Service Terms: Privacy Policy

The Tie Inc. and its affiliates (together "Company," "we," "us," or "our") respect your privacy and are committed to protecting it through our compliance with this policy.

This Policy describes the types of information we may collect from you or that you may provide when you visit our website, https://www.thetie.io, subscribe to any of our newsletters, any digital subscription, and any other of the Company's products or services including other web, mobile applications, or subdomains (collectively, our "Site") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Site;
• In email, text, and other electronic messages between you and this Site;
• Through mobile and desktop applications you download from this Site, which provide dedicated non-browser-based interaction between you and this Site; and
• When you interact with advertising and applications on third-party websites and services, if any, if those applications or advertising include links to this Policy.

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or through the Site.

At all times, your use of the Site is subject to the Terms of Use, which incorporates this Privacy Policy.

We collect several types of information from and about users of our Site, including information:

• By which you may be personally identified, such as name, email address, or any other identifier by which you may be contacted online or offline ("personal information");
• Signature, online identifier, internet protocol address or similar identifiers;
• That is about you but individually does not identify you (for example, industry or demographic information); and/or
• About your internet connection, the equipment you use to access our Site, and usage details.

• Directly from you when you provide it to us;
• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and/or other tracking technologies; and/or
• From third parties, for example, our business partners.

The information we collect on or through our Site may include:

• Information that you provide by filling in forms on or off of our Site. and/or
• Records and copies of your correspondence (including email addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including geolocation, traffic data, location data, logs, and other communication data and the resources that you access and use on the Site; and
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Site according to your individual interests;
• Speed up your searches; and
• Recognize you when you return to our Site.

• Cookies (or browser cookies). A cookie is a small text file that is stored on a user's device (such as a computer, smartphone, or tablet) when they visit our Site. Cookies are commonly used to improve user experience and provide personalized features on the Site. The cookies will be stored on your device and allow your browser to remember information about your specific user profile. We do not use cookies to track information other than information specifically granted to us by the user. Disabling certain cookies may impact the functionality and user experience of our Site.
• Flash Cookies. Certain features of our Site may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

We use information that we collect about you or that you provide to us, including any personal information, for carefully-considered purposes and for the benefit or our customers as follows:

• To present our Site and its contents to you and to operate our services, products, and systems properly;
• As to the non-public portions of our Site, to authenticate user information and ensure only authorized users access our Site;
• To provide you with information, products, or services that you request from us;
• To fulfill any other purpose for which you provide it;
• To provide you with notices about your account/subscription, including expiration and renewal notices;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection purposes;
• To communicate with you, including notifying you about changes to our Site or any products or services we offer or provide though it;
• To allow you to participate in interactive features on our Site;
• To analyze use of our Site;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

You may also send us an email at finance@thetie.io or legal@thetie.io to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you are a California, Virginia, Colorado, Connecticut, Utah, Iowa, Indiana, Tennessee, Texas, Florida, Montana, Oregon, or Delaware resident, your State has passed legislation regarding your privacy rights. Of those thirteen, California, Colorado, Connecticut, and Virginia laws are currently effective.

To learn about your California privacy rights, see California Privacy Rights.

To learn more about your Colorado, Virginia, or Connecticut privacy rights and how to exercise them, please make a written request to legal@thetie.io. While we will make reasonable efforts to accommodate any request, we also reserve the right to place limitations on any request, subject to applicable laws.

The California Consumer Privacy Act (CCPA) provides California residents with additional rights as it relates to the protection of personal data.

"Personal information" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you.

If you think The Tie has misappropriated your personal information, California consumers have a right to:

• know about the personal information The Tie collects about you;
• correct inaccurate personal information;
• limit the use and disclosure of sensitive personal information;
• delete personal information collected by The Tie; and
• receive non-discriminatory treatment against you for exercising any of these rights.

Some examples of "personal information" as defined by the CCPA include:

• name, alias, postal address, IP address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers;
• commercial information including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies;
• internet or other electronic network activity information including, but not limited to, browsing history, search history and information regarding a consumer's interaction with a website, application, or advertisement; and
• geolocation data.

The Tie collects the following types of information which may constitute "sensitive personal information" as defined under the CCPA: log-in and password, email address, signature, online identifier (i.e., IP address), and certain information about your internet connection (i.e., device type). The Tie only uses such information to provide our services and products or as otherwise permitted by the CCPA. The Tie does not sell or share your personal information to third parties and/or other affiliates.

For more information on how we collect, use, and retain your information as well as updates, see INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT (above).

California customers can exercise their rights directly or through an authorized agent by contacting The Tie's Legal Department. Please include "California Privacy Rights" in the Subject line of your email, if sending an inquiry electronically.

For more information regarding The Tie's use of your data, send inquiries to The Tie's Legal Department:

Email: legal@thetie.io

Mailing Address: 41 W 25th Street, 5th Floor, New York NY 10010

The European Union's General Data Protection Regulation (GDPR) provides customers in the European Economic Area (EEA) with additional rights as it relates to protection of personal data.

References to "personal information" in this Policy are equivalent to "personal data" as defined under GDPR. "Personal information" or "personal data" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you.

Under the GDPR, a company may be a "data controller," "data processor" or both.

Data Controller

Under Article 4 of the GDPR, a company is a "data controller" when it determines the purposes and means of processing personal data. In The Tie's role as a "data controller," we ensure that European customers have the right to access the data gathered about them and subsequently request a correction, minimization or deletion of the data collected depending on the individual circumstances, with the acknowledgement that in doing so, your experience of the Site may be impacted.

When acting as data controller, The Tie commits to:

• take into account the nature, scope, context, and purposes of processing, and
• implement appropriate measures to ensure the ability to demonstrate processing is in accordance with GDPR.

Under Article 4 of the GDPR, a company is a "data processor" when it processes personal data on behalf of a "data controller." In The Tie's role as "data processor," we process your data safely and legally; and while the majority of The Tie's business operates as a "data controller," circumstances may arise where we process data.

Under Article 2 of the GDPR, The Tie retains the right to process personal data by competent authorities for the purposes of the prevention, investigation, detection, or prosecution of criminal offenses or the execution of criminal penalties.

In accordance with this Privacy Policy and the GDPR, personal data shall be:

• processed lawfully, fairly and in a transparent manner in relation to you;
• collected for specified, explicit and legitimate purposes;
• adequate, relevant and limited to what is necessary;
• accurate and, where necessary, kept up to date;
• kept in a form that permits identification of you for no longer than is necessary; and
• processed in a manner that ensures appropriate security of personal data.

The Tie only retains data so long as is necessary and for the purposes for which it was collected. The Tie will retain your data for the necessary retention period and abide by applicable retention period criteria. The Tie will not keep your personal information for longer than is necessary. Reasons for retaining your data may include, but are not limited to, increased user accessibility of the Site, to comply with legal inquiries, and to help law enforcement with ongoing investigations.

You shall have the right to:

• ask whether we have any personal data about you and request a copy of such personal data;
• request that we update or correct inaccuracies in your personal data;
• request that we restrict the processing of your personal data if such processing is appropriate; and
• object to our processing of your personal data if processing is inappropriate.

For more information about how we collect, use, and retain your information as well as updates, see INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT (above).

European customers can exercise their rights directly or through an authorized agent by contacting The Tie's Legal Department. Please include "European Privacy Rights" in the Subject line of your email.

For more information regarding The Tie's use of your data, send inquiries to The Tie's Legal Department:

Email: legal@thetie.io

Mailing Address: 41 W 25th Street, 5th Floor, New York, NY 10010

Any information that you provide to us is kept secure; however, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our Site's services, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: The Tie Inc., 41 West 25th Street, 5th Floor, New York, NY 10010 or by email to legal@thetie.io.

To register a complaint or concern, please email legal@thetie.io. Note that we may reject requests which risk the privacy of others or would require a disproportionate technical effort or which would otherwise be impractical.

Our Site is used by customers throughout the world. Some of these countries have different levels of privacy protection than those in the U.S. By using our Site and our products and services, you acknowledge that you agree to any transfer and processing of personal information, including to and in the United States. We implement appropriate safeguards to protect any information that is transferred. Additional information about the transfer of personal information in accordance with the GDPR to the US is available here: https://www.thetie.io/gdpr/.

Limitation of Liability

You acknowledge that we have no control as to the availability of third-party content and that, from time to time, individual sources may become inoperable for reasons outside of our control.

REGARDLESS OF THE TYPE OF CLAIM OR THE NATURE OF THE CAUSE OF ACTION, TO THE EXTENT ALLOWED BY LAW, YOU UNDERSTAND AND EXPRESSLY AGREE THAT IN NO EVENT WILL THE COMPANY OR ITS AFFILIATES, OFFICERS, EMPLOYEES, AGENTS, OR LICENSORS BE LIABLE FOR: (I) ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING, BUT NOT LIMITED TO, LOSS OF REVENUES, DATA OR PROFITS, OR OTHER INTANGIBLE LOSSES, EVEN IF THE COMPANY HAS BEEN ADVISED AS TO THE POSSIBILITY OF SUCH DAMAGES; OR (II) TOTAL CUMULATIVE LIABILITY ARISING UNDER OR RELATED TO THE SITE, WHETHER IN CONTRACT, TORT, OR OTHERWISE. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. IN THOSE JURISDICTIONS, THE COMPANY'S LIABILITY SHALL BE LIMITED TO THE GREATEST EXTENT PERMITTED BY LAW. YOU UNDERSTAND AND AGREE THAT YOUR USE OF OUR SITE IS PREDICATED UPON YOUR WAIVER OF ANY RIGHT TO SUE THE COMPANY, ITS OWNERS OR ITS AFFILIATES DIRECTLY, OR TO PARTICIPATE IN A CLASS ACTION SUIT FOR ANY LOSSES OR DAMAGES RESULTING FROM YOUR USE OF OUR SITE.

IN ALL CASES, NEITHER THE COMPANY NOR ITS AFFILIATES ASSUME ANY RESPONSIBILITY OR LIABILITY FOR ANY ERRORS OR OMISSIONS ON OUR SITE OR WITH RESPECT TO SITE MATERIALS, ANY FAILURES, DELAYS, OR INTERRUPTIONS IN OUR SITE'S ACCESSIBILITY, ANY LOSSES OR DAMAGES ARISING FROM THE USE OF OUR SITE OR SITE MATERIALS, ANY CONDUCT BY OTHER USERES OF OUR SITE, OR UNAUTHORIZED ACCESS TO OR USE OF OUR SITE OR SITE MATERIALS.

Our goal is to help you make more informed decisions; however, you are fully responsible for any decisions you make. We are not liable for any loss or damage caused by reliance on information contained on this Site or in any of our communications. Nothing on our Site should be considered to be investment advice. Price projections are in no way a guarantee of a future price. Price projections and ranges are based on statistical methods and data analytics. Historical price movements are no guarantee of future price returns. Price projections are for informational purposes only.

This Site cannot assist you with respect to any regulatory complaint. If you have a specific complaint about the trading of a cryptocurrency, or about an exchange, please register your complaint with an appropriate regulatory entity. For example, for more information, see www.sec.gov (U.S. Securities and Exchange Commission), www.finra.org (Financial Industry Regulatory Authority), or www.nasaa.org (North American Securities Administrators Association).

ARBITRATION NOTICE: YOU AGREE THAT ANY DISPUTES BETWEEN YOU AND US WILL BE RESOLVED BY BINDING, INDIVIDUAL ARBITRATION AND YOU WAIVE YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT OR CLASS-WISE ARBITRATION.

Please note that The Tie does business in the following states under the corresponding names:

• Michigan: d/b/a MI Tie
• Texas: d/b/a TX Tie Inc
• Massachusetts: d/b/a Tie Software Inc