California Consumer Privacy Act (CCPA) Notice

This California Consumer Privacy Act ("CCPA") Privacy Notice supplements the Many Hats, LLC Privacy Policy and applies solely to California residents. This Notice describes how we collect, use, disclose, and protect your personal information and explains your rights under the California Consumer Privacy Act (as amended by the California Privacy Rights Act).

1. INFORMATION WE COLLECT

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

Category Examples Collected
A. Identifiers Name, postal address, email address, telephone number, username, IP address, brokerage account identifiers, API tokens YES
B. Personal Information (Cal. Civ. Code § 1798.80(e)) Name, address, telephone number, financial account information YES
C. Protected Classifications Age (to verify 18+) YES
D. Commercial Information Trade history, transaction records, order submissions, order execution results, profit/loss information, subscription records YES
E. Internet / Network Activity Browsing history, search queries, usage details, interaction with website or service, cookies data, device information, browser type, operating system YES
F. Geolocation Data General location data YES
G. Sensory Information None NO
H. Professional / Employment Information None NO
I. Non-Public Education Information None NO
J. Inferences Preferences and behavior patterns related to service usage YES

Sensitive Personal Information

We collect the following categories of sensitive personal information:

• Account credentials (username and password)

• Financial account information (processed through Stripe; we do NOT store full credit card numbers)

2. SOURCES OF PERSONAL INFORMATION

We collect personal information from the following sources:

• Directly from you when you register, use our service, or communicate with us

• Automatically through cookies, web beacons, and tracking technologies

• From third parties including:

- Brokerage firms (trade execution data)

- Payment processors (transaction confirmation)

- Service providers supporting our operations

3. PURPOSES FOR COLLECTING PERSONAL INFORMATION

We use personal information for the following business and commercial purposes:

Service Delivery:

• Providing and maintaining the Many Hats algorithmic trading service

• Processing account registration and authentication

• Executing trade orders through connected brokerage accounts

• Providing trading analytics and performance metrics

Business Operations:

• Processing payments and billing through Stripe

• Responding to customer support requests

• Sending account notifications and service updates

• Enforcing our Terms and Conditions of Service

• Detecting and preventing fraud and abuse

• Improving platform functionality and user experience

Communication:

• Responding to your inquiries

• Sending promotional communications (with your consent)

• Notifying you of service changes

Legal Compliance:

• Complying with legal obligations

• Protecting rights, property, and safety

• Responding to government or regulatory requests

We do NOT use your personal information to train AI systems or third-party data models.

4. DISCLOSURE OF PERSONAL INFORMATION

In the past 12 months, we have disclosed the following categories of personal information for business purposes:

Category Third Parties
Identifiers Service providers, payment processors (Stripe), brokerage firms, subsidiaries and affiliates
Commercial Information Service providers and brokerage firms for trade execution
Internet / Network Activity Service providers for analytics and hosting
Financial Information Payment processors (Stripe – PCI DSS compliant)
Geolocation Data Service providers

Recipients of Personal Information:

• Service providers (contractors bound by confidentiality obligations)

• Payment processors (Stripe for billing)

• Brokerage firms (to execute your trade instructions)

• Subsidiaries and affiliates

• Professional advisors (legal, accounting)

• Business transferees (in event of merger, acquisition, or asset sale)

• Government entities (when legally required)

5. SALE AND SHARING OF PERSONAL INFORMATION

We do NOT sell your personal information.

We do NOT share your personal information for cross-context behavioral advertising.

We have not sold or shared personal information in the past 12 months and do not have actual knowledge that we sell or share personal information of consumers under 16 years of age.

6. RETENTION OF PERSONAL INFORMATION

We retain personal information for as long as necessary to:

• Provide you with the Many Hats service

• Maintain your account

• Comply with legal, tax, and regulatory obligations (typically 7 years for financial records)

• Resolve disputes and enforce our agreements

• As otherwise disclosed at the time of collection

When you close your account, we delete personal information unless retention is required by law or legitimate business purposes (such as fraud prevention).

7. YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you have the following rights:

A. Right to Know

You may request that we disclose:

• Categories of personal information collected

• Categories of sources

• Business/commercial purposes for collection

• Categories of third parties with whom we share personal information

• Specific pieces of personal information collected about you

B. Right to Delete

You may request deletion of personal information we collected from you, subject to certain exceptions (e.g., completing transactions, legal compliance, fraud detection).

C. Right to Correct

You may request correction of inaccurate personal information we maintain about you.

D. Right to Limit Use of Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes other than those permitted under CCPA (service delivery, security, legal compliance). Therefore, this right does not apply to our current practices.

E. Right to Opt-Out of Sale/Sharing

Since we do not sell or share personal information, this right does not currently apply. If our practices change, we will provide a "Do Not Sell or Share My Personal Information" link.

F. Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights, including by:

• Denying goods or services

• Charging different prices or rates

• Providing a different level or quality of service

• Suggesting you will receive a different price or service level

8. HOW TO EXERCISE YOUR RIGHTS

To exercise your rights to know, delete, or correct your personal information:

Email: [email protected]

Mail: Many Hats, LLC

251 W. Central Ave. #138

Springboro, OH 45066

Online: Log into your account at app.nxtdeal.io and visit your account profile page

Verification Process

To protect your privacy, we will verify your identity before responding to your request. We may ask you to:

• Provide identifying information (name, email, account details)

• Confirm recent account activity

• Respond to verification emails

For requests to know specific pieces of information or delete personal information, we require a higher level of verification.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. The agent must:

• Provide written authorization signed by you, or

• Present a valid power of attorney under California Probate Code

We may still require you to verify your identity directly or confirm you provided the agent permission.

Response Timing

We will respond to verifiable requests within 45 days. If we need more time (up to 90 days total), we will notify you of the reason and extension period.

9. NO DISCRIMINATION FOR EXERCISING RIGHTS

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not:

• Deny you access to the Many Hats service

• Charge you different prices or rates

• Provide a different level or quality of service

10. CALIFORNIA "SHINE THE LIGHT" LAW

California Civil Code Section § 1798.83 permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes.

We do not share personal information with third parties for their direct marketing purposes.

If you have questions, contact us at [email protected].

11. FINANCIAL INCENTIVES

We do not currently offer financial incentives or price differences related to the collection, retention, or sale of personal information.

12. CHANGES TO THIS NOTICE

We will update this CCPA Privacy Notice as needed to reflect changes in our practices or legal requirements.. We will post the updated notice on our website with a revised "Last Updated" date.

Material changes will be communicated through:

• A notice on our website homepage

• Email notification to your registered email address

13. CONTACT INFORMATION

For questions about this CCPA Privacy Notice or our privacy practices:

Many Hats, LLC

251 W. Central Ave. #138

Springboro, OH 45066

Email: [email protected]

Notice at Collection Summary

We collect identifiers, commercial information, internet activity, geolocation data, financial information (processed via Stripe), and account credentials to provide our algorithmic trading service, process payments, prevent fraud, and improve our platform. We do not sell your personal information. For more details, see the full CCPA Privacy Notice above.

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This document does not constitute an offer to sell securities or investment advisory services.
All trading involves risk. You should carefully consider whether this strategy
is appropriate for your financial situation.

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