Currently completing registration with the SEC as a Registered Investment Advisor (RIA), with a fiduciary and legal responsibility to act in our clients' best interest.

PALUS FINANCE, INC. — PRIVACY POLICY

Effective Date: February 10, 2026

Last Updated: February 10, 2026

1. INTRODUCTION

This Privacy Policy ("Policy") describes how Palus Finance, Inc., a Delaware corporation ("Palus," "Company," "we," "us," or "our"), collects, uses, shares, and protects information in connection with the Palus platform, including any associated websites, mobile applications, and related services (collectively, the "Platform").

By accessing or using the Platform, you agree to the collection and use of your information as described in this Policy. If you do not agree, you should not use the Platform. This Policy is incorporated into and subject to our Terms of Service.

The Platform is currently in a closed beta phase. This Policy may be updated materially as the Platform evolves, and we encourage you to review it periodically.

2. INFORMATION WE COLLECT

2.1 Information You Provide

We collect information that you provide directly to us, including:

  • Account information: Name, email address, phone number, and other details provided during registration.
  • Identity verification information: Government-issued identification, proof of address, date of birth, taxpayer identification numbers, and other documentation required for Know Your Customer ("KYC") or Know Your Business ("KYB") procedures, which may be collected by us or by our third-party verification partners on our behalf.
  • Business information: If you are using the Platform on behalf of a business entity, we may collect information about that entity, including its legal name, registration details, ownership structure, and authorized representatives.
  • Communications: Information you provide when you contact us for support or otherwise communicate with us.

2.2 Information Collected Automatically

When you use the Platform, we may automatically collect certain information, including:

  • Device and access information: IP address, browser type, operating system, device identifiers, and general location information.
  • Usage information: Pages or features accessed, actions taken on the Platform, timestamps, and referring URLs.
  • Transaction information: Records of your purchases, sales, withdrawals, wallet addresses, and other activity on the Platform.

We do not currently use third-party analytics or tracking tools, but may do so in the future. If we do, this Policy will be updated accordingly.

2.3 Information from Third Parties

We may receive information about you from our third-party service providers, including identity verification partners and payment processors, in connection with the services they provide to us.

2.4 Blockchain Data

Transactions on the Platform are recorded on the Solana blockchain. Blockchain data, including wallet addresses and transaction details, is publicly accessible and is not within our control once recorded.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

  • Providing the Platform: To operate, maintain, and improve the Platform and to process your transactions.
  • Identity verification: To verify your identity and comply with applicable KYC/KYB and anti-money laundering requirements.
  • Security and fraud prevention: To detect, investigate, and prevent fraud, unauthorized access, and other illegal or prohibited activities, including in connection with the Token clawback mechanism described in our Terms of Service.
  • Communications: To send you important information about your account, transactions, changes to the Platform, or changes to our terms and policies. These are transactional and operational communications, not marketing.
  • Compliance: To comply with applicable legal and regulatory obligations, respond to legal process, and cooperate with governmental authorities.
  • Improvement and development: To understand how Users interact with the Platform and to develop new features, products, or services.
  • Enforcement: To enforce our Terms of Service and protect the rights, property, and safety of Palus, our Users, and the public.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information in the following circumstances:

  • Service providers: With third-party vendors and partners who perform services on our behalf, including identity verification, payment processing, cloud hosting, and infrastructure services. These providers are contractually obligated to use your information only for the purposes of providing services to us.
  • Legal and regulatory: With law enforcement, regulators, courts, or other governmental authorities when we believe disclosure is required by applicable law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect the rights, property, or safety of Palus, our Users, or the public.
  • Fraud and security: With third parties as necessary to investigate, prevent, or take action regarding suspected fraud, security incidents, or violations of our Terms of Service.
  • Business transfers: In connection with a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity.
  • With your consent: In any other circumstances where you have provided your consent.

5. DATA SECURITY

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, and destruction. Our Platform infrastructure is hosted with industry-standard cloud providers using standard security practices.

However, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your information, and you use the Platform at your own risk.

6. DATA RETENTION

We retain your personal information for as long as your account is active or as reasonably necessary to provide the Platform to you. We may also retain your information after account closure as necessary to:

  • Comply with applicable legal, regulatory, or tax obligations;
  • Resolve disputes and enforce our agreements;
  • Maintain transaction records as required by law; and
  • Prevent fraud and protect the security of the Platform.

When your information is no longer needed for any of these purposes, we will delete or de-identify it in accordance with our internal data management practices.

7. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have certain rights with respect to your personal information, which may include the right to access, correct, delete, or port your data, or to object to or restrict certain processing. To exercise any such rights, please contact us using the information in Section 11 below.

We will respond to requests in accordance with applicable law. Please note that certain information may be exempt from such requests, including information we are required to retain for legal or compliance purposes and transaction records recorded on the blockchain, which cannot be modified or deleted.

8. COOKIES AND TRACKING

The Platform does not currently use cookies beyond those strictly necessary for authentication and session management. If we introduce additional cookies or tracking technologies in the future, we will update this Policy and provide any notices required by applicable law.

9. CHILDREN'S PRIVACY

The Platform is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal information from a minor, we will take steps to delete that information promptly.

10. CHANGES TO THIS POLICY

We may update this Policy from time to time. When we make material changes, we will notify you through the Platform or by other reasonable means. Your continued use of the Platform after any changes to this Policy constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

11. CONTACT US

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

Palus Finance, Inc.
251 Little Falls Drive
Wilmington, DE 19808
info@palus.finance

BY USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.