SYNDIFUL PRIVACY POLICY
Effective Date: June 12, 2025

Syndiful, LLC (“Syndiful,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you use the Syndiful platform (the “Platform”).

1. Definitions

• User: Any person or entity accessing or using the Platform.
• Platform: Syndiful’s website, SaaS services, and related tools.
• Personal Information: Any information that identifies or can reasonably identify a person.
• Sponsor: A user submitting offerings.
• LP: Accredited investors using the Platform.

2. Scope

This Policy applies to personal data collected via www.syndiful.com, the Syndiful SaaS platform, and related services. It covers sponsors, LPs, and authorized users. It excludes data Sponsors collect independently from investors outside the Platform.

3. Information We Collect

Information You Provide: Sponsor account details, deal materials, uploaded contracts, investor onboarding data, accreditation/KYC/AML documents, payment info.
Automatically Collected: IP address, device/browser info, logs, cookies, session data.
Third-Party Data: From integrated vendors (e.g., identity, KYC/AML, payment processors).
Syndiful does not knowingly collect data from minors under 18.

4. How We Use Information

We process data to:

• Operate and improve the Platform
• Facilitate sponsor submissions and LP onboarding
• Verify identity and accreditation
• Comply with legal and regulatory obligations
• Prevent fraud or misuse
• Analyze usage for better user experience
• Send updates or promotional materials (where permitted or with consent)

Syndiful acts as either a data processor on behalf of Sponsors or as a controller for data collected independently.

5. Data Sharing

We may share data with:

• Integrated service providers (KYC/AML, accreditation, fund admins, payment processors)
• Vendors under confidentiality agreements
• Regulators or legal authorities as required by law
• In corporate transactions (merger, acquisition, asset sale)
  Syndiful does not sell or rent personal data.

6. Sponsor Responsibilities

Sponsors are solely responsible for the legal compliance, accuracy, and authorization of any investor personal data they collect or upload to the Platform. Sponsors must obtain proper consent or other legal basis for sharing personal data with Syndiful.

7. Data Security

We implement administrative, technical, and physical safeguards, including:

• Encryption at rest and in transit
• Secure cloud infrastructure
• Role-based access controls
• Employee security training
• Activity logging and monitoring
• Penetration testing
• Redundant backup and disaster recovery systems
  However, no system is 100% secure. You acknowledge inherent internet-based risks.

8. Data Retention

We retain personal data as long as necessary for stated purposes, legal/regulatory obligations, audits, or dispute resolution. Data may be anonymized or aggregated after primary use ends.

9. International Data Transfers

Data may be processed in the U.S. or other jurisdictions where Syndiful or its service providers operate. Transfers comply with applicable legal mechanisms, including Standard Contractual Clauses or equivalent protections.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete your personal information
• Restrict or object to processing
• Withdraw consent (if processing is based on consent)
• Lodge complaints with regulators

To exercise rights, contact legal@syndiful.com. We will respond within 30 days or as required by law.

11. Changes to this Privacy Policy

We may update this Policy. Material changes will be posted on the Platform with additional notice where required.

12. Contact Information

Syndiful, LLC
Email: legal@syndiful.com

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