PRIVACY POLICY

PROMISE FINANCIAL, INC., DBA PROMISSORY

Last Updated: April 4, 2025

This Privacy Policy describes how Promise Financial, Inc., doing business as Promissory ("Promissory," "we," "us," or "our"), collects, uses, shares, and protects personal information obtained from users ("you" or "your") of our website, Promissory.com, and our services related to QSBS stacking, tax preparation, and financial planning.

1. INFORMATION WE COLLECT

1.1 Personal Information

We collect the following categories of personal information:

• Contact Information: Full legal name, postal address, email address, phone number.

• Identification Information: Social Security Number (SSN), Tax Identification Number (TIN), date of birth.

• Family Information: Information about your spouse, children, and other beneficiaries, including their full legal names, addresses, and Social Security Numbers.

• Business Information: Information about your business ownership, stock ownership, and financial information related to your business.

• Transaction Information: Information about the services you purchase, billing information, payment methods, and payment history.

• Communication Information: Records of communications between you and Promissory, including emails, phone calls, platform messages, and SMS communications.

• Account Information: Login credentials, account preferences, and account activity.

1.2 Automatically Collected Information

We automatically collect certain information when you visit our website or use our services:

• Device Information: Information about your device, including IP address, browser type, operating system, and device identifiers.

• Usage Information: Information about how you use our website and services, including pages visited, time spent, and actions taken.

• Cookies and Similar Technologies: We use cookies and similar technologies to collect information about your browsing activities. For more information, please see our Cookie Policy section below.

2. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

• To provide and maintain our services

• To create and manage your account

• To process and complete transactions

• To prepare tax forms and legal documents

• To file documents with the IRS on your behalf

• To establish and manage trusts

• To communicate with you about our services

• To respond to your inquiries and provide customer support

• To send you important information about your account or our services

• To improve our website and services

• To prevent fraud and ensure security

• To comply with legal obligations

• For other purposes with your consent

3. INFORMATION SHARING AND DISCLOSURE

3.1 Third-Party Service Providers

We share your information with third-party service providers who help us deliver our services:

• Trust Custody Partners: We share information necessary for trust establishment and management, including Crawford Trust Company.

• Valuation Partners: We share business information for valuation purposes.

• Payment Processors: We share payment information with Stripe to process payments.

• Marketing Technologies: We share information with marketing platforms to provide a personalized service.

• Cloud Service Providers: We use cloud services to store and process information.

• Communication Services: We use communication service providers to facilitate emails, SMS, and other communications.

3.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

3.3 Business Transfers

If Promissory is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your information.

3.4 With Your Consent

We may share your information with third parties when we have your consent to do so.

4. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data

• Two-factor authentication (2FA)

• Automatic log-out functionality

• Regular security audits

• Human review of all trust transactions

• Secure code practices

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

4.1 Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify you in accordance with applicable laws. Our notification will typically include:

• A description of the breach

• The types of information affected

• Steps we are taking to address the breach

• Recommended actions you can take to protect yourself

• Contact information for questions

We will provide this notification without unreasonable delay, typically within 72 hours of discovering the breach, through email and/or prominent notice on our website.

5. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We may retain information indefinitely unless specifically requested to delete it, subject to legal requirements.

Factors we consider in determining retention periods include:

• Legal obligations to retain data for certain periods

• Statute of limitations under applicable law

• Ongoing or potential disputes

• Guidelines issued by relevant data protection authorities

• The purposes for which we collected and use the information

6. YOUR RIGHTS AND CHOICES

Depending on your location, you may have certain rights regarding your personal information:

6.1 California Residents

Under the California Consumer Privacy Act (CCPA), California residents have the right to:

• Request disclosure of the personal information we collect, use, disclose, and sell

• Request deletion of personal information

• Opt-out of the sale of personal information

• Non-discrimination for exercising CCPA rights

To exercise these rights, please contact us using the information provided in the "Contact Us" section.

6.2 All Users

All users have the following rights:

• Access: You can request access to your personal information that we hold.

• Correction: You can request that we correct inaccurate or incomplete information.

• Deletion: You can request deletion of your personal information, subject to certain exceptions.

• Communication Preferences: You can update your communication preferences at any time.

6.3 Response Timeframe

We strive to respond to all privacy-related requests within 30 days. In some cases, particularly for complex requests or if you have submitted multiple requests, we may need up to 45 days to respond. If we require additional time, we will inform you of the reason and extension period in writing. If we cannot fulfill your request, we will explain why in our response.

7. 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 are a parent or guardian and believe your child has provided us with personal information, please contact us.

8. COOKIE POLICY

8.1 What Are Cookies

Cookies are small text files that are placed on your device when you visit our website. They allow us to recognize your device and remember certain information about your visit.

8.2 How We Use Cookies

We use cookies to:

• Keep you signed in to your account

• Remember your preferences

• Understand how you use our website

• Improve our website and services

• Protect against fraudulent activity

8.3 Types of Cookies We Use

• Essential Cookies: Necessary for the website to function properly.

• Preference Cookies: Allow the website to remember choices you make.

• Analytics Cookies: Help us understand how visitors interact with our website.

• Marketing Cookies: Used to track visitors across websites to enable targeted advertising.

8.4 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically delete or reject cookies. However, if you delete or reject cookies, some features of our website may not function properly.

9. THIRD-PARTY WEBSITES AND SERVICES

Our website may contain links to third-party websites and services. This Privacy Policy does not apply to those websites or services. We encourage you to review the privacy policies of any third-party websites or services before providing any information to them.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top. For significant changes, we will provide additional notice, such as an email notification. Your continued use of our services after such changes constitutes your acknowledgment of the modified Privacy Policy.

11. COMPLIANCE WITH LAWS AND REGULATIONS

We comply with applicable data protection laws and regulations, including the California Consumer Privacy Act (CCPA). As a registered tax agent/preparer, we also comply with IRS regulations regarding taxpayer information.

11.1 Tax Information Handling

As a registered tax agent/preparer, we adhere to IRS regulations regarding the confidentiality and security of taxpayer information:

• We collect only the information necessary to prepare and file tax documents

• We maintain appropriate administrative, technical, and physical safeguards to protect tax information

• We restrict access to tax information to authorized employees and service providers

• We do not disclose tax information to third parties except as permitted by law or with your consent

• We comply with IRS Publication 4557 (Safeguarding Taxpayer Data) guidelines

• We retain tax records in accordance with IRS requirements (generally for 3 years from the filing date)

12. TRUST DOCUMENTS AND PRIVACY

When creating trust documents on your behalf:

• All information contained in the trust documents is subject to this Privacy Policy

• Trust documents may be shared with the trust custody partner (e.g., Crawford Trust Company)

• The information in these documents may be subject to legal disclosure requirements

• Trust documents are maintained with strict confidentiality and security protocols

• Access to trust documents is limited to authorized personnel and service providers

• You maintain ownership rights to the content of your trust documents as specified in our Terms and Conditions

13. INTERNATIONAL DATA TRANSFERS

While our services are intended for U.S. residents, your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the information to the United States and process it there.

14. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Promise Financial, Inc.
3827 S Carson St
505-25 Unit #3395
Carson City, NV 89701
Email: info@promissory.com

15. SPECIAL NOTIFICATION FOR NEVADA RESIDENTS

If you are a Nevada resident, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by emailing us at info@promissory.com. Please note that we do not currently sell data triggering that statute's opt-out requirements.

16. SPECIAL DISCLOSURE FOR CALIFORNIA RESIDENTS

CCPA Privacy Notice Supplement

This California Privacy Rights section provides information about the categories of personal information that we collect, the purposes for which we use personal information, and your rights under California law.

16.1 Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information:

• Identifiers (e.g., name, address, email, phone number, SSN)

• Personal information categories listed in the California Customer Records statute

• Commercial information (e.g., products or services purchased)

• Internet or other electronic network activity information

• Professional or employment-related information

• Financial information

• Inferences drawn from other personal information

16.2 Sources of Personal Information

We obtain personal information directly from you, from your browser or device when you visit our website, from service providers, and from publicly available sources.

16.3 Use of Personal Information

See Section 2 of this Privacy Policy for information about how we use your personal information.

16.4 Disclosure or Sale of Personal Information

In the past 12 months, we have disclosed personal information to the categories of third parties listed in Section 3 of this Privacy Policy.

We do not sell personal information as defined by the CCPA.

16.5 Your Rights Under California Law

If you are a California resident, you have the following rights:

• Right to Know: You can request information about the personal information we have collected about you and how we have used and disclosed it.

• Right to Request Deletion: You can request that we delete your personal information, subject to certain exceptions.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

16.6 How to Exercise Your Rights

To exercise your rights under the CCPA, please submit a request by:

• Emailing us at info@promissory.com

We will verify your identity before responding to your request by asking you to provide additional information or log into your account.