This Privacy Policy of Enine [1E9 Advisors Inc.] and its affiliates (collectively, “Enine,” “we,” “us,” or “our”) is effective as of January 1, 2026. It describes how Enine collects, uses, retains, processes, transfers, and discloses information in connection with enine.com and any related systems, advisory services, software services, digital products, or other offerings (collectively, the “Enine Services”).

This Policy applies when you access or use the Enine Services, communicate with us, or otherwise interact with Enine. Where you or the organization with which you are affiliated (“Organization”) have entered into a separate written agreement with Enine, that agreement shall govern to the extent its terms conflict with this Policy.

Depending on the context, Enine may act either as a data controller determining the purposes and means of processing, or as a service provider processing information on behalf of a customer pursuant to contractual instructions. Where Enine acts solely as a service provider with respect to data submitted by a customer through the Enine Services, the customer remains responsible for compliance with applicable data protection laws, and data subjects should direct inquiries to the relevant customer.

Enine collects information that you provide directly when you create an account, request services, correspond with us, or otherwise submit information through the Enine Services. We also collect information generated in connection with your use of the Enine Services, including technical and usage data necessary to operate, secure, and improve our systems. In certain circumstances, we may receive information from third parties where you or your Organization have authorized us to access such information.

Enine processes information to provide, operate, secure, and improve the Enine Services; to perform contractual obligations; to communicate with you; to prevent fraud or misuse; and to comply with applicable law. Information may be processed in the United States or in other jurisdictions in which Enine or its service providers operate. Where information is transferred across borders, Enine implements appropriate safeguards consistent with applicable data protection laws.

Enine retains information only for as long as necessary to fulfill the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on the nature of the information and the context in which it was collected.

Individuals may request access to, correction of, or deletion of personal information held by Enine, subject to applicable law and contractual obligations. Where Enine processes information solely on behalf of a customer, such requests should be directed to the relevant customer.

Enine does not sell personal information. We may share information with service providers engaged to support the Enine Services, who are authorized to process information only as necessary to provide services to Enine and who are subject to appropriate confidentiality and security obligations. We may also disclose information where required by law or where necessary to protect the security or integrity of our systems or the rights, property, or safety of Enine, our customers, or others.

Enine implements administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, and destruction, consistent with industry standards appropriate to the nature of the services provided. While no system can guarantee absolute security, Enine maintains safeguards proportionate to the risks presented by the processing of information.

The Enine Services are not directed to individuals under the age of eighteen, and we do not knowingly collect personal information from such individuals.

Enine may amend this Policy from time to time. If a revision is material, we may provide notice prior to the change becoming effective. Continued use of the Enine Services after the effective date constitutes acceptance of the revised Policy.

Questions regarding this Privacy Policy may be directed to privacy@enine.com.