Privacy Policy [PLACEHOLDER]

Last Modified and Effective Date: July 6, 2026

This Privacy Policy (“Policy”) explains and governs the manner in which Wire Industries Inc dba WireMarkets, together with its related, affiliated, parent, or subsidiary companies (collectively referred to herein as “WireMarkets,” “we,” “our,” or “us”), collects, uses, discloses, and otherwise processes information related to your use of our website, mobile applications, social media accounts, digital platforms, or other online services (collectively “Services”).

When we refer to “you” or “your” in this Policy we mean any individual who interacts with or uses our Services. By accessing and using the Services, you represent that you understand and agree to this Policy, and consent to the collection, use, disclosure, and sharing of information as described in this Policy. If you do not consent to our practices, you can choose not to use the Services.

1. Personal Data We Collect

We may collect, use, store, and disclose different kinds of information that is linked or reasonably linkable to an identified or identifiable individual (collectively referred to herein as “Personal Data”). Information that we collect may depend on how you interact with us and use the Services. A description of the types of information we may collect is described in detail below.

• Identifiers — such as name, online identifier, gender, profession, social security number, driver’s license number, passport number, or other government-issued identification document.
• Contact Information — such as your email address, mailing address, and telephone numbers.
• Financial Information — such as financial transaction history, credit history, tax information, and credit scores.
• Profile Data — such as your username and password and your interests and preferences.
• Commercial Information — such as records of products or services purchased, obtained, or considered, trades made, survey responses, or other purchasing or consuming histories or tendencies.
• Characteristics of Protected Classifications — under applicable law, including age or date of birth, national origin, and citizenship.
• Biometric Information — including faceprints (i.e. your face geometry) to verify your identity, which is collected by our vendor. Biometric information is treated as sensitive Personal Data as described below.
• Usage Data — information about how you use our Services, such as statistics regarding the opening and clicking of emails, and activity on the website (activity, time spent, user stats, referring/exit pages, and clickstream data), or how you otherwise engage with us.
• Internet or Other Electronic Network Activity Information — including browsing history, search history, and information regarding your interactions with a website, application, or advertisement, including IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
• Marketing and Communications Data — such as marketing campaign data, click throughs, your preferences in receiving marketing from us and our third parties, your communication preferences, email communications, and chat communications.
• Audio and Visual Information — such as audio or video recordings and photographs.
• Location Data — such as precise geolocation data through GPS, Wi-Fi, wireless network triangulation, or other methods.
• Inference Data — including inferences drawn from the Personal Data identified above.
• Sensitive Personal Data — we collect Personal Data that may be considered sensitive under applicable privacy laws, including social security number, driver’s license, passport, or other government-issued ID, national origin, citizenship, precise geolocation, and biometric information. We do not use or disclose sensitive Personal Data for any purposes other than as permitted by law, including providing you with the goods and services you request, verifying your identity, ensuring the security and integrity of our websites and apps, and complying with applicable legal requirements.

2. Biometric Information Policy

WireMarkets uses third-party technology through its vendors to collect, store, and use biometric information, such as your faceprints (i.e. your face geometry), along with other Personal Data like a selfie and government-issued ID. By using our Services, you consent to WireMarkets, our identity verification vendors, and each of our contracted service providers collecting, storing, and using your biometric information for the purposes identified below and as set forth in those vendors’ privacy policies.

Purpose for Collection of Biometric Information. WireMarkets and its vendors may use biometric information to verify your identity, prevent fraud, improve products and services, and comply with legal obligations.

Data Retention. Biometric information will be securely deleted no later than 3 years after your last interaction with us or our vendor, whichever happens first, provided we have no other legal obligation to retain such information for any longer period.

3. How We Collect Personal Data

We may collect Personal Data from a variety of sources and methods. This includes:

a. Directly From You

We may collect Personal Data during your access or use of the Services, such as when you:

• Create or verify an account;
• Purchase goods and/or services;
• Participate in a promotion, survey, and/or contest;
• Communicate with us by mail, phone, email, or otherwise engage with us;
• Make a deposit or withdrawal; or
• Otherwise complete a form or share your Personal Data with us.

b. Information We Collect When You Use Our Services

• Automated technologies or interactions. As you navigate around our Services (whether or not you have logged into a user account) we may collect certain information using various technologies to help us personalize your experience. This may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, time zone setting and location, language preferences, device type and ID, and other technical information from the devices you use.
• Cookies and Tracking Technologies. We and our service providers use cookies, pixels, and other tracking technology to recognize your browser or device and to capture and remember certain information about your activities on our website. You can choose to have your computer warn you each time a cookie is being sent, or turn off cookies by adjusting your browser settings; if you turn off cookies, some features of the website may not function properly. You can generally opt out of receiving targeted ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative by visiting optout.networkadvertising.org, or via the Digital Advertising Alliance at optout.aboutads.info. We also use pixel tags in our HTML-based emails to let us know which emails have been opened; if you prefer not to be tracked, most email services allow you to disable external images.
• Analytics. We use third-party cookies provided by Google Analytics to better understand our visitors. These cookies collect IP address and usage data, such as the length of time spent on a page, the pages visited, and the websites visited before and after ours. You can access the Google Analytics Opt-Out Browser Add-on to opt out.

c. Information We Collect from Third Parties

• Service Providers. We collect Personal Data from service providers including email service providers, website hosting platforms, third-party identity verification, analytics, and geolocation service providers.
• Social Media Services. When you create an account using your Google or Apple login we receive Personal Data from those third parties, which may include your public profile information and email.
• Third-Party Advertising Partners. We collect Personal Data received from third-party advertising partners, including partners who host and manage online advertisements and ad platforms.
• Data Brokers. We may collect information from third-party data brokers, including contact details, demographic information, commercial preferences, and online activity data, to better understand our customers, tailor our services and marketing, and detect and prevent fraud.
• Publicly Available Information. We may collect Personal Data from publicly available sources, government and other public sources, and social media platforms and networks.

4. How We Use Personal Data

Our primary purpose for collecting your information is to provide you with the products and services you request. We may also use your information to:

• Provide products and services — set up and manage your account, facilitate transactions, verify your identity and account information, provide required notices and updates, resolve disputes, troubleshoot problems, and communicate with you about content, products, services, updates, events, and offers.
• Comply with legal and regulatory obligations — including anti-money-laundering and counter-terrorism-financing requirements. When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you, and we may ask to see your driver’s license or other identifying documents.
• Market our goods and services or those of our group of companies, business partners, and other third parties, and provide you with recommendations we believe would be of interest to you.
• Generate insights — identify trends and make inferences about you and your interactions with us, such as analyzing your behavior and preferences and how you use and engage with our Services.
• Protect ourselves and others — enforce our Terms and this Policy, establish, exercise, and defend legal rights and claims, prevent fraud, cooperate with law enforcement and regulators, and stop prohibited, illegal, or harmful activities.
• Run internal business and operational functions — manage customer accounts, troubleshoot and test systems, audit our interactions with you, respond to security incidents, and manage competitions and promotions you have chosen to participate in.

5. Data Retention

We will retain your Personal Data for as long as necessary to fulfill the purposes we have outlined, to comply with applicable laws and regulations, and to support any claim, defense, or declaration in a case or before a jurisdictional, administrative, arbitration, or mediation authority. This includes, for example, retaining your Personal Data to provide you with the products or services you have requested, maintain our business relationship with you, improve our business over time, ensure the ongoing legality, safety, and security of our Services, or otherwise in accordance with our internal retention procedures.

6. How We Disclose Personal Data

• Group Companies. We may disclose your Personal Data to the WireMarkets group of companies, including affiliated entities, parents, and subsidiaries, who may use it for the purposes described herein, such as to customize offerings and market services to you. Our affiliated companies provide support services for WireMarkets, including order flow, customer support, and other business services.
• Service Providers. We may use third-party service providers to perform certain business services and disclose your information to them as needed. Service providers are only allowed to use, disclose, or retain this information to provide these services, which include hosting; account authentication and identity verification; marketing and email; customer and technical support; quality assurance testing; and back-office support.
• Business Transactions. We may sell, transfer, or merge parts of our business or our assets, or acquire or merge with other businesses. If a change happens to our business, your information may be transferred to the new owners, who may use it in the same way as set out in this Policy.
• Legal Process. Subject to applicable law, we may disclose information about you if required to do so by law, regulation, or legal process; in response to requests by government entities such as law enforcement; when we believe disclosure is necessary to prevent harm, injury, or loss; to establish, exercise, and defend against legal claims; or in connection with an investigation of suspected or actual unlawful activity.
• Targeted Advertising and Business Partners. We have shared Personal Data with third-party advertising partners to serve ads to you about our Services as you browse the Internet. We also work with business partners — such as social networks, promotional and sponsorship partners, content licensors, market access partners, sports leagues, teams and governing bodies, and advertising measurement partners — and may disclose your Personal Data to them for their own purposes. This sharing may be considered a “sale” or “sharing” of Personal Data under certain laws; see “Your Privacy Rights” below to opt out. WireMarkets does not sell the Personal Data of minors under 16 years of age.
• User Disclosures. Information you transmit in a publicly accessible blog, chat room, or social network, or share in an open forum, may become public information and may be viewed and used by others without restriction. We do not control such uses of your Personal Data.

7. Communications and Opt-Out

Depending on your marketing settings and preferences, we may use your information to tell you about our products, services, and offers by email, text, or push notification.

• Email. You may opt out of promotional emails by following the unsubscribe instructions in a promotional email. This will not apply to operational or informational emails related to your account. You may continue to receive promotional messages for a short period while we process your request.
• Text Messaging. We may send marketing texts where you have provided opt-in consent. Standard messaging charges apply. Your agreement to receive promotional texts is not a condition of any purchase or service. You may opt out at any time by replying STOP to any text message you receive from us.
• Push Notifications. Where you have chosen to receive push notifications, we may send them relating to our products, services, offers, and other initiatives. You can stop receiving them at any time by changing your preferences on your device.

8. Third-Party Websites and Social Media Services

Third-Party Websites. The Services may contain links to other websites or Internet resources. We have no responsibility or liability for, or control over, those other websites or their collection, use, and disclosure of your information, and this Policy does not apply to Personal Data collected through them. We suggest that you read the privacy policy and terms of use of each such website.

Social Media. Our Services may allow you to engage with social media services and widgets, which may access, collect, and integrate with your social network accounts and information. We do not control those networks or your profiles on them. Your interactions with them are governed by the privacy policy of the company providing them.

9. Your Choices

There are several ways in which you may opt out of the various programs and services we provide, including the email, text messaging, and push notification options described above.

Location Data Opt-Out. You may adjust the settings on your device to allow or restrict the sharing of location information. If you elect not to share your location information, you may be unable to access certain features of our Services, and we may still estimate your general location based on the IP address you use.

10. Security

While we work to employ reasonable technical and organizational measures to safeguard the Personal Data that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, we cannot guarantee the security of any Personal Data that you transfer over the Internet to us.

11. Privacy of Minors

The Services are intended for users aged twenty-one (21) and older. If you are under the age of twenty-one (21), you are not authorized to provide us with any personally identifying information, nor to access or use our Services in any manner whatsoever. By using the Services, you represent that you are twenty-one (21) years of age or older.

12. Your Privacy Rights

Depending on your jurisdiction of residence, you have certain rights with respect to your Personal Data. This section describes those rights and explains how to exercise them.

• Right of Access and Portability. You have the right to confirm whether we are processing your Personal Data and to access it, including the categories of Personal Data we collect, the sources, the categories sold or shared, our purposes, and the specific pieces of Personal Data. You also have the right to obtain a copy in a portable, readily usable format.
• Right to Correct. You may request that we correct inaccurate Personal Data we have collected from you, though we may need to verify the accuracy of the new data you provide.
• Right to Delete. You may request that we delete Personal Data we have collected from you under certain circumstances. Some information may not be eligible for deletion based on applicable law or the requirements of contracts.
• Right to Opt Out. You have the right to opt out of processing Personal Data for targeted advertising, the sale of Personal Data, or profiling in furtherance of a decision that produces a legal or similarly significant effect.
• Right to Limit Use and Disclosure. Where applicable, you have the right to request that we limit the use and disclosure of sensitive Personal Data to specific business purposes approved by law. Our use of sensitive Personal Data is already limited to those purposes.
• Right to Withdraw Consent. You have the right to withdraw your consent at any time where we rely on consent to process your Personal Data. If you withdraw consent, we may not be able to provide certain products or services to you.
• Right to Non-Discrimination. Unless permitted by applicable law, we will not discriminate against you for exercising any of your privacy rights.

Exercising Your Privacy Rights

To submit a request to know, correct, delete, or opt out, please contact us at privacy@wiremarkets.com. If your browser supports it, you can turn on the Global Privacy Control (GPC) to opt out of the sharing of your Personal Data for targeted online advertising. Only you, or an agent you authorize to act on your behalf, may make a verifiable request related to your Personal Data.

Verifying Your Request. A verifiable request must include your full legal name, email, and phone number, and describe your request with sufficient detail that allows us to understand, evaluate, and respond to it. We cannot respond to your request or provide you with your Personal Data if we cannot verify your identity or authority. We endeavor to respond within forty-five (45) days of receipt; if we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.

13. Categories of Personal Data Disclosed, Sold, or Shared

The following table summarizes the categories of Personal Data we may disclose for a business purpose or sell or share (including for targeted advertising), and the categories of recipients, in the preceding twelve months.

14. Other Notices and Important Information

Privacy Policy Changes. This Policy may change from time to time. When changes are made, we will update the “Last Modified and Effective Date” at the top of this Policy. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy for updates. When necessary, we may notify you of material changes, for example via email.

15. Contact Us

For questions relating to this Policy, you should contact us at privacy@wiremarkets.com.