Privacy and Cookie Policy

1. Company and privacy contact

Schwarzman LLC
190 Elgin Avenue
Grand Cayman
Cayman Islands
Registration Number CR-5512

Privacy contact: through the support function in the SCHWARZMAN application after sign-in.

2. Scope

This Policy applies to personal information processed by Schwarzman LLC.

Independent card issuers, KYC/KYB providers, payment processors, wallet or custody providers, conversion providers, settlement providers and other third-party providers may process personal information for the services they provide under their own privacy notices and legal obligations.

3. Information we collect

Depending on how you interact with SCHWARZMAN, we may collect or receive the following categories of information.

A. Identification and contact information
This may include your name, date of birth, email address, telephone number, residential or business address, nationality, country of residence and account identifiers.

B. Business-account information
For business accounts, this may include legal entity name, incorporation details, registered address, business activity, directors, managers, authorized representatives, beneficial owners, control persons and corporate verification documents.

C. Verification, compliance and risk information
Where applicable, this may include identity-document information, verification status, KYC/KYB results, sanctions and politically exposed person screening results, fraud-risk indicators, source-of-funds or source-of-wealth information, transaction-monitoring information, wallet-risk or blockchain-analytics information and compliance correspondence.

Some verification and compliance information may be collected directly by an independent service provider and may not be stored by Schwarzman LLC.

D. Membership, account and transaction information
This may include membership status, billing history, account activity, card-related status information, supported digital-asset deposits, wallet addresses, transaction identifiers, transaction amounts and status, cashback, SHOP Token activity, holding-reward selections, referral information and support history.

E. Device, website and application information
This may include IP address, device type, browser, operating system, application version, approximate location derived from network information, login events, security events, cookie or similar identifiers, pages or screens viewed and interactions with the website or application.

F. Communications
We may retain communications sent through email, in-app support, complaint channels or other official channels.

G. Marketing and analytics information
Subject to applicable consent and opt-out requirements, this may include marketing preferences, campaign source, referral source, advertising interactions, waitlist activity and website conversion events.

4. Sources of information

We may collect personal information:

• directly from you;
• automatically from your device or browser;
• from the SCHWARZMAN application;
• from identity-verification and compliance providers;
• from card and payment providers;
• from wallet, custody, conversion or settlement providers;
• from fraud-prevention or cybersecurity providers;
• from blockchain analytics providers;
• through referral links;
• from marketing and analytics providers; and
• from public or legally available sources where permitted.

5. How we use information

We may use personal information to:

• create and administer accounts;
• provide and manage the SCHWARZMAN membership;
• process or administer subscription billing;
• provide website and application functionality;
• support card-program functionality;
• display and administer transaction information;
• facilitate supported digital-asset functionality;
• calculate and administer cashback and rewards;
• administer referrals;
• verify identity and business information;
• conduct KYC/KYB, AML and sanctions screening;
• prevent fraud, abuse and account takeover;
• conduct blockchain and wallet-risk analysis;
• respond to support requests and complaints;
• maintain security;
• investigate disputes;
• comply with legal obligations;
• enforce agreements and policies;
• maintain business, compliance and accounting records;
• improve products and user experience;
• measure website and application performance;
• send operational communications; and
• send marketing communications where permitted.

6. How we disclose information

We may disclose personal information to categories of recipients including:

• card issuers and card-program providers;
• BIN sponsors;
• payment processors;
• KYC/KYB and identity-verification providers;
• AML, sanctions and fraud-screening providers;
• wallet, key-management or custody-infrastructure providers;
• digital-asset conversion and liquidity providers;
• settlement providers;
• blockchain analytics providers;
• cloud and hosting providers;
• email and communications providers;
• customer-support providers;
• cybersecurity providers;
• analytics providers;
• advertising providers where enabled;
• professional advisers, auditors and insurers;
• corporate transaction counterparties; and
• governmental, regulatory or law-enforcement authorities where legally required.

A provider may act as a service provider or processor for Schwarzman LLC, or as an independent business or controller for its own legal and regulatory purposes, depending on the service and applicable law.

7. Public blockchains

Public blockchains are designed to record information publicly and persistently. Wallet addresses, transaction hashes, token transfers and other on-chain data may be publicly visible and may be impossible for Schwarzman LLC to alter or delete.

SCHWARZMAN and its providers may use blockchain analytics for sanctions compliance, fraud prevention, transaction monitoring and wallet-risk assessment.

8. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including providing services, maintaining security, resolving disputes, preventing fraud, satisfying legal, accounting or compliance obligations and establishing or defending legal claims.

Retention periods vary according to the category of information, the service involved, the account relationship and applicable legal or provider requirements. Certain transaction, verification, compliance, fraud-prevention and legal records may be retained after an account is closed.

9. Security

We use administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration or loss.

No electronic system can guarantee absolute security. Users remain responsible for protecting their own credentials, devices and authentication factors.

10. International processing

Schwarzman LLC is established in the United States and works with service providers that may operate in the United States and other countries. Personal information may therefore be processed outside your state, province or country of residence.

Where applicable law requires a particular transfer mechanism or safeguard, Schwarzman LLC and/or the relevant provider will apply the mechanism applicable to their respective processing.

11. Children

SCHWARZMAN is not intended for persons under 18 and does not permit minors to open a SCHWARZMAN account.

If we learn that personal information was collected from a person who is not eligible to use SCHWARZMAN, we may restrict the account and handle the information as required by applicable law.

12. Marketing communications

Where permitted, SCHWARZMAN may send product updates, launch notices or promotional communications.

Marketing emails include an unsubscribe method where required. Operational, security, legal, compliance, billing and account communications are not marketing communications and may continue where necessary.

13. Cookies and similar technologies

SCHWARZMAN may use cookies, pixels, SDKs, local storage and similar technologies for website operation, security, preferences, analytics, attribution and advertising.

Strictly necessary technologies support core website operation and security.

SCHWARZMAN also uses privacy-focused first-party analytics to understand website performance and usage. The website is configured not to use those first-party analytics to store IP addresses or share first-party analytics data with advertising networks.

14. Meta Pixel and advertising technology

With the user's applicable consent or other legally valid permission, SCHWARZMAN may use the Meta Pixel or similar advertising technology to measure advertising performance, attribute conversions and build or measure advertising audiences.

This may involve transmitting website events and technical identifiers to Meta Platforms and its affiliates or another advertising provider.

The Meta Pixel on the SCHWARZMAN website is configured not to load before the required marketing-cookie consent is given through the website's cookie controls.

Users can change available cookie choices through the “Cookie settings” control in the website footer.

15. Sale, sharing and targeted advertising

Schwarzman LLC does not sell personal information for monetary consideration as part of its ordinary business model.

Some U.S. state privacy laws define “sale”, “sharing” or targeted advertising broadly and may treat certain advertising disclosures as covered activity even where no money is paid for the data.

Where an applicable law grants an opt-out right for sale, sharing or targeted advertising, SCHWARZMAN honors that right through the privacy and cookie controls made available for the relevant user and through any legally required universal opt-out mechanism.

16. Global Privacy Control

Where an applicable law requires recognition of a qualifying universal opt-out mechanism, SCHWARZMAN treats a valid Global Privacy Control signal in accordance with that law.

The effect of the signal depends on the applicable law and the information available to associate the signal with the relevant browser, device or account.

17. Privacy rights

Depending on your location and applicable law, you may have rights to:

• confirm whether we process personal information about you;
• access personal information;
• correct inaccurate personal information;
• delete certain personal information;
• receive a portable copy of certain personal information;
• opt out of certain sale, sharing or targeted-advertising processing;
• limit certain uses of sensitive personal information; and
• appeal certain decisions on privacy requests.

To submit a privacy request, use the support function in the SCHWARZMAN application after sign-in.

We may need to verify your identity before completing a request. Authorized-agent requests may require proof of authority. Some information may be exempt from a request because of legal, security, fraud-prevention, financial-crime, recordkeeping or other lawful requirements.

SCHWARZMAN does not discriminate against a user for exercising a privacy right protected by applicable law.

18. California privacy rights

If and to the extent the California Consumer Privacy Act, as amended, applies to Schwarzman LLC and to your information, California residents may have rights including the right to know, access, correct and delete personal information; the right to opt out of sale or sharing; the right to limit certain uses of sensitive personal information; and the right to non-discrimination.

The categories of personal information Schwarzman LLC may collect are described in Section 3. The sources are described in Section 4, the purposes in Section 5 and the categories of recipients in Section 6.

Schwarzman LLC does not sell personal information for monetary consideration as part of its ordinary business model. Where advertising technology constitutes “sharing” under applicable California law, SCHWARZMAN provides and honors the legally required opt-out mechanisms, including qualifying Global Privacy Control signals.

19. Other U.S. state privacy rights

If another U.S. state comprehensive privacy law applies to Schwarzman LLC and to your information, residents of that state may exercise the rights granted by that law using the support function in the SCHWARZMAN application and the privacy controls made available on the website or application.

Where the applicable law provides a right to appeal a denied privacy request, you may submit an appeal by replying to the decision or by submitting a new support request in the SCHWARZMAN application with the subject line “Privacy Appeal”.

20. Legal requests

We may preserve, use or disclose personal information where reasonably necessary to comply with applicable law or valid legal process, meet sanctions or financial-crime obligations, protect users or third parties, investigate fraud or security incidents, enforce contractual rights, or establish, exercise or defend legal claims.

21. Corporate transactions

Personal information may be transferred in connection with a merger, financing, acquisition, restructuring, sale of assets or other corporate transaction, subject to applicable legal requirements.

22. Changes to this Policy

We may update this Policy as our services, providers, technology or legal obligations change. The current version is published on schwarzman.app. Where required, material changes will be communicated separately.

23. Contact

Privacy and cookie questions or requests:
Through the support function in the SCHWARZMAN application after sign-in.

Schwarzman LLC
190 Elgin Avenue
Grand Cayman
Cayman Islands