullpreferences
          💰 name Transaction •Records	ST22 Signatureand •OTCM Taxationtoken numbertransactions
          🏦 • Custody BankRecords	Empire accountStock detailsTransfer • Digital wallet information • Credit card numbers ⚠coordination
          ⚖️ Note: Compliance TheseRecords	KYC/AML mayverification, beaccreditation controlledstatus
          📧 by Communication localRecords	Support lawsrequests, incorrespondence

          your

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          jurisdiction

          🌐 Internet Activity Information

          • Data Type	Purpose
            🔍 Internet Browsing browsingHistory	Site andusage searchanalysis history (on our platform only)
            💻 Information Interaction onData	How youryou interactionuse withour websitesServices
            📊 or Trading applicationsActivity	Transaction patterns for compliance monitoring
            🔐 Security Events	Login attempts, security alerts

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            🎯 Collection Philosophy

            We try to collect information that we believe is necessary to:

            • Purpose	Description
              🖥️ Functionality	Make the Site render and work well for you
              ⚡ User Experience	Make your use of Services faster, easier, and more intuitive
              🚀 Improvement	Improve and expand our Services
              ⚖️ Compliance	Meet Category 1 regulatory requirements
              🛡️ Security	Protect against fraud and unauthorized access

              ⚠️ Without much of this information:

              • ❌ The Services simply will not be possible
              • 💸possible, Improvingand theCategory Services1 willcompliance cannot be difficult or more costly

              maintained.

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              🔧 How We Use Your Personal Data

              Nearly all Personal Data we collect is used to manage, improve, understand andunderstand, personalize our ServicesServices, and maintain Category 1 compliance.

              🎯 We Use Personal Data To:

              Service Delivery

              Service Delivery:Use	Description
              ✅ Purpose Fulfillment	Accomplish a purpose when you provide Personal Data for a particular purpose
              🛠️ Service Provision	Provide our Services to you and respond to your requests
              💰 Communication:Transaction Processing	Process ST22 and OTCM token transactions
              🏦 Custody Coordination	Coordinate with Empire Stock Transfer

              Category 1 Compliance (Required)

              Use	Regulatory Basis
              🪪 KYC Verification	Bank Secrecy Act, AML requirements
              💰 Accreditation Verification	SEC Rule 506(c)
              🚫 OFAC Screening	U.S. Treasury sanctions requirements
              📊 Transaction Monitoring	Securities law compliance
              🏛️ Regulatory Reporting	SEC, FinCEN reporting obligations
              📋 Record Keeping	Securities transaction record requirements

              Communication

              Use	Description
              📧 Service Communications	Communicate with you about Services based on your preferences
              ✅ Confirmations	Send confirmationtransaction emails and promotional offers confirmations
              📨 Updates	Email you about your use of the Services
              🚨 Security Alerts	Notify you of security-related events

              Support & Personalization:Personalization

              Use	Description
              🤝 Support	Offer and provide support for the Services
              🎨 Personalization	Personalize the content on our Site
              📋 Requests	Fulfill requests and respond to questions

              Improvement & Development:Development

              Use	Description
              🔬 Better test,Research	Test, research, analyze and develop the Service
              🚀 New Features	Offer new Services and make the Site better

              Security & Compliance:Compliance

              Use	Description
              🛡️ Fraud Prevention	Deter and stop illegal, fraudulent, and other damaging actions
              🔐 Security	Maintain safety, security and integrity of the Site and Services
              ⚖️ Policy Enforcement	Ensure compliance with obligations and enforce company policies
              🏛️ Legal Compliance	Interact with governmental and law enforcement requests as required by law

              Other

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              Functions:
              • 💼 Perform other business functions noted when we collected your Personal Data
              • 📜 Functions as set forth in applicable data privacy laws

              🔄 New Uses

              We may need to use your previously-collected Personal Data for new purposes consistent with our Services and their evolution. When this happens, we will inform you before we start (except where required by law or Category 1 compliance).

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              📧 Communication Preferences

              Don't want to receive marketing communications from us?

              • Method	Instructions
                📱 Email Opt-Out	Use the opt-out link provided in emails
                📧 Contact Us	Email your preference to: privacy@otcm.io

                info@otc.meme

              ⚠️ REQUIREDNote: COMMUNICATIONS:
              Some communicationsYou cannot be optedopt out of whiletransactional youor usecompliance-related ourcommunications Services:
              • Corporate action noticesrequired for yourCategory meme1 token investments
              • Tax reporting for compensation from token sales

              operations.

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              🤝 How We Share Your Personal Data

              💰 Not for Monetary Gain

              We are NOT in the business of sharing your Personal Data for monetary gain.

              We do need to perform and improve our Services,Services and maintain Category 1 compliance, which requires sharing your Personal Data with:

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              🏛️ Regulatory and Compliance Sharing (Required)

              Recipient	Data Shared	Purpose
              🏦 Empire Stock Transfer	Identity, ownership records	SEC-registered transfer agent custody
              🏛️ SEC	As required by law	Securities law compliance
              💵 FinCEN	SAR/CTR filings as required	Bank Secrecy Act compliance
              🚫 OFAC	Screening data	Sanctions compliance
              👮 Law Enforcement	As required by law	Legal obligations

              ⚠️ Mandatory Sharing: Category 1 compliance requires sharing certain data with regulatory bodies and Empire Stock Transfer. This sharing is not optional.

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              🏢 Service Providers

              • Provider Type	Purpose
                💳 Payment processorsProcessors	Process payments for minting fees
                🛡️ Security providersProviders	Maintain platform security
                💻 Technology/Hosting	Infrastructure services
                📊 Analytics providersProviders	Usage analysis
                🔐 KYC/AML Providers	Identity verification
                💰 Accreditation Verification	SEC Rule 506(c) compliance

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                🔍 Compliance & Security

                • Recipient	Purpose
                  📋 Auditors and others that help us maintain	Maintain compliance and security
                  🚨 Those Security detectingServices	Detect security issues and fraud
                  🛡️ Those Fraud protectingPrevention	Protect against illegal or improper activity

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                  🔬 Research & Development

                  • Recipient	Purpose
                    🧪 Those Internal undertaking internal researchResearch for technological	Technological development
                    🐛 Those Debug that debugServices and help repair	Repair errors on the Site or Services 👥

                    Those that need Personal Data short-term to build consumer profiles (with additional consent when required)

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                  📞 Customer Service

                  • Recipient	Purpose
                    🤝 Customer careCare	Customer providers support services
                    📦 Order processing orProcessing	Transaction fulfillment

                    services
                  • 📢 Advertising and marketing services

                  🏛️ Legal Requirements

                  • 🏛️ Government, law enforcement, or administrative bodies that require information as mandated by law or regulations

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                  🌐 Public & Transaction Information

                  Others may access your Personal Data if you:

                  • Action	Consequence
                    📢 Post informationPublicly	Information publicly becomes public
                    💰 Complete transactionsTransactions	Transaction initiateddata orrecorded authorizedon byblockchain you (public)
                    🤝 Access third-partyThird business partnersParties through our Services	When this happens: Their privacy policies control

                    ⚠️ Blockchain Transparency: ST22 and OTCM token transactions are recorded on the useSolana ofblockchain thatand information,are publicly visible. While your identity is not ours.directly published, wallet addresses and transaction history are public.

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                    🏢 Corporate Changes

                    While we hope this never happens, yourYour Personal Data may be acquiredtransferred through:

                    • Event	Handling
                      🤝 Corporate Merger/Acquisition	Data acquisitiontransfers (merger) to acquiring entity
                      💔 Bankruptcy	Data may be transferred as asset
                      💰 Asset Sale	Data may be included in sale

                      We will notify you of any such transfer and your options.

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                      🛡️ Data Security and Retention

                      🔐 Security Measures

                      We employ a number of safeguards designed to protect Personal Data:

                      • Safeguard Type	Examples
                        🔧 Technical	Encryption, safeguards access controls, monitoring
                        🏢 Organizational	Employee safeguards training, access policies
                        🏗️ Physical	Secure safeguardsfacilities, device security

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                        ⚠️ Security Disclaimer

                        🚨 IMPORTANTNO LIMITATION:SYSTEM SecurityIS risk100% isSECURE
                        
                        inherentDespite inour allsecurity internetmeasures, we cannot guarantee absolute security.
                        You are responsible for:
                        • Maintaining security of your wallet and informationprivate technologies.keys
                        WE• CANNOTUsing GUARANTEEstrong, THEunique SECURITYpasswords
                        OF• YOURProtecting PERSONALyour INFORMATION.devices from unauthorized access
                        • Reporting any suspected security breaches immediately

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                        📅 Data Retention

                        Category 1 Compliance Retention Requirements

                        Data Type	Retention Period	Regulatory Basis
                        🪪 KYC Records	5 years after account closure	Bank Secrecy Act
                        💰 Transaction Records	7 years	Securities laws, IRS requirements
                        📊 Accreditation Records	5 years	SEC Rule 506(c)
                        🚫 OFAC Screening	5 years	Treasury requirements
                        📧 Communications	3 years	Business records

                        ⚠️ Regulatory Retention: We are required by law to retain certain records for specified periods. Deletion requests cannot override regulatory retention requirements.

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                        🌍 Personal Data Use/Storage

                        🗺️ Global Processing

                        Your Personal Data may be used, hostedhosted, or otherwise processed outside of your home jurisdiction in jurisdiction(s) that may not provide equivalent levels of protection, including the United States.

                        Processing Location	Safeguards
                        🇺🇸 United States.	Primary processing location
                        🌍 ✅ Other REQUIREDJurisdictions	Standard CONSENT:contractual Youclauses mustwhere consent to this use and storage in order to use our Services.applicable

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                        👶 Personal Data of Children

                        🚫 Age Restrictions

                        • Requirement	Description
                          ❌ No Minors	We do not offer our Services to children
                          🚫 No Collection	We do not knowingly collect or solicit Personal Data from childrenanyone under 18
                          ⚠⚖️ IF Accredited YOUInvestors	ST22 AREsecurities UNDERrequire 18accredited YEARSinvestor OFstatus AGE:(adults Pleaseonly)

                          do NOT attempt to register for or use the Services or send us any Personal Data

                          🗑️ Data Deletion Policy

                          If we discover Personal Data from a child under 18:

                          • Action	Timeline
                            🚨 Deletion	We will delete it as quickly as possible
                            📧 Contact	If you believe a child under 18 has given us Personal Data, contact us at info@otc.memeprivacy@otcm.io

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                            ⚖️ Privacy Rights In Certain Jurisdictions

                            🏛️ Consumer Data Protection Laws

                            Certain jurisdictions have enacted laws to protect and empower consumers with respect to their data and Personal Data.

                            📍🇺🇸 Location-BasedCalifornia RightsResidents (CCPA/CPRA)

                            California residents have specific rights:

                            Right	Description
                            🔍 Right to Know	Request disclosure of Personal Data collected
                            🗑️ Right to Delete	Request deletion of Personal Data (subject to exceptions)
                            🚫 Right to Opt-Out	Opt-out of sale/sharing of Personal Data
                            ✏️ Right to Correct	Request correction of inaccurate Personal Data
                            ⚖️ Non-Discrimination	Not be discriminated against for exercising rights

                            ⚠️ Limitations: Category 1 regulatory retention requirements may limit deletion rights.

                            🌍 Other Jurisdictions

                            You may have additional rights regarding Personal Data we collect and use based on your residency.

                            📚Contact Evolvingprivacy@otcm.io Legalfor Landscape

                            jurisdiction-specific

                            This area of law is evolving. To learn what laws your state has enacted (or is considering), check resources like the United Nations Conference on Trade and Development.information.

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                            🔄 Changes to this Privacy Policy

                            📝 Updates May Occur

                            From time to time, we may need to change how we use your Personal Data due to:

                            • Reason	Description
                              ⚖️ Legal Changes	Applicable laws  and regulations
                              🏛️ Regulatory Updates	Category 1 compliance requirements
                              🚀 Service Evolution	Better performance of our Services

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                              📢 Notification Process

                              If changes happen, we will:

                              • Action	Method
                                🔄 Update Policy	Update this Privacy Policy
                                🚨 Alert you and other visitorsYou by: 🌐 Placing a	Place notice on the Site 📧 Sendingand/or ansend email 📱
                                📅 Another Effective expedientDate	Clearly methodindicate when changes take effect

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                                ✅ Continued Use = Agreement

                                ⚠️ IMPORTANT:
                                If you visit the Site or use our Services after changes have been posted,
                                you agree to the changes.

                                📅 Effective Date

                                We use Personal Data according to the Privacy Policy effective at the time that information is collected.collected. Continued use after policy updates constitutes acceptance.

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                                📞 Contact Information

                                🤝 Questions or Comments?

                                If you have any questions or comments about:

                                • Topic	Contact
                                  🔒 Your Personal Data	privacy@otcm.io
                                  🛡️ Your privacy Privacy	privacy@otcm.io
                                  📋 Our Privacy Policy	privacy@otcm.io
                                  ⚖️ Your rightsRights	privacy@otcm.io
                                  🏛️ Category 1 Compliance	compliance@otcm.io

                                  PleaseMailing contactAddress:

                                  us

                                  OTCM at:Protocol, Inc.
                                  Attn: Privacy Officer
                                  [Address]
                                  Wyoming, United States

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                                  📋 Document Information

                                  Field	Value
                                  📄 Document Version	3.0
                                  info@otc.meme📅 Effective Date	January 2026
                                  📍 Jurisdiction	Wyoming, United States
                                  ⚖️ Governing Law	Wyoming State Law and Federal Law
                                  🏛️ Regulatory Framework	SEC Category 1 (Issuer-Sponsored Tokenized Securities)

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                                  🛡️ Your Privacy Matters -— We're committed to protecting your personal information while maintaining Category 1 compliance and providing you with the best possible service experience.

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                                  © 2026 OTCM Protocol, Inc. | All Rights Reserved

                                  ST22 Tokenized Securities are securities under federal securities laws. Category 1 compliance requires collection and retention of certain personal data as described in this Privacy Policy.