Effective Date: March 20, 2026

1. Introduction & Service Distinction

EXDS Capital LLC is committed to protecting the confidentiality and security of our clients' and website visitors' information. This Privacy Policy is designed to comply with SEC Regulation S-P, the Gramm-Leach-Bliley Act (GLBA), and applicable data protection laws.

How your data is handled depends on your relationship with us:

• Investment Advisory Clients: Handled strictly under U.S. federal laws (GLBA/Reg S-P).
• EXDS Insight Subscribers (Global): Subject to applicable global privacy laws, including the EU General Data Protection Regulation (GDPR) for European subscribers.

By using our website, subscribing to EXDS Insight, or becoming an advisory client, you acknowledge and consent to the practices described in this Privacy Policy.

2. Information We Collect

We collect data necessary to operate effectively and provide you with our services:

• Non-Public Personal Information (NPI): If you become an advisory client, we collect NPI such as your identity (Name, SSN/Tax ID), contact details, and financial information (income, net worth, account balances).
• Subscription Information: For EXDS Insight, we collect your name, email, and secure payment processing data.
• Website Data & Cookies: We utilize Cookiebot to manage user consent and collect standard analytics data (e.g., IP addresses, browser interaction metrics) to improve our website.

3. How We Use and Share Information

EXDS Capital LLC does not sell your personal information to third parties. We use and share your information strictly for lawful business purposes, such as opening accounts, processing transactions, and delivering communications. We share data only with trusted service providers:

• Custodians: Interactive Brokers LLC (IBKR) and Charles Schwab & Co., Inc. for trade execution and account custody.
• Service Providers: Google Workspace (secure internal operations/document storage), MailerLite (email communications/newsletters), and Cookiebot (cookie consent and compliance management).
• Regulatory Authorities: When required by law or to cooperate with SEC or state regulatory examinations.

4. Safeguarding Information

In compliance with the SEC Safeguards Rule, we maintain robust physical, electronic, and procedural safeguards designed to protect your NPI from unauthorized access or use. This includes data encryption, secure servers, multi-factor authentication, and strict internal access controls limiting data strictly to authorized personnel.

We retain records of communications and client-related information for at least five years (with the first two years in an easily accessible place) in accordance with SEC Rule 204‑2.

5. Cookies, Web Tracking, and User Rights

• Cookies: You may manage or revoke your consent to non-essential cookies at any time using the Cookiebot interface on our website.
• Email Communications: You may opt out of our marketing and EXDS Insight emails by clicking the "unsubscribe" link provided in our MailerLite communications.
• GDPR Rights (EU/UK/EEA Subscribers): If you are an EXDS Insight subscriber located in the EU/UK/EEA, you have the right to request access, rectification, erasure, or data portability of your personal data.

To exercise your privacy rights, or if you have questions regarding this policy, please contact us at privacy@exdscapital.com.

FACTS – What Does EXDS Capital LLC Do With Your Personal Information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number, income, and employment information
• Account balances and transaction history
• Investment objectives and risk tolerance
• Credit history and assets

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons EXDS Capital LLC chooses to share; and whether you can limit this sharing.

Questions?

Email: privacy@exdscapital.com

EXDS Capital LLC
8 The Green STE B, #24792, Dover, Delaware 19901

Definitions

Affiliates - Companies related by common ownership or control. They can be financial and nonfinancial companies. EXDS Capital has no affiliates.

Nonaffiliates - Companies not related by common ownership or control. They can be financial and nonfinancial companies. EXDS Capital does not share with nonaffiliates so they can market to you.

Joint Marketing - A formal agreement between non-affiliated financial companies that together market financial products or services to you. EXDS Capital does not engage in joint marketing.