⚠️ Draft for attorney review. Not legal advice. A privacy policy must accurately describe your actual practices — have counsel and your technical team confirm every commitment below (especially the "we do not sell" statement and the data-minimization claims) reflects what the Platform and its verticals actually do before publishing.

Our Promise

Most platforms treat your personal information as inventory — something to package and sell. We are built the other way around.

Within the NewtekNation ecosystem, your data belongs to you. We are the ecosystem, not a data broker. The ecosystem sustains itself through its own mechanics — membership, tokens, ecosystem yield, and services — not by selling your personal information. Because of that, we do not sell your personal information, and the verticals that operate within the ecosystem are designed to hold only what they need to serve you — and often, they hold nothing personal at all.

This is one of the core CJI benefits of pledging: you gain access to the Library and the ecosystem without surrendering ownership of yourself.

1. Our Privacy Principles

1. You own your data. You may access, correct, export, or delete your personal information (Section 7).

2. We don’t sell it. We do not sell, rent, or trade your personal information, and we do not "share" it for cross-context behavioral advertising as those terms are defined under U.S. state privacy laws.

3. Data minimization. We collect only what we need to operate the Platform and honor your Pledge.

4. Vertical separation. Individual verticals within the ecosystem receive only the minimum information necessary for the specific service you use — and where a vertical does not need your personal information to function, it does not receive or store it.

5. No incentive to exploit. Because the ecosystem is self-funded, we have no business reason to monetize your identity. The incentive that drives data-selling elsewhere simply isn’t present here.

2. Information We Collect

We aim to collect as little as practical.

• You provide: account details (name, email, username, password, date of birth for age verification), profile information you choose to add, messages and content you post, and transaction or pledge records.

• Collected automatically: device and log data (IP address, browser/device type, access times), general usage data, and approximate location from IP. Precise location only with your device-level permission.

• From third parties (only if you choose): information from a social login or connected service you link, and from payment processors for transactions you initiate.

We do not seek sensitive personal information beyond what is necessary, and we do not knowingly collect information from anyone under 18 (Section 10).

3. How We Use Your Information

To: create and operate your account and Pledge; provide the Platform, the Library, and ecosystem services; process transactions you initiate; personalize your experience; communicate service notices and (with consent where required) optional updates; maintain safety, security, and integrity (fraud and abuse prevention, enforcement of the Terms); and comply with law. We may create aggregated, de-identified insights that do not identify you.

We do not use your personal information to build profiles for sale, or to power third-party advertising networks.

4. How We Share — and How We Don’t

We do not sell your personal information. Period. We share personal information only in these limited cases:

• Service providers performing functions on our behalf (hosting, payment processing, security, email delivery), under contracts that require them to protect it and use it only as we direct — never for their own purposes.

• At your direction — for example, information you choose to make visible to other Members through your privacy settings, or that you submit to complete a transaction you initiate.

• Legal reasons — when required by law, valid legal process, or to protect the rights, property, or safety of the ecosystem, our Members, or the public.

• Business transfer — in a merger, acquisition, reorganization, or asset transfer, your information may transfer as part of the transaction, subject to this Policy; we will provide notice and any choices required by law.

Nothing in this section authorizes the sale of your personal information.

5. The Ecosystem & the Verticals

NewTek-Connections is the forward-facing layer of the NewtekNation ecosystem. Each vertical (community, program, or service) operates on a need-to-know basis: it receives only the data required for what you asked it to do. Central ecosystem stewardship exists to serve you, not to centralize a sellable profile. Where ecosystem tokens, credits, or wallets are involved, on-network records are governed by their own published terms; we minimize the personal information tied to them.

6. Data Retention

We keep personal information only as long as needed to provide the service and meet legal obligations, then delete or de-identify it:

• Account data: life of the account, plus a short window after a deletion request.

• Transaction records: as required for financial and legal compliance.

• Communications: a limited period after your last activity, unless law requires longer.

• Automatically collected data: a limited period for security and analytics.

7. Your Rights & Choices

Regardless of where you live, we offer every Member the ability to:

• Access the personal information we hold about you;

• Correct inaccurate or incomplete information;

• Delete your personal information (subject to limited legal exceptions);

• Port a copy of your data in a portable format;

• Opt out of optional communications at any time;

• Restrict or object to certain processing, and withdraw consent where processing is consent-based.

To exercise any right, contact us (Section 12). We will respond within the time required by applicable law (generally within 30–45 days).

8. Cookies & Tracking

We use essential cookies (authentication, security, session) and limited functional/performance cookies to operate and improve the Platform. We do not rely on advertising cookies to sell or share your information for cross-context behavioral advertising. You can manage cookies through your browser; disabling essential cookies may break core functionality.

9. Security

We use industry-standard safeguards — encryption in transit (TLS) and at rest, secure password hashing, access controls, monitoring, and regular assessments. No system is perfectly secure, so we cannot guarantee absolute security, but we treat your data as something to protect, not to trade.

10. Children’s Privacy

The Platform is for adults 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn we have, we will delete it promptly. Contact us if you believe a minor has provided us information.

11. International Transfers

We operate from the United States; if you access the Platform from elsewhere, your information may be processed in the U.S. By using the Platform you consent to this transfer, subject to this Policy.

12. Your State & Regional Rights

• California (CCPA/CPRA): You have rights to know, delete, correct, and to opt out of "sale" or "sharing." We do not sell or share your personal information, so there is nothing to opt out of — but you retain every other right, and we will not discriminate against you for exercising it.

• Other U.S. states (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others): you have comparable rights; contact us to exercise them.

• EU/UK (GDPR): you have rights of access, rectification, erasure, restriction, objection, and portability, and may withdraw consent at any time.

13. Changes to This Policy

We may update this Policy to reflect changes in practices or law. We will post the updated Policy and revise the "Last Updated" date, and provide additional notice for material changes. Continued use after an update constitutes acceptance.

14. Contact Us

NewTek-Connections (operated under license from NewtekNation)

Privacy inquiries: [privacy@newtek-connections.com]

General: [support@newtek-connections.com] · Web: [www.newtek-connections.com]

BY PLEDGING OR USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY. YOUR DATA REMAINS YOURS — WE ARE THE ECOSYSTEM, NOT THE MARKETPLACE FOR YOUR IDENTITY.

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