Digital Asset Academy, LLC   Privacy Policy

Effective Date: April 1, 2025

This Privacy Policy (the “Policy”) describes the methods by which Digital Asset Academy, LLC (hereinafter referred to as “Digital Asset Academy” or the “Company”) collects, maintains, discloses, and processes your personal information to service your account with Digital Asset Academy, and with respect to visitors to the assetacademy.ai website (the “Site”).

Personally Identifiable Information

For this Policy, Personally Identifiable information (“PII”) means information related to an individual that is collected or maintained for business purposes and by which the individual can be identified (including, but not limited to: name, address, phone number and email address). Information by which an individual cannot be identified (examples: anonymous, de-identified, or aggregate information) is not considered PII and therefore is not subject to this Policy.

Personal Information Collected by Digital Asset Academy

Digital Asset Academy collects basic user profile information from visitors to the Site, such as certain PII noted above. Also, in connection with providing service for your account, the Company may also receive non-public PII from you, and from various sources, including, but not limited to: 1) Your account applications or forms; 2) Information from third-party data sources; and 3) Other sources with your consent.

How Digital Asset Academy Uses PII

Digital Asset Academy may use PII in relation to service offerings and to complete your purchase requests on the Site. Digital Asset Academy may email visitors regarding purchase opportunities or information related to the subject matter of the Site. The Company may also use PII to contact you in response to specific inquiries, or to provide requested information.

How Digital Asset Academy Protects PPI

Digital Asset Academy implements and maintains various measures intended to protect PII. The Company restricts access to PII to those who require it within the Company to develop, support, offer, and deliver products and services to you, and to operate the Company’s business. PII is only accessible to employees of the Company or affiliated entities that have password protected access. Sensitive information, such as credit card numbers, is secured by encryption protocols to protect the information sent over the Internet. While Digital Asset Academy takes commercially reasonable measures to maintain a secure website, electronic communications and databases are subject to errors, tampering and break-ins, and the Company cannot guarantee or warrant that such events will not occur, and the Company will not be liable to you for any such occurrences.

Your Digital Privacy

When you interact with Digital Asset Academy by using our websites, online services, applications, or other Company properties that are owned and controlled by the Company (“Digital Offering(s)“), or via electronic communications, Digital Asset Academy manages PII in accordance with the practices and methods described in this Policy.

When you use or interact with Digital Asset Academy via our Digital Offerings or interact with the Company via other forms of electronic communications, the Company (or service providers on the Company’s behalf) may collect technical and other information, including but not limited to: device type, browser type and internet protocol address. Digital Asset Academy may use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving the design and functionality of the Company’s Digital Offerings, and personalizing your experience.

Does  Digital Asset Academy Use Cookies?

No, Digital Asset Academy does not use cookies.

Connecting with the Company on Social Media Platforms

Digital Asset Academy may collect information you provide by interacting with the Company via social media, such as photographs. Any content you post, such as pictures, information, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to such platforms to better understand your rights and obligations in relation to such content.

Data Security

Digital Asset Academy has implemented measures designed to secure your PII from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your PII also depends on you. Where the Company has provided you with, or where you have selected, a password for access to certain parts of the Company’s Digital Offerings, you are responsible for keeping this password confidential. Digital Asset Academy asks that you not share your password with other persons.

The transmission of information via the Internet is not completely secure. Although Digital Asset Academy does its best to protect your personal information, the Company cannot guarantee the security of your personal information transmitted to the Company’s Digital Offerings. Any transmission of personal information is at your own risk. Digital Asset Academy is not responsible for circumvention of any privacy settings or security measures contained in the Digital Offerings.

Third-Party Websites, Online Services and Content

Digital Asset Academy’s Digital Offerings may contain links to third-party websites and online services (for example, social media platforms) and may include embedded content that is hosted by third parties. This Policy does not address the privacy, security, cookie policy and settings, or other practices of the third parties that provide such websites, online services, or content, and Digital Asset Academy is not responsible for the privacy practices or the content of these other websites, online services, or content providers. If you use a link to another website or online service or view third-party content (for example, an embedded video), please consult the privacy policy for that website or online service for additional information on their privacy practices and advertising opt-out instructions.

Children’s Privacy

In general, Digital Asset Academy ‘s Digital Offerings are not directed to individuals under the age of eighteen (18). The Company does not intentionally collect information on the Company’s websites from persons that the Company knows are under the age of eighteen (18), and Digital Asset Academy requests that such persons not provide personal information through the Company’s Digital Offerings. If the Company provides a Digital Offering that is intended to be used by individuals under the age of eighteen (18), it will have a separate privacy policy.

How Digital Asset Academy Shares Personal information

Under Federal law, the Company may share certain nonpublic personal information about you to offer you products and services, and for other purposes. The Company may share personal information that we collect about you with: 1) The Company’s corporate affiliates to provide services to you and for other business purposes; 2) Unaffiliated service providers (for example, entities that may provide services at the Company’s direction); 3) Government agencies, other regulatory bodies, and law enforcement officials; 4) Other organizations as permitted or required by law (for example, to respond to a subpoena); or 5) In connection with corporate business transactions, such as a merger or sale of a business. Digital Asset Academy does not share or sell personal information about the Company’s customers with unaffiliated third parties for use in marketing their products and services.

Digital Asset Academy’s service providers are obligated to keep the PII the Company shares with such service providers confidential and use it only to provide services as directed by the Company.

You Have the Right to Limit and may Opt-Out of Sharing

You have the right to limit some, though not all, sharing of your personal information. You may have the right to opt-out of certain types of sharing, as examples: 1) If in the future the Company shares your personal information with unaffiliated third parties for their marketing purposes. As noted above the Company does not share or sell personal information about the Company’s customers with unaffiliated third parties for use in marketing their products and services; 2) If we share your personal financial information with non-affiliated financial institutions for joint marketing purposes (unless the third party is under a contractual agreement to market only Digital Asset Academy products and services); or 3) If we share your personal information with our corporate affiliates for marketing purposes.

How to Opt-Out

If you do not want the Company to share your personal information for the reasons outlined above, you may opt out by emailing the Company at info@assetacademy.ai. Please include your full name, address, and account number (if applicable) in your request. In addition, if you opt-out: 1) Your choice will apply to all your accounts with Digital Asset Academy unless you specify otherwise; 2) If you are a joint account holder, any account holder may opt out on behalf of all account holders; and 3) The Company will continue to share information as permitted by law. The opt-out request will be in effect until you notify the Company otherwise in writing.

How can PII be Updated or Corrected?

You may contact Digital Asset Academy to update Personally Identifiable Information or to correct any inaccuracies by emailing the Company at info@assetacademy.ai.

Can Personally Identifiable Information be Deleted or Deactivated?

Digital Asset Academy provides you with a mechanism to delete/deactivate PII from the Site’s database by contacting info@assetacademy.ai. However, because of backups and records of deletions, it may be impossible to delete personal information without retaining some residual information.

Opt-Out from Receiving Unsolicited Information and Contacting Digital Asset Academy

You may opt-out of receiving unsolicited information from or being contacted by Digital Asset Academy or affiliated entities by contacting the Company at info@assetacademy.ai. If you have any questions regarding this Privacy Policy, please contact Digital Asset Academy at info@assetacademy.ai.

Former Customers

If you are a former customer, this Policy also applies to you; the Company treats your information the same as for current customers.

Revisions to Privacy Policy

Digital Asset Academy reviews this Privacy Policy at a minimum annually and revises the Policy from time to time as needed by posting a revised version and updating the Effective Date (the “Effective Date”), upon which the revised version will be effective. Your continued use of the Company’s services after the Effective Date constitutes your consent to any changes to the Policy as of the Effective Date.

Your State Privacy Rights

Some states (as examples, California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia) may provide, either currently or in the future, that their state residents have the rights to: 1) Confirm whether the Company processes their personal information; 2) Access and delete certain personal information, 3) Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah); 4) Control data portability; 5) Opt-out of personal data processing for: targeted advertising (excluding Iowa); sales; or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah); and 6) Either limit (opt-out of) or require consent to process sensitive personal data.

These rights may vary by state; for additional information on certain State specific rights, please see Exhibit A – State Related Privacy Policies attached hereto.

EXHIBIT A

STATE RELATED PRIVACY POLICIES

Additional Information for Nevada Residents

Nevada provides state residents with a limited right to opt-out of the sale of certain personal information. Residents that want to exercise this opt-out right may submit a request to: info@assetacademy.ai. Note that the Company does not currently sell data triggering this Nevada opt-out provision.

Additional Information for California Residents

The following information is provided pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively hereinafter the “CCPA”) and applies to the personal information and your relationship(s) with Digital Asset Academy that are subject to the provisions of the CCPA. As used herein, “personal information” means information that meets the definition of “personal information” as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA.

Digital Asset Academy and the CCPA

Depending on your relationship and interactions with Digital Asset Academy and the products and services provided to you by the Company, some or all of the personal information that the Company collects or maintains is covered by one or more of the exemptions described below (see section below entitled “CCPA Exemptions”). As a result, in some cases, Digital Asset Academy may not an obligation under the CCPA to accept any CCPA requests, and in other instances, the Company may not have an obligation to honor a particular CCPA request, due to the nature of the personal information that Digital Asset Academy collects or maintains.

The CCPA gives certain rights to California residents and imposes certain obligations on businesses subject to the CCPA. As required by the CCPA, following is a description of certain rights that California residents generally have under the CCPA. Based on your relationship with Digital Asset Academy, some, or all of, the rights described below may not apply to you. As used below, a “consumer” means a resident of the State of California and a “covered business” means a business subject to the CCPA.

Right to Know/Right to Access. A consumer has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that such covered business disclose to that consumer the following: 1) Categories of personal information the business has collected about that consumer; 2) Categories of sources from which personal information is collected; 3) Business or commercial purpose for collecting, selling or sharing (if applicable) personal information; 4) Categories of third parties to whom the covered business discloses personal information; and 5) Specific pieces of personal information that the covered business has collected about that consumer. Such disclosures are not required to include any information about activity that occurred prior to January 1, 2022.

Note that a covered business is not required to honor more than two (2) of these requests from the same consumer during any twelve (12) month period.

• Right to Delete. A consumer has the right to request that a covered business delete any personal information that the business has collected from the consumer, subject to certain exceptions.
• Right to Correct. A consumer has the right to request that a covered business correct inaccurate personal information that a business maintains about a consumer.
• Right to Opt-Out of Sale/ Sharing. If a covered business sells or shares personal information, a consumer has the right to opt-out of the sale or sharing of their personal information by the business.
• Right to Limit Use and Disclosure of Sensitive Personal Information. If a covered business uses or discloses sensitive personal information for reasons other than those set forth in the CCPA, a consumer has the right to limit the use or disclosure of sensitive personal information by the business.
• Non-Discrimination. A covered business cannot discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.

Categories of Personal Information that may be Collected about You

• Personal identifiers, including, but not limited to: your name, postal address, email address, online identifier, internet protocol address, account name, or other similar identifiers
• Information covered by California’s records destruction law (California Civil Code 1798.80)
• Characteristics of protected classifications under California or US federal law
• Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet/electronic network interactions, including, but not limited to: browsing history, search history, and information regarding your interactions with the Company’s Digital Offerings or advertisements
• Audio, electronic, visual, and similar data
• Inferences drawn from any of the information listed above to create a profile about you
• Sensitive personal information including, but not limited to: Social Security Number, account log-in, password or credentials allowing access to your account(s) or to the Company’s Digital Offerings

The retention periods for data elements within each category vary depending on the nature of the data element and the purposes for which it is collected and used. The Company’s retention period for the data elements within each category is set based on the following criteria: (1) Length of time that data is needed for the purposes for which it was created or collected; (2) Length of time data is needed for other operational or record retention purposes; (3) Length of time data is needed in connection with legal, compliance and regulatory requirements; legal defense purposes and to comply with legal holds; (4) How data is stored; (5) Whether data is needed for security purposes and fraud prevention; and (6) Whether data is needed to ensure continuity of the Company’s products and services.

Categories of Sources from which Personal Information is Collected

In addition to the sources described in the section above titled “Personal Information Collected by Digital Asset Academy”, depending on the nature of your relationship and interactions with the Company, and on products and services that Digital Asset Academy provides to you, the Company may obtain personal information from the following sources: 1) You or your representative, such as when using the Company’s products, services or Digital Offerings; when interacting with the Company or any of the Company’s service providers regarding products, services or Digital Offerings; or when otherwise communicating with the Company; 2) Providers of publicly available information; 3) Third parties that provide products or services to you through your relationship with the Company; 4) Third parties that perform services for the Company or on the Company’s behalf; 5) Other third-party sources, including government sources, data brokers and social networks; or 6) Automatically, via technologies when you interact with the Company’s Digital Offerings or electronic communications.

Why Digital Asset Academy Collects Personal information

The section above entitled “How Digital Asset Academy Uses PII” provides a description of some of the business purposes for which Digital Asset Academy collects personal information. In addition to those purposes described above, below are additional business purposes for which the Company collects personal information:

• To provide you with information about products and services that may interest you
• To maintain the accuracy and integrity of the Company’s records
• For marketing and communication purposes
• For reporting and analytical purposes
• For personalizing your interactions and experiences with Digital Asset Academy
• For training and quality-control measures
• To verify your identity
• To protect against malicious, fraudulent, or illegal activity
• For business analysis, planning, and reporting
• For customer education
• For effectiveness measurement

Categories of Personal Information Disclosed for Business Purposes

Depending on the nature of your relationship and your interactions with Digital Asset Academy, and on the products and services that the Company provides to you, Digital Asset Academy discloses to third parties for business purposes the personal information that is encompassed by one or more of the categories described in the “Categories of Personal Information that may be Collected about You” section above, with the categories of third parties listed in the section entitled “Categories of Sources from which Personal Information is Collected” above.

Selling/Sharing of Personal Information

In the twelve (12) months preceding the date of this policy, Digital Asset Academy has not “sold” and/or “shared” personal information for “cross context behavioral advertising” (as defined in the CCPA) with respect to California residents covered by the CCPA. Digital Asset Academy does not knowingly “sell” or “share” for “cross-context behavioral advertising” personal information of minors under sixteen (16) years of age.

CCPA Exemptions

There are certain types of personal information collected or maintained by covered businesses that are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases no obligations, under the CCPA with regard to the following types of personal information: 1) Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act, (Public Law 106-102), and implementing regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 [commencing with Section 4050] of the California Financial Code); and 2) Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate pursuant to the Health Insurance Portability and Accountability Act of 1996.

In addition, some businesses are not subject to the CCPA, such as:

• A business that does not do business in the State of California
• A business that is not organized or operated for the profit or financial benefit of its shareholders or other owners
• A business that does not determine the purposes and means of the processing of consumers’ personal information
• A business that has annual gross revenue of $25,000,000 or less

Furthermore, under the CCPA there are a number of instances under which a covered business under the CCPA may refuse to honor a CCPA request to delete a consumer’s personal information and is allowed to continue to maintain the personal information. Some examples include instances where retention of the personal information is necessary to: 1) Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer or reasonably anticipated within the context of the covered business’ ongoing business relationship with the consumer, or otherwise perform a contract between the Company and the consumer; 2) Help to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for those purposes; 3) Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law; 3) Debugging to identify and repair errors that impair existing intended functionality; 4) Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information; or 5) Comply with a legal obligation.

The description of the CCPA set forth is a summary of only certain aspects of the CCPA and is not, and should not be considered, a complete description of the CCPA. In addition to the descriptions above, the CCPA includes other exemptions that apply to certain types of personal information and businesses, as well as additional instances in which a covered business is not required to honor a consumer’s request to delete personal information.