Privacy Policy

Last updated: September 15, 2025

Introduction

Wraith Brokerage, LLC and its affiliates (hereinafter "Wraith Brokerage" or "we") value the privacy of individuals who use our websites and related services (collectively, our "Services"). This Privacy Policy explains how we collect, use, and share the information of US residents who use our Services ("Users," "you," or "your"). By using our Services, you agree to the collection, use, disclosure, and processing of your information as described by this Privacy Policy.

We collect Personal Data from US residents and comply with the consumer privacy laws of Florida ("US Privacy Law"). For the purposes of this Notice, "Personal Data" means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:

• Publicly available information;
• Deidentified or aggregated data; or
• Information otherwise excluded from the scope of US Privacy Law.

This Privacy Policy provides the following information to US residents:

• Categories of Personal Data we collect;
• Purposes for which we use Personal Data;
• Categories of Personal Data we share with third parties;
• Categories of third parties with which we share Personal Data; and
• How US residents can exercise their rights under US Privacy Law.

Categories of Non-Sensitive Personal Data We Collect

The tables below outline the non-sensitive categories of Personal Data Wraith Brokerage collects about US residents, what we use that data for, and whether and how it is shared with third parties.

We collect Non-Sensitive Personal Data:

• Directly from individuals who submit information through our contact forms

How We Use the Information We Collect

In addition to the purposes listed above, we may use the information we collect:

• To provide, maintain, improve, and enhance our Services;
• To understand and analyze how you use our Services and develop new products, services, features, and functionality;
• To allow you to share content with other Users of our Services;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide User support;
• For marketing and advertising purposes, including developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
• To detect and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected

How We Share the Information We Collect

We share Personal Data with the following categories of third parties:

Processors

We may share any information we collect with Wraith Capital Advisory, LLC, our affiliate, in connection with the provision of our Services. As our affiliate, Wraith Capital Advisory, LLC may use this information to assist us in providing the Services and for other business purposes related to our affiliate relationship. Wraith Capital Advisory, LLC is required to maintain appropriate safeguards for your information.

Our Affiliates

We may share your information with our affiliates, subsidiaries, and representatives as needed to provide our Services.

Other Users

Content you post on our systems, such as comments or reviews, may be displayed to other Users as appropriate.

Our Business Partners

We may share relevant information about you with our business partners to provide you with exclusive offers for products and services that may interest you.

Our Advertising Partners

We work with third-party services to conduct advertising via cookies. These third parties may also collect information about your use of other websites, apps, and online resources. Please note that this list may be updated from time to time to provide you with the latest information. For more information about your choices regarding how these partners use your information, see the Your Choices section below.

We may also share your Personal Data with other parties for the following reasons:

As Required by Law

We may share your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others' rights, property, or safety. In particular, we may share relevant information with the appropriate third parties if you post any illegal, threatening, or objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers

We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or in which we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the same general provisions of this Privacy Policy.

Consent

We may also share your information with your permission.

For more information on how we share the information we collect, see the Categories of Non-Sensitive Personal Data tables above. We do not sell Personal Data to anyone.

Your Rights and Choices

Our Communications

From time to time, you may receive marketing or other informational email messages from us. You can unsubscribe from our promotional and informational emails via the link provided in the emails. Users may continue to receive administrative messages necessary to service User accounts after opting out of receiving promotional messages from us.

Cookies

Most web browsers allow you to manage cookies through the browser settings. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.

Our Partners

Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. You can visit those organizations' websites to learn about how you may opt out of receiving web-based personalized ads from their member companies. You can also access any settings offered by your mobile operating system to limit ad tracking. To inquire about your choices regarding our business partners generally, contact us at info@WraithBrokerage.com.

Your Rights

US residents have the following rights under US Privacy Law:

• The rights to access, correct, or delete Personal Data;
• The right to obtain a portable copy of Personal Data;
• The right to limit the use of Sensitive Personal Data in certain circumstances;
• The rights to opt out of targeted advertising, sales of personal data, or profiling;
• The right not to receive discriminatory treatment for exercising your privacy rights; and
• The right to appeal our decisions about your requests if you disagree with them.

Exercising Your Rights

If you are a US resident, you can submit a request to exercise your personal data rights by sending an email to info@WraithBrokerage.com with the subject line "Privacy Rights Request".

Wraith Brokerage also processes opt-out requests sent by Universal Opt-Out Mechanisms (also referred to as "Opt-Out Preference Signals") frictionlessly in compliance with US Privacy Law. You can send an Opt-Out Preference Signal for our business to process frictionlessly by visiting our website using a device or browser that broadcasts commonly used and recognized Opt-Out Preference Signals. We will apply the Opt-Out Preference Signals we receive to the browser or device that sent the signal. Please be aware that we do not accept or process rights requests submitted through other means.

To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by sending an email to the email address we have on file with a link to complete the verification process. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose.

We will respond to your rights request within 45 days (or within 15 days when required by US Privacy Law), and in certain cases we may inform you that we will need an additional 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay acting on your request until we can appropriately verify your identity and the request as authentic. Also note that each of your rights are subject to certain exceptions that may permit or require us not to process your request.

Authorized Agents

You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by using the method(s) described above. We may require verification of your authorized agent's authority in addition to the information we require for verification of your identity.

Notice of Right to Opt-Out of Sale/Sharing for Targeted Advertising

US Privacy Law gives US residents the right to direct a business that "sells" their Personal Data or shares it for targeted advertising purposes to stop selling and/or sharing their Personal Data at any time. As used here, "selling" means exchanging Personal Data with a third party for money or anything of value, and targeted advertising is the practice of displaying advertisements to a person that are selected based on that person's activities over time and across non-affiliated websites or applications. In certain situations, and as detailed more fully in the tables above, we share for targeted advertising Personal Data with third parties. You can opt out of the sharing of your Personal Data for targeted advertising purposes by sending an email to info@WraithBrokerage.com with the subject line "Privacy Rights Request."

Notice of Right to Limit the Use of Sensitive Personal Data

You have the right to limit some uses of Sensitive Personal Data. In general, you may direct companies not to use your Sensitive Personal Data except as necessary to provide goods or services you have requested or to further certain other exempt purposes. However, Wraith Brokerage does not Process any Sensitive Data.

SMS and Text Messaging

Wraith Brokerage offers SMS text messaging services to provide you with information about our Services and related communications. Participation in our SMS program is optional, and you may opt-in or opt-out at any time as described below.

Consent and Program Participation

By providing your mobile phone number and opting into our SMS program, you expressly consent to receive text messages from Wraith Brokerage at the mobile number you provided. Your consent to receive SMS messages is separate from any other consents you may provide to Wraith Brokerage and is not a condition of purchasing any goods or services from us. You may opt-in to our SMS program through our website, contact forms, or by texting a keyword to our designated number.

We may send you the following types of SMS messages:

• Promotional and marketing messages about our Services, special offers, and updates;
• Transactional messages related to your use of our Services, such as confirmations and notifications;
• Account-related messages, including security alerts and service updates; and
• Customer service messages in response to your inquiries.

Message Frequency and Charges

Message frequency varies depending on your preferences and activity. You may receive up to 10 messages per month, though frequency may vary. Message and data rates may apply as charged by your wireless carrier. Wraith Brokerage does not charge for SMS messages, but your carrier's standard messaging and data rates apply. Check with your wireless carrier for details about your specific plan.

Opt-Out Instructions

You may opt-out of receiving SMS messages from Wraith Brokerage at any time by:

• Replying "STOP" to any SMS message you receive from us;
• Texting "STOP" to our designated SMS number; or
• Contacting us at info@WraithBrokerage.com with your opt-out request.

After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. You will not receive any additional SMS messages from us unless you opt-in again. Opting out of SMS messages will not affect your ability to receive other forms of communication from us, such as email.

Help Information

For help with our SMS program, reply "HELP" to any message or text "HELP" to our designated number. You may also contact us at info@WraithBrokerage.com for assistance.

Children's Data

We do not knowingly collect or use the Personal Data of children under 16. If you believe that we have collected the Personal Data of a child under 16, please contact us at info@WraithBrokerage.com.

Third-Party Content

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the content provided by, or the privacy practices of, these third parties. Please be aware that this Privacy Notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your information by using administrative, technological, and physical safeguards designed to improve the security of the information we maintain and protect it from accidental loss, unauthorized access or use, or any other inappropriate or unlawful processing. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your data.

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By using our Services, you consent to the transfer, storage, and processing of your information as described in this Privacy Notice.

Changes to This Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we make material changes, we may notify you by sending an email to the address we have on file. We encourage you to read this Privacy Policy periodically to stay up to date about our privacy practices.

Contact Us

If you have any questions, comments, or concerns about our processing activities, please email us at info@WraithBrokerage.com.