Privacy Policy

Updated November 18, 2025

1. Introduction.

Your privacy is important to us. crypto trust fund strives to ensure your information is secure and handled appropriately and in line with this policy. This privacy policy applies to the information we collect about you in the course of our business, including: through our website, any of our other websites, products, or services that include a link to this privacy policy, our products, and other related offerings operated by or on behalf of us, including our customer service features such as phone calls and chats. We refer to these products, services, and offerings collectively as the "Services."

If you are using our Services, this policy applies to you. If you disagree with any aspect of this policy, please do not use the Services.

This Privacy Policy is incorporated into our Terms of Service and governs your use of crypto trust fund's services.

The Privacy Policy contains the following sections:

• The information we collect
• How we use your information
• How we disclose your information
• Online analytics and advertising
• Children's privacy
• Your rights and choices
• Notice to CA residents
• Transmission of information to other countries
• Securing and storing your data
• Retention of your information
• Employee and Applicant Privacy
• Policy modification
• How to contact us

2. The information we collect.

The information we collect about you depends on the Services you use, how you use them, and the information you provide to us. We collect information in three main ways: (1) information you provide directly to us; (2) information we collect automatically through technology when you use the Services; and (3) information we collect from other sources.

A. Information you provide directly to us

When you use our Services, you may provide certain information to us. The categories of information we collect directly could include:

• Contact and account information, like your name, address, telephone number, username, email address, and login credentials.
• Government issued identifiers, like your driver's license, passport number, or other issued government identification.
• Financial and transactional information, like your account number, credit card or other billing information, and purchase and transaction history.
• Customer service interaction information, such as messages submitted to us through online forms or email.

B. Information we collect automatically through technology when you use the Services

When you use our Services, we, our service providers, and our vendors may automatically collect certain information using a variety of third party technologies, including cookies and similar tools. Some of the information we automatically collect includes:

• Device data: IP address, browser language, unique device identifiers, operating system, browser type.
• Usage data: browsing behavior, page visits, the features you use, clicks, and searches on the site.
• Location Information: General location information based on IP address.

C. Information we collect from other sources

We may receive information about you from other crypto trust fund users. We may also receive information about you from other sources, such as business partners, marketing partners, and other parties to help supplement our records.

3. How we use your information.

We may use the information we collect for the following purposes:

A. To provide you with the services you requested, including to assemble and deliver your personalized crypto trust planning documents, process payments, verify your identity, create and administer your account, and offer member support.

B. To communicate with you by email, telephone, or text message, for example, to keep you posted on your crypto trust plan, provide transaction or account-related messages, and share product updates.

C. For marketing, advertising, and analytics purposes.

D. To personalize your experience to provide the Services.

E. To improve our Services, including bug detection and error reporting.

F. For our business operations, including maintaining your account, and for security, fraud prevention, and legal compliance.

4. How we disclose your information.

We and our service providers disclose the information we collect from and about you in the following circumstances:

A. Vendors and Service Providers— We work with select third-party vendors to ensure we can provide our Services and operate our business, and we may provide access to or disclose your information to these vendors. They provide a variety of services we use, including: printing and mailing off your crypto trust planning documents, facilitating filing of legal documents at your direction, or by connecting you with an attorney if you've purchased a form of attorney support, performing the services we've agreed to via the support of other similar service providers, payment processing, financial data aggregation services, A/B testing and personalization platforms, mobile attribution, customer communication, product analytics, error and performance monitoring platforms, AI-powered communication and call center platforms, conversation intelligence and recording platforms, marketing, analytics, product design and development, data hosting and storage, security, fraud prevention, research, and legal services.

B. Corporate affiliates and subsidiaries— We may share your information with our corporate affiliates and/or subsidiaries who are subject to this privacy policy.

C. Corporate merger or acquisition— We may sell, transfer, or otherwise share some or all of our assets, including your information, in connection with a corporate transaction such as a merger, acquisition, reorganization, or sale of assets. In such an event, you may receive notice if your data is transferred and becomes subject to a different privacy policy.

D. Legal compliance and protection of crypto trust fund and others— We may release your information when necessary to comply with the law, enforce our site policies, or protect our rights or the rights of others regarding property or safety.

F. Third-party services— We might link to or offer third-party services on our website. If you click on any of those third-party offerings, we may facilitate disclosure of your information and documents you choose to use with those services if we have your consent to do so. Your use of those services is not governed by our Terms of Service or this Privacy Policy. We do not control the services of those third parties or how they use your information and documents. Be sure to review the third-party's terms and conditions, and privacy policy before using any third-party services.

Additionally, some features may allow you to share your account information and documents with third parties, such as a financial advisor. When you grant such access, you acknowledge and agree that this authorization extends to the third party's authorized employees and agents ("Delegates") who may be granted access by the primary third party. You are responsible for this authorization, and you may revoke it at any time through your account settings. For example, if you choose to link a financial account to our Services, you may be directed to a service like Plaid Inc. ("Plaid"). When you use such a service, you are providing your information directly to that third party, and your data is governed by their privacy policy.

G. Other third party partners— We may also disclose your information to other third parties. For example, we may share certain of your contact information and information about the type of product you purchase so that these parties may contact you to offer you products, services, and promotions that you might find valuable. We may also allow third-party advertising technologies on our Services that use cookies and similar technologies to deliver relevant and targeted content and advertising to you about the Services on other websites you visit and applications you use, as explained further in the "Online Analytics and Advertising" section below.

Please review the "Your rights and choices" section for more information on how to opt out of such disclosures.

H. Aggregate/Anonymous Information— From time to time, we may disclose aggregated and/or anonymized information about the use of the Services. The disclosure of such data is unrestricted.

I. Non-Profit Organizations— General Disclosures. We may disclose your personal information, such as your name and contact information, to non-profit organizations for general charitable or educational purposes. This is separate from our NPO Platform described in Section 4.K below. You may opt out of these general disclosures by following the instructions in the "Your rights and choices" section of this policy.

J. Business Partner Programs. We may enter into agreements with business partners, such as banks, credit unions, and other financial institutions, where we are compensated for providing them with your personal information. This activity constitutes a "sale" of personal information under applicable privacy laws. The information we sell may include:

• Contact and Transactional Information, such as your name, the type and value of your purchase, and the date of your purchase.
• Financial Characteristics and Inferences, such as an estimated net worth range or whether you own real crypto trust or have life insurance.

You have the right to opt out of the sale of your personal information at any time by using the privacy settings tool accessible via the cookie icon on our website.

A note about your feedback. If you submit a user testimonial, we may publish your testimonial on the Services. Our processing/disclosure of feedback and submitted content will be in accordance with our Terms of Service and any additional terms provided to you at the point of submission.

K. NPO Platform Data Sharing— NPO Platform Overview. We operate an NPO Platform that enables non-profit organizations to receive information about crypto trust fund users who have designated charitable gifts to those organizations in their crypto trust plans. When you create an crypto trust plan that includes charitable gifts, you may choose to share certain information with the specific non-profit organizations you designate in your plan, whether as gift recipients or beneficiaries (including primary, backup, or second backup beneficiaries). We do not share your information with any NPOs that you have not specifically named or designated in your crypto trust plan.

Data Shared with NPOs. We share information only with NPOs you specifically name or designate in our crypto trust plan. If you use an NPO's referral link, we share limited metadata with that specific NPO for referral tracking purposes. When an NPO is named in your plan and you consent, we may share the following categories of information based on the NPO's subscription tier:

All Subscription Tiers (Essentials, Premium, Enterprise):

• Donor name
• Donor plan type (Will, Trust, Couples, Individual)
• Age
• State
• Plan status (Account created, in progress, Complete, Signed)
• Gift details (Fixed vs. percentage, estimated amount)
• Date account created
• Donation notes

Premium and Enterprise Tiers Only:

• Donor email address
• Campaign data including:
  • Name and email of individuals who used NPO referral links
  • Notes indicating whether sign-up was organic versus referral-driven
  • UTM data for campaign tracking
  • Date of gift last update

Referral Program Data. We collect and share referral tracking information when you use NPO-provided discount codes or referral links. The scope of data shared depends on your relationship with the NPO: (1) if you click an NPO's referral link but do not name that NPO in your crypto trust plan, we share only basic metadata (name, email, state, age) with that specific NPO for referral tracking purposes. (2) if you use an NPO's referral link and also name that NPO in your crypto trust plan and consent to data sharing, we share the full tier-appropriate Donor Data described above. In both scenarios, we collect UTM parameters, referral attribution data, and campaign performance metrics that help NPOs understand the effectiveness of their outreach efforts. Referral data is shared only with the specific NPO whose link or code was used.

Co-Branded Services Data. For Enterprise-tier NPOs with co-branded landing pages, we may collect additional information about your interactions with co-branded content and share this data with the relevant NPO for campaign analysis and donor stewardship purposes.

Your Consent and Control. We share your information only with NPOs you specifically name in your crypto trust plan, whether as gift recipients or beneficiaries (including primary, backup, or second backup beneficiaries). There are two primary ways consent is obtained (1) if you use an NPO's referral link or discount code, you automatically consent to share basic metadata (name, email state, age) with that specific NPO for referral tracking purposes, (2) Sharing full Donor Data as described above requires your consent during the crypto trust planning process. You can:

• Authorize sharing your Donor Data with NPOs you include as beneficiaries in your crypto trust plan
• Opt out of data sharing at any time
• Withdraw consent for future data sharing

NPO Data Use Restrictions. NPOs that receive your information through our platform are contractually required to:

• Use your information solely for legitimate charitable purposes
• Implement appropriate security measures to protect your data
• Not sell, rent, or transfer your information to third parties
• Honor your opt-out requests
• Delete your information upon request or termination of their platform access

L. Sponsored Benefit and Member Organization Programs. When you access our Services through a benefit program sponsored by your employer, union, membership organization, financial institution partner, or similar entity (a "Sponsoring Organization"), we may share basic benefit utilization information with that Sponsoring Organization. This information may include your name, the date you activated your benefit or created your account, the type of crypto trust planning product you selected (such as a Will Product or Trust Product), and other mutually agreed information related to benefit program administration. Sponsoring Organizations use this information to administer their benefit programs, understand member or employee engagement with the benefit, measure program effectiveness, and fulfill their obligations to their members or employees. This data sharing is for benefit administration purposes and is not considered a "sale" of your personal information under applicable privacy laws, including the CCPA. This sharing only occurs when you access our Services through a sponsored benefit program and does not trigger opt-out rights under our "sale" provisions, though you retain all other privacy rights described in Section 7 of this policy. Sponsoring Organizations are responsible for providing appropriate notice to their members or employees about this data sharing and must maintain appropriate security measures to protect your information.

5. Online analytics and advertising.

As you use our Services, we and our service providers collect a variety of information through the use of "cookies" and similar technologies, such as tracking pixels, to understand how you navigate through and interact with our Services, to learn what content is popular, to enhance the Services and provide you with a more relevant and personalized experience, for authentication and advertising purposes, to save your preferences, and to collect certain usage, device and location information as described in the "Information we collect automatically" section above. We also use third-party services to send promotional emails to visitors to our website who may be interested in our products and services.

Online analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in the "Information we collect automatically" section above to help us analyze how users use the Services. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services on our behalf. If you'd like to opt out of Google Analytics, please use the Google Analytics Opt-Out Browser Add-on located here: https://tools.google.com/dlpage/gaoptout.

Online advertising

We strive to provide you with relevant, tailored advertising regarding our Services. We do not serve third-party advertisements to you while using our Services. However, we do work with online analytics and advertising partners to: (1) better understand the use of our Services so that we can improve our Services; and (2) deliver crypto trust fund advertisements that are more tailored to you both on our Services and on third-party Services.

To engage in these activities, our partners may place cookies, pixel tags, and similar technologies on our Services. For example, we may use tracking pixels from third parties such as Meta to collect information about your activities on our Services to provide you with more relevant advertising on other websites and social media platforms. These partners may use the information they collect to identify crypto trust fund products you might be interested in and to recognize your device to show you relevant advertisements. Additionally, we sometimes provide basic information we collect (such as email addresses) to service providers, who may "match" this information in de-identified form to cookies, mobile ad identifiers, and other proprietary IDs, to provide you with more relevant ads when you visit other online services.

We do not have access to, and this Privacy Policy does not govern, the use of cookies or other tracking technologies that may be placed on devices you use to access our Services by non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link or the Digital Advertising Alliance's Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs. For additional ways to opt-out of targeted advertising activities under applicable law, see the "Your rights and choices" section below.

Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Services.

6. Children's privacy.

Our services are intended for use only by those who are over 18 years of age. We do not direct crypto trust fund to children under the age of 18, and we do not knowingly collect or solicit information through the Services from any person under the age of 18. Our documents allow for you to enter information regarding your dependent children, but we don't collect that information without your direct consent to do so. We restrict use of any data you submit regarding your minor children to the specific business purpose of helping you create your crypto trust plan. We reserve the right to delete any information identified as having been provided through the Services from children under the age of 18 or about children under the age of 18 to the extent such information was not provided with the requisite consent.

7. Your rights and choices.

In addition to the other rights and choices described in this privacy policy, you have these rights and choices regarding your information:

Rights Regarding Your Information. Depending on your jurisdiction, you may have the right to make certain requests regarding your "personal information" or "personal data" and (as such terms are defined under applicable law, and collectively referred to herein as "personal information"). Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

You may also have the right to opt out of "sales" of your information and "sharing/use of your information for targeted advertising" as described below.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request.

If you would like further information regarding your legal rights or would like to exercise any of them, please email us at legal@trustsfunds.net or call us at 1 (866) 908-7878.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you. To exercise such an appeal right, email us at legal@trustsfunds.net.

Marketing Communications. You can unsubscribe from our marketing emails via the unsubscribe link provided in the emails or by emailing us at legal@trustsfunds.net. If you receive an unwanted SMS or text message from us, you may reply STOP to opt out of receiving future messages. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us, such as order confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you. We will not disclose mobile phone numbers collected solely through our SMS text programs to unaffiliated third parties for their marketing purposes.

Notice of Right to Opt-Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes. Depending on your jurisdiction, you may also have the right to opt out of "sales" of your information and "sharing/use of your information for targeted advertising."

As explained in the "How we disclose your information" section above, we sometimes disclose information to unaffiliated third-party business partners we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a "sale" under applicable laws.

We also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services or use analytics partners to assist us in analyzing use of our services and our user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a "sale" of personal information under applicable law, or, the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of the disclosure of your information for purposes that could be considered "sales" for those third parties' own commercial purposes, or "sharing" for purposes of targeted advertising, please use the privacy settings tool accessible via the cookie icon on our website, or, if you are using our mobile application, navigate to the "Do Not Sell or Share My Personal Information" toggle in the settings menu.

Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

NPO Platform Opt-Out Rights. You have specific rights regarding data sharing through our NPO Platform:

• Granular Control: You can opt out of data sharing with specific NPOs while maintaining sharing with others
• Referral Tracking Opt-Out: You can opt out of referral link tracking and UTM data collection
• Campaign Data Opt-Out: Premium and Enterprise tier data sharing can be limited to basic information only
• Complete NPO Opt-Out: You can opt out of all NPO Platform data sharing while maintaining your charitable gift designations

To exercise these rights, contact us at legal@trustsfunds.net or use your account privacy settings.

Notice of Financial Incentives. We may offer opportunities to receive certain benefits, such as discounts, promotional entries, or other similar incentives, which may require the provision of personal information, such as answering surveys or providing additional feedback or information. Such opportunities could be considered a financial incentive under applicable law (each, an "Incentive Program"). Your participation in Incentive Programs is purely voluntary. When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and may revoke your participation depending on the Incentive Program. The monetary value of the reward, discount, or incentive is a reasonable approximation of the monetary value of participation in the Incentive Program. We have arrived at this estimate based on consideration of multiple factors, including the following: (1) revenue generated by crypto trust fund in connection with the Incentive Program; (2) expenses incurred by crypto trust fund in operating the Incentive Program; and (3) improvement of products and services based on information obtained through the Incentive Program.

8. Notice to CA residents.

This section supplements our privacy policy with additional information for California residents about our information collection and use practices as required by the California Consumer Privacy Act, as amended ("CCPA"). In this section, the terms "personal information" and "sensitive personal information" have the meaning set forth in the CCPA.

Under the CCPA, "sharing" is defined as the targeting of advertising to a consumer based on that consumer's personal information obtained from their activity across distinct online services, and "selling" is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We engage in activities that constitute both a "sale" and "sharing" of personal information under these definitions. Specifically, as described in our "Business Partner Programs" section, we sell personal information to our business partners for compensation. We also share personal information with our advertising partners for cross-context behavioral advertising. You have the right to opt out of these sales and sharing activities by using the privacy settings tool accessible via the cookie icon on our website.

NPO Platform as "Sales" Under CCPA. Our NPO Platform data sharing may constitute "sales" of personal information under the California Consumer Privacy Act, as NPOs pay subscription fees for access to donor data. California residents have the right to opt out of these sales using the privacy settings tool accessible via the cookie icon on our website.

Referral Tracking as "Sharing." The collection and sharing of UTM data and referral tracking information for NPO campaign analysis may constitute "sharing" for targeted advertising purposes under CCPA. You can opt out of this sharing through your privacy settings.

The following chart provides information about our practices in the 12 months leading up to the effective date of this privacy policy in relation to the categories of personal information that we collected from California residents generally, the purposes for which we use the information, the categories of third parties to whom we disclose the information for business purposes, and the categories of third parties to whom we "share" or "sell" the information for advertising/analytics purposes.

For more information about each category, purpose of use, and the third parties to which we disclose information, please see the "Information we collect," "How we use your information," and "How we disclose your information" sections above.

Your Choices Regarding "Sharing" and "Selling." You have the right to opt out of crypto trust fund's sale/sharing of your personal information for purposes of online analytics and advertising by clicking the using the privacy settings tool accessible via the cookie icon on our website or by using the "Do Not Sell or Share My Personal Information" toggle within our mobile application's settings menu. Please note that we will also honor browser-based opt out signals (such as the Global Privacy Control) in accordance with our legal obligations.

To opt out of the offline disclosure of your information to third parties for these purposes and as otherwise explained herein, please email us at optout@trustsfunds.net.

Other CCPA and California rights.

Right to Limit. The CCPA allows you to limit the use or disclosure of your "sensitive personal information" (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.

Personal Information rights. Please see the "Your rights and choices" section above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

Retention of Your Personal Information. Please see the "Retention" section below.

Do Not Track ("DNT"). DNT is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser-based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. Learn more about Do Not Track. Please note that Do Not Track is a different mechanism that the legally-recognized browser-based opt out preference signal mentioned above.

California "Shine the Light" disclosure. The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. You can exercise your right to opt out by emailing us optout@trustsfunds.net.

9. Transmission of information to other countries.

Please note that crypto trust fund is located in the United States and provides the Services, and processes your data, in the United States. crypto trust fund may subcontract the processing of your data to, or otherwise disclose your data to, service providers and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. By submitting your information to us you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence including but not necessarily limited to the United States.

10. Securing and storing your data.

We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. You must keep your password confidential, and you should always log out and close your browser when you finish your session.

Our service is built on top of Amazon Web Services (AWS). Amazon maintains ISO 27001 and SAS70 Type II certification for the AWS infrastructure, and has years of experience managing and securing large-scale data centers. More details about AWS security are available here.

However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information.

11. Retention of your information.

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this privacy policy. For example, data from support interactions like chat transcripts may be retained for a shorter period than the core information required to maintain your crypto trust plan. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

12. Employee and Applicant Privacy.

To learn how we collect and use employee and/or applicant data, please review our Employee and Applicant privacy policy.

13. Policy modification.

From time to time we may change or update this privacy policy to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will post all updates here, and we may provide additional notice through the Services or contact you through other methods to alert you of material changes to this policy, in accordance with applicable legal requirements.

14. How to contact us.

Any questions you have regarding this policy should be directed to: legal@trustsfunds.net.