FYXO INC ("FYXO," the "Company," "we," "us," or "our") has created this Privacy Policy because we know that you care about how the information you provide to us is collected, used, and shared. This Privacy Policy relates to information collection and use practices in connection with the websites we own or control (the "Websites"), the products and services we make available (the "Products and Services"), and any other way in which you interact with us.

FYXO offers a range of products, including software, websites, apps, and services used by individuals and organizations worldwide. References to FYXO Products and Services in this Privacy Policy include our services, websites, apps, software, and related offerings that display or link to this Privacy Policy.

We are committed to processing personal information in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR and the Data Protection Act 2018, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA), and other applicable U.S. and international data protection laws. We operate a Privacy by Design approach, assessing privacy impact from the outset and designing systems and processes to protect personal information.

This Privacy Policy applies to visitors to the Websites who view only publicly available content ("Visitors"); customers who have signed up to access and use the Products and Services ("Customers"); and a customer's employees or contractors authorized by the Customer to access and use the Products and Services ("Authorized Users").

• By visiting our Websites, Visitors agree to this Privacy Policy and any accompanying Terms of Use.
• By accessing and/or using the Products and Services, each Customer and Authorized User agrees to this Privacy Policy.

Capitalized terms not defined in this Privacy Policy have the meaning given in our Terms of Use or applicable services agreement, as the context requires.

While operating the Websites, providing the Products and Services, and interacting with you, we collect and/or receive different categories of information directly from you, automatically through your use of our Products and Services, and from third parties.

3.1 Contact Information
When you contact us through the Websites, by email, by mail, or by phone, or when you register for events, request resources, or sign up for communications, you may provide your name, email address, phone number, company name, job title, and other information relevant to your inquiry ("Contact Information"). We use Contact Information to provide requested services or information and, where permitted, to contact you about our current and future Products and Services.

3.2 Account Information
To access certain Products and Services, you may create an account and provide information such as an email address and password ("Account Information"). We use Account Information to create and manage your account and verify identity.

3.3 Billing Information
To pay fees for Products and Services, you may provide payment-related information such as card number, expiration date, and billing address ("Billing Information"). Billing Information is collected and processed by third-party payment processors under their own policies. We do not directly obtain, store, or process payment card or bank account numbers.

3.4 Information Obtained Automatically (Usage Data)
When you access or use the Websites and/or Products and Services, we automatically collect technical information ("Usage Data") such as IP address, browser type and version, operating system, pages visited, time and duration of visits, referrers and exits, and mobile diagnostic data. We may also evaluate devices to identify malicious software or activity affecting service availability.

3.5 Tracking Technologies and Cookies
We and service providers use cookies, pixels, web beacons, local storage, and similar technologies ("Tracking Technologies") to operate, secure, analyze, and improve the Websites and Products and Services.

• Cookies: Small files that help authenticate users, remember preferences, analyze usage, and measure performance. We use session cookies and persistent cookies.
• Local Storage Technologies: Technologies such as HTML5 that provide cookie-equivalent functionality and can store larger amounts of data.
• Web Beacons: Pixel tags or clear GIFs used to confirm page/email access and interaction.
• Security Cookies: Used to support and strengthen security controls.

If you disable cookies or other Tracking Technologies, some parts of the Websites and Products and Services may not function properly.

3.6 Information Obtained from Third-Party Analytics Services
We use third-party analytics providers to evaluate use of our Websites and Products and Services, compile activity reports, and analyze performance. By accessing the Websites and/or Products and Services, you consent to processing of data by those providers for the purposes set out in this Privacy Policy.

• Google Analytics: https://www.google.com/analytics
• To exercise these choices, please contact us at [email protected].

3.7 Information Obtained from Other Sources
We may obtain information from sources including social platforms (such as LinkedIn, X/Twitter, and Facebook) and service providers that help determine approximate location from IP address. We handle this information in accordance with this Privacy Policy and applicable law. Information collected by third-party platforms is governed by their own policies.

We may use and share your personal information for the following purposes:

• Provide, maintain, secure, troubleshoot, and support the Websites and Products and Services.
• Improve, develop, and personalize Products and Services, and make recommendations.
• Communicate service updates and changes.
• Conduct marketing and advertising and measure effectiveness, with required consent where applicable.
• Gather analytics and monitor usage to improve performance.
• Detect, prevent, investigate, and address fraud, security incidents, technical issues, and other unauthorized activity.
• Share information with service providers and contractors performing services on our behalf.
• Create and disclose aggregated or de-identified information.
• Share information with our parent, subsidiaries, affiliates, or entities under common control.
• Comply with law and respond to lawful requests.
• Support corporate transactions such as merger, acquisition, financing, reorganization, or sale of assets.
• Otherwise process data with your consent.

We take reasonable contractual and operational measures to require parties receiving personal information from us to use it only for permitted purposes, disclose it only as allowed by law and policy, and protect it appropriately.

If you are in the European Economic Area (EEA) or the United Kingdom, our legal basis for collecting and using personal information depends on the information concerned and the context in which we collect it. We process personal information on one or more of the following bases:

• Performance of a contract with you, or steps at your request before entering into a contract.
• Your consent, which you may withdraw at any time.
• Our legitimate interests, where not overridden by your data protection rights.
• Compliance with legal obligations.

Update Information
If the personal information we hold about you changes, you may correct, update, or delete it by contacting us as set out in the Contact Us section, or, where available, within your account settings. We may retain certain information to comply with legal obligations, resolve disputes, and enforce agreements.

Marketing Communications
You may opt out of marketing and non-transactional communications by using the unsubscribe instructions in marketing emails. You cannot opt out of transactional or service-related communications.

Cookie Management
Most browsers allow you to remove or reject cookies through browser settings. If you disable cookies or other Tracking Technologies, parts of the Websites and Products and Services may not function properly. For more information, including how to manage and delete cookies, visit www.allaboutcookies.org. Apply preferences on each device and browser you use.

We take commercially reasonable technical and organizational measures to protect information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, considering the risks and the nature of the data.

For example, we use encryption in transit (HTTPS/TLS) to help secure communications. However, no method of Internet transmission or electronic storage is completely secure, and absolute security cannot be guaranteed.

The Websites and Products and Services may contain links to third-party websites ("External Sites") that are not operated by us. These links are provided for convenience and do not constitute endorsement.

We do not control and are not responsible for the content or privacy practices of External Sites. Review the privacy policy of every site you visit and take precautions when downloading files. Access to External Sites is at your own risk.

We do not knowingly collect personal information from children under 18 through the Websites or Products and Services. If you are under 18, please do not provide personal information.

If you believe a child under 18 provided personal information, contact us and we will take steps to delete that information from our systems.

We retain information for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with legal and regulatory obligations, resolve disputes, and enforce agreements.

Usage Data is retained for shorter periods unless used to strengthen security, improve functionality, or retained longer due to legal requirements.

Our servers and service providers are located in the United States and other countries where FYXO or its service providers operate. If you are outside the United States, information we collect, including personal information, may be transferred to and processed in countries where data protection laws may differ.

Except as otherwise required by applicable law, by providing information or allowing collection through the Websites and Products and Services, you consent to transfer and processing in accordance with this Privacy Policy. We take steps to ensure transfers are subject to appropriate safeguards.

FYXO INC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

FYXO INC has certified adherence to the relevant DPF Principles regarding personal data received from the European Union, the United Kingdom (and Gibraltar), and Switzerland, as applicable. If there is any conflict between this Privacy Policy and the DPF Principles, the Principles govern. FYXO INC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

For more information, please visit Data Privacy Framework Statement | FYXO.

Various browsers offer a Do Not Track (DNT) setting to express a preference not to be tracked. There is currently no industry standard for responding to such signals. At this time, we do not monitor, recognize, or honor DNT signals or similar mechanisms.

If you are a California resident, you may have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA). These may include the right to know what information we collect, use, and disclose; the right to request deletion or correction; the right to opt out of sale or sharing; and the right not to be discriminated against for exercising your rights.

To exercise rights, contact us as set out in the Contact Us section. We will verify requests before responding, and you may use an authorized agent where permitted by law.

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information to third parties. You may exercise this right by contacting [email protected] with the subject line "Nevada Do Not Sell Request" and providing your name and the email address associated with your account.

Please note that we do not currently sell personal information as "sale" is defined in Nevada Revised Statutes Chapter 603A.

If you are in the EEA or the United Kingdom, you have certain data protection rights. Subject to applicable law, these rights include:

• The right to access personal information we hold about you.
• The right to rectification of inaccurate or incomplete information.
• The right to erasure in certain circumstances.
• The right to restrict processing in certain circumstances.
• The right to object to processing, including direct marketing.
• The right to data portability in a structured, commonly used, machine-readable format.
• The right to withdraw consent where processing is based on consent.
• The right to lodge a complaint with a supervisory authority.

We may request identity verification before responding to rights requests.

Depending on the specific Product or Service you use, or interactions you have with us, we may provide different or supplemental privacy notices for those contexts. Where provided, those notices govern the relevant Product, Service, or interaction.

If there is any conflict between the English version of this Privacy Policy and a translated version, the English version controls.

This Privacy Policy is effective as of the date stated at the top of this page. We may update it from time to time and post changes here. Where appropriate, we may provide additional notice (such as by email or a prominent service notice) and update the effective date.

To the extent permitted by applicable law, use of information is governed by the Privacy Policy in effect at the time information is collected. Review this page periodically for updates.

If you have any questions about this Privacy Policy or wish to report a privacy concern, contact us using one of the following methods:

• Privacy inquiries: [email protected]
• Legal inquiries: [email protected]
• Mailing address: FYXO, 104 West 40th Street, New York, NY 10018, US