Effective Date: 10/15/2025 

Your privacy is important to us at Tokenova, Inc. (“Tokenova,” “we,” “our,” or “us”). We respect your privacy and are committed to protecting personal information that we collect through our website, applications, and services.

1. What this Privacy Policy Covers

This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of information when you interact with Tokenova.com (the “Site”) and related services, including:

• Access to Tokenova’s digital infrastructure for the tokenization of private market securities;
• Investor onboarding tools, data rooms, or due diligence platforms; and
• Communications, newsletters, or events we may host.

This Privacy Policy does not apply to third-party broker-dealers, funding portals, or other regulated partners that conduct securities offerings through our infrastructure. Those entities have their own privacy policies and regulatory obligations.

By using our Site or Services, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

We collect information to operate efficiently and in compliance with applicable regulations.

Personal Information (PII):
When you create an account, request information, or engage in an offering via our platform, we may collect information such as:

• Name, email, phone number, company name, job title, and business address;
• Investor qualification details (e.g., accredited investor verification, if applicable);
• Billing or payment information for subscription or transaction services; and
• Communications preferences.

Non-Personal Information:
We may also collect anonymized or aggregated data (e.g., browser type, device, pages visited, IP address, and usage statistics) to improve our Services.

All data is stored and processed in accordance with applicable data-protection laws, including GDPR, CCPA, and other international frameworks.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and improve Tokenova’s digital infrastructure;
• Enable connectivity with regulated partners (e.g., broker-dealers, ATSs);
• Communicate important updates, product information, and investor education;
• Comply with SEC, FINRA, and international regulatory obligations; and
• Detect, prevent, and address fraud or security issues.

We do not sell personal data to third parties.

4. Cookies and Tracking

We use cookies and similar technologies to enhance your experience, analyze web traffic, and personalize content. You can manage cookie preferences through your browser or via our [Cookie Settings]. Refusing cookies may limit certain Site functionality.

5. Sharing of Information

We may share limited data with:

• Regulated partners (e.g., FINRA-member broker-dealers or ATS platforms) to facilitate compliant securities offerings;
• Service providers that assist us with hosting, analytics, or communications; and
• Government or regulatory authorities as required by law.

We require all third parties to handle personal data in accordance with strict confidentiality and security obligations.

6. Data Storage and International Transfers

Tokenova’s infrastructure and data processors may store or process information in the United States or other jurisdictions where we operate or have trusted partners.
Where required, cross-border data transfers comply with GDPR Standard Contractual Clauses or equivalent safeguards.

7. Security

We implement industry-standard administrative, technical, and physical safeguards to protect your data, including encryption in transit and at rest. However, no system is completely secure, and we cannot guarantee absolute security.

8. Access, Correction, and Deletion

You may review, update, or request deletion of your personal information by contacting [email protected].
We will process such requests in accordance with applicable laws and our regulatory obligations (e.g., record-keeping requirements under SEC and FINRA rules).

9. Children’s Privacy

Our Services are intended for individuals 18 years or older and are not directed to children. We do not knowingly collect personal information from minors. If we become aware that a child’s information has been collected, we will promptly delete it.

10. Links to Third-Party Sites

Our Site may contain links to third-party websites (including those of our global partners or broker-dealer affiliates). We are not responsible for their content, security, or privacy practices. We encourage you to review their privacy policies separately.

11. Global Compliance and Partnerships

Tokenova collaborates with global partners in the financial, technological, and regulatory sectors. We adhere to applicable international privacy and data-protection laws, including the EU GDPR, UK Data Protection Act, California Consumer Privacy Act (CCPA), and similar frameworks in allied jurisdictions.

12. Business Transfers

In the event of a merger, acquisition, or asset sale, personal information may be transferred as part of that transaction, consistent with applicable legal and regulatory requirements.

13. Changes to This Policy

We may update this Privacy Policy periodically. When changes are made, we will revise the “Effective Date” above and post the updated version on our Site. Significant changes will be communicated through appropriate means.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:
Email: [email protected]
Mail: Tokenova, Inc., 6555 Sanger Road, Suite 100, Orlando, FL 32827, USA

Summary for Visitors

• Tokenova, Inc. is an SEC-registered Exempt Reporting Adviser (ERA).
• We provide digital infrastructure for tokenization and comply with U.S. and global privacy standards.
• We do not sell personal data and use it only to deliver and improve regulated financial infrastructure.