Privacy Policy

Last updated: March 19, 2026

1. Introduction

Crobo Inc. ("Crobo," "we," "us," or "our") operates the Crobo Earn platform and related services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile applications, and services (collectively, the "Services").

By using our Services, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the Services.

2. Information We Collect

Personal Information You Provide:

• Name, email address, phone number, and mailing address
• Date of birth and Social Security Number (for brokerage account opening and regulatory compliance)
• Government-issued identification documents
• Employment information and financial details (income, net worth, investment experience)
• Bank account information for funding and withdrawals
• Tax identification information

Information Collected Automatically:

• Device information (browser type, operating system, device identifiers)
• IP address and approximate location
• Usage data (pages visited, features used, session duration)
• Cookies and similar tracking technologies

Information from Third Parties:

• Identity verification services (for KYC/AML compliance)
• Our broker-dealer and clearing partners
• Google (if you sign in with Google OAuth)
• Credit reporting agencies (as required for account opening)

3. How We Use Your Information

We use the information we collect to:

• Open and maintain your brokerage account
• Process transactions and manage your investments
• Comply with legal and regulatory requirements, including Know Your Customer (KYC), Anti-Money Laundering (AML), and tax reporting obligations
• Communicate with you about your account, transactions, and service updates
• Improve, personalize, and develop our Services
• Detect, prevent, and address fraud, security issues, and technical problems
• Fulfill contractual obligations to our partners, including our investment adviser and broker-dealer

4. How We Share Your Information

We do not sell your personal information. We may share your information with:

• Beckett Collective — our registered investment adviser, to provide investment advisory services for your managed account
• Broker-Dealer and Custodian — FINRA-registered, SIPC-member broker-dealer(s) that hold your securities in individual FBO (For Benefit Of) accounts
• Service Providers — third-party companies that help us operate the Services (e.g., cloud hosting, identity verification, payment processing, analytics)
• Regulatory and Legal Authorities — government agencies, regulators, courts, or law enforcement when required by law, subpoena, or regulatory request
• Corporate Transactions — in connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction

5. Data Security

We implement industry-standard administrative, technical, and physical safeguards to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication and access controls
• Regular security assessments and monitoring
• Limited employee access to personal information on a need-to-know basis

While we strive to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you Services. We also retain information as necessary to comply with legal obligations (including broker-dealer recordkeeping requirements, which may require retention for a minimum of 6 years after account closure), resolve disputes, and enforce our agreements.

7. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to legal and regulatory retention requirements
• Portability: Request your data in a structured, commonly used format
• Opt-Out: Opt out of marketing communications at any time by clicking "unsubscribe" in any email or contacting us

To exercise any of these rights, please contact us at privacy@crobo.money.

Please note: Certain information is required to maintain your brokerage account and comply with financial regulations. Deleting such information may require closing your account.

8. California Residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete it, and the right to opt out of the "sale" of personal information. We do not sell personal information. To exercise your CCPA rights, contact us at privacy@crobo.money.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to improve functionality and user experience. These include:

• Essential cookies: Required for the Services to function (authentication, security)
• Analytics cookies: Help us understand how users interact with our Services
• Preference cookies: Remember your settings (e.g., theme preference)

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Services.

10. Third-Party Links

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies.

11. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will promptly delete it.

12. International Users

Our Services are operated in the United States. If you access the Services from outside the United States, your information may be transferred to and processed in the United States, where data protection laws may differ from those of your country.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. Your continued use of the Services after changes are posted constitutes your acceptance of the revised policy.

14. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us:

• Email: privacy@crobo.money
• Website: crobo.money