Effective Date: May 1, 2026 Last Updated: August 6, 2026 CoShares (“CoShares,” “Company,” “we,” “our,” or “us”) provides technology that helps investors organize, analyze, and collaborate around their investments. CoShares includes three primary environments: Solo, Investment Clubs, and Circles. The platform may provide portfolio tracking, brokerage connections, investment ledgers, reporting, contribution tracking, governance tools, document storage, AI-powered features, investment education, social content, community features, and other tools. This Privacy Policy explains how CoShares collects, uses, stores, shares, and protects information when people use the CoShares website, applications, Solo environment, Club environment, Circle environment, Social features, AI features, administrative systems, and related services. CoShares is not a brokerage firm, investment adviser, bank, or custodian. CoShares does not take custody of users’ securities or investment accounts and does not place trades on behalf of users. Brokerage and investment activity takes place through third-party financial institutions and brokerage firms selected by users or Clubs. Certain CoShares features may allow users or Clubs to initiate or manage contribution-related activity through third-party payment or financial service providers. When these features are available, the third-party provider is responsible for the actual processing or movement of funds according to its own terms and privacy practices. CoShares may receive information needed to record, display, reconcile, or report the activity inside the platform. This Privacy Policy applies to CoShares members, Solo users, Investment Club members and administrators, Circle members and administrators, Platform Administrators, visitors to CoShares websites, and other people who use CoShares services. Third-party services such as brokerages, banks, payment processors, brokerage connection providers, financial data providers, authentication providers, and other integrations have their own privacy policies and security practices. This Privacy Policy does not replace the policies of those third parties. Information You Provide to CoShares CoShares collects information that users provide when creating or managing an account. This may include a name, email address, username, password or authentication information, profile image, profile information, account preferences, membership information, subscription information, role, permissions, and other information needed to operate an account. Users may also provide information when participating in Investment Clubs, Circles, community features, polls, reactions, the Ambassador Network and Referral Program, support requests, or other CoShares features. CoShares may maintain both private account information and information a user chooses to make visible through public or community features. Users should review their privacy settings before making information public. Solo Environment The Solo environment allows an individual user to organize and analyze investments connected to that user. Depending on the user’s plan and available features, CoShares may process brokerage account information, holdings, balances, transactions, portfolio information, documents, brokerage statements, reports, AI Coach activity, and other information related to the user’s Solo environment. Solo financial information is private unless the user clearly chooses to share information through a feature designed for that purpose. CoShares does not automatically make Solo balances, holdings, transactions, brokerage accounts, reports, or other private financial information publicly visible. Investment Club Environment The Club environment allows members to organize and operate an investment club. CoShares may collect and maintain Club names, Club identifiers, member information, roles, permissions, contribution records, ownership information, allocation information, governance actions, voting records, portfolio information, brokerage information, transaction records, documents, reports, AI Coach activity, and other records needed to operate Club features. Access to Club information depends on membership, permissions, Club settings, and administrative roles. CoShares may maintain permanent or historical Club ledger records to support ownership history, transaction history, reporting, governance, reconciliation, auditing, and other Club functions. Contributions CoShares may maintain contribution information such as contribution amounts, dates, status, frequency, member totals, Club totals, ownership information, and related records. A contribution displayed as submitted, pending, approved, confirmed, completed, or recorded does not necessarily mean that CoShares took custody of the funds. When money movement is supported through CoShares, the actual financial transaction may be performed by a third-party payment or financial service provider. CoShares may retain records of contribution activity even when the underlying payment occurred outside of CoShares because those records may be needed for Club ownership, reporting, auditing, and historical records. Circle Environment Circles allow people to collaborate around investing without pooling their investment funds. A Circle member may choose to use information associated with brokerage accounts or portfolios available through the member’s CoShares account. Circle members may have privacy controls that determine what information is visible to other Circle members. Participation in a Circle does not automatically make a member’s complete brokerage account, holdings, balances, transactions, Solo information, reports, or other private financial information available to the Circle. CoShares uses applicable privacy settings and permissions to determine what Circle information may be displayed to other members. Users are responsible for reviewing the information they choose to make visible within a Circle. Brokerage Connections CoShares may allow eligible users and Clubs to connect one or more brokerage accounts through supported third-party brokerage connection or financial data providers, which may include providers such as SnapTrade, Connect Trade, or other supported services. When a brokerage account is connected, CoShares may receive read-only financial information made available through the connection. This may include brokerage institution, account identifiers, account type, account balances, holdings, securities, ticker symbols, quantities, prices, cost information, transaction history, investment income, and other portfolio-related information. Brokerage data may be used to populate CoShares ledgers, update portfolio information, maintain transaction histories, calculate information displayed by the platform, and generate reports and AI-supported analysis. Some information, such as current holdings and account balances, may be refreshed when brokerage information is synchronized. Historical transaction records may be maintained to provide an accurate investment history and prevent duplicate records. CoShares does not collect or store a user’s brokerage password when authentication is handled by the brokerage or brokerage connection provider. CoShares may maintain secure connection tokens, identifiers, synchronization records, and other information required to maintain the integration. Brokerage Statements and Uploaded Documents Users may upload brokerage statements and other documents to supported CoShares environments. When a brokerage statement is uploaded, CoShares may process and extract information such as account information, balances, holdings, transactions, dates, ticker symbols, quantities, prices, investment income, and other information contained in the document. Extracted information may be placed into the appropriate CoShares ledgers and used for portfolio tracking, analysis, reporting, reconciliation, and other requested features. Uploaded documents and extracted information may remain stored according to CoShares retention practices. Deleting an uploaded document may not automatically delete ledger records, historical transactions, reports, audit records, backups, or other information that must be retained for operational, security, historical, or legal reasons. Ledgers and Historical Records CoShares uses internal ledgers to maintain structured records for Solo, Club, and other supported environments. These records may contain user identifiers, display names, portfolio information, brokerage information, transactions, documents, contributions, ownership information, allocation information, and other records needed to operate CoShares. Some ledger records are designed to preserve historical activity. CoShares may therefore retain certain records even after newer information is received. Current information such as holdings and balances may be updated while historical records such as completed transactions may remain available as part of the account or Club history. Reports CoShares may generate financial and investment-related reports using information stored within the applicable CoShares environment. Solo reports are generated using information available to the applicable Solo user. Club reports are generated using information available to the applicable Club. CoShares is designed to keep information from different environments separated according to applicable permissions and access controls. Reports may contain sensitive financial information. Access to reports is controlled by the applicable account, membership, role, environment, and permission settings. CoShares may preserve completed reports as historical records so users and Clubs can review information from earlier reporting periods. AI Coaches and AI Features CoShares provides AI-powered features, including AI Coaches, analysis, summaries, educational tools, and other AI-supported experiences. When a user interacts with an AI feature, CoShares may process the user’s prompt, conversation, relevant platform information, selected reports, and other information required to provide the requested response. When an environment’s automatic data feature is enabled, the AI Coach may receive authorized information from that environment. For example, a Club AI Coach may use authorized Club information, while a Solo AI Coach may use authorized information belonging to that Solo user. CoShares is designed to prevent an AI Coach from automatically using private information from an unrelated environment. Some AI processing may be performed by third-party artificial intelligence service providers. Information necessary to provide an AI feature may therefore be transmitted to those providers subject to applicable agreements, settings, and safeguards. AI-generated information may contain errors and should not be treated as guaranteed financial information or personalized investment advice. AI Credits CoShares may use AI Credits to measure or provide access to certain AI-powered features. CoShares may maintain information about AI Credit balances, purchases, subscription allocations, usage, adjustments, and related activity. Payment information associated with purchases may be processed by a third-party payment processor. Social and Educational Content CoShares may provide a Social or discovery experience containing market information, investing education, company or ETF spotlights, market recaps, polls, and other CoShares-created or AI-assisted content. CoShares may collect information about how users interact with this content, including content views, saves, poll votes, shares, and reactions. CoShares may offer reactions such as Insightful, Interesting, and Moving Forward. CoShares may store which account selected a reaction so the platform can prevent duplicate reactions, allow users to change reactions, and calculate reaction totals. Public CoShares articles may have permanent public web addresses. Public article pages may contain information such as the article title, description, category, publication date, image, and CoShares branding. This information may appear in link previews when content is shared outside CoShares. Private Club or other restricted content is not intended to become public simply because a link is created or shared. Access controls continue to apply to restricted content. Member Profiles CoShares may provide member profiles using information associated with an existing CoShares account. Depending on the features available and the user’s choices, a profile may display a name, username, profile image, biography, investing interests, or selected public activity. Private financial information such as brokerage balances, private holdings, transactions, private reports, account identifiers, and restricted Club or Circle information is not intended to appear on a public member profile unless a feature clearly allows the user to choose what information is shared. Ambassador Network and Referral Program Eligible users or Premium Clubs may participate in the CoShares Ambassador Network or Referral Program. CoShares may collect information needed to operate these programs, including participant identity, referral identifiers, referral activity, eligibility, status, rewards, payments, performance information, and related records. Information may be shared with payment or service providers when needed to administer eligible rewards or payments. Subscription and Payment Information CoShares offers free and paid features and may offer subscriptions, AI Credits, Club upgrades, or other paid services. Payments may be processed by third-party payment providers. CoShares may receive transaction identifiers, subscription status, plan information, payment status, billing dates, and limited payment-related information needed to manage the service. CoShares does not need to store full payment card information when that information is handled directly by the payment provider. Technical, Security, and Usage Information CoShares may automatically collect technical and usage information when the platform is accessed. This may include IP address, browser, device type, operating system, session identifiers, login activity, page views, feature usage, application events, error information, security events, administrative actions, fraud signals, and other system activity. CoShares may use this information for security monitoring, fraud detection, troubleshooting, system performance, analytics, auditing, access control, incident investigation, and improving the platform. How CoShares Uses Information CoShares uses information to provide and maintain accounts, Solo portfolios, Investment Clubs, Circles, brokerage connections, ledgers, reports, documents, AI features, Social features, polls, subscriptions, contributions, governance features, Ambassador features, customer support, security systems, and other platform functions. Information may also be used to authenticate users, enforce permissions, synchronize financial information, prevent duplicate records, generate requested analysis, improve platform performance, investigate suspicious activity, prevent fraud or abuse, maintain audit trails, communicate with users, enforce CoShares terms, and comply with legal obligations. CoShares does not sell personal information. CoShares does not rent personal information to third parties. Service Providers and Integrations CoShares may share information with service providers when reasonably necessary to operate the platform. These providers may include cloud hosting services, database providers, authentication services, file storage providers, email services, payment processors, brokerage connection providers, financial data providers, AI providers, analytics services, security providers, monitoring services, customer support tools, and other technology providers. CoShares seeks to limit information shared with service providers to information reasonably needed to provide the applicable service. Legal and Safety Disclosures CoShares may disclose information when reasonably necessary to comply with law, respond to valid legal requests, enforce agreements, investigate fraud or misuse, protect platform security, respond to security incidents, protect users, or protect the rights and interests of CoShares or others. Information Security CoShares uses administrative, technical, and organizational safeguards designed to protect information. Depending on the system and information involved, safeguards may include encryption in transit, protection of sensitive stored information, role-based access controls, least-privilege access, secure authentication, administrative multi-factor authentication, access logs, audit trails, secure integration tokens, session monitoring, fraud monitoring, security alerts, and other security controls. No online system can guarantee complete security. Users are responsible for protecting their account credentials and promptly reporting suspected unauthorized access. Data Retention CoShares retains information for as long as reasonably necessary to provide platform functionality, maintain accurate financial and historical records, support users and Clubs, maintain reports and ledgers, protect security, prevent fraud, resolve disputes, maintain audit trails, enforce agreements, and comply with legal obligations. Different types of information may have different retention periods. Certain historical records, including transactions, ownership records, contribution records, governance records, reports, security logs, and audit information, may need to be retained even after other information is deleted. Access, Correction, and Deletion Users may request access to, correction of, or deletion of eligible personal information by contacting CoShares at info@co-shares.com. CoShares will review requests according to applicable law, security requirements, and platform obligations. CoShares may need to verify a person’s identity before completing a request. Certain information may not be immediately or completely deleted when it must be retained for financial history, Club ownership records, governance history, security, fraud prevention, audit trails, dispute resolution, backups, legal requirements, or other legitimate operational needs. Where appropriate, CoShares may restrict access to or remove identifying information from retained records. Cookies and Similar Technologies CoShares may use cookies and similar technologies to maintain sessions, authenticate users, remember preferences, understand platform usage, improve performance, and support security. Users may control certain cookies through their browser or device settings. Disabling required cookies may prevent parts of CoShares from working correctly. Children’s Privacy CoShares is not intended for individuals under 18 years of age. CoShares does not knowingly collect personal information from children under 18. If CoShares learns that such information was collected, CoShares may delete it or take other appropriate action. Changes to This Privacy Policy CoShares may update this Privacy Policy as the platform, legal requirements, or data practices change. The current version will display a new “Last Updated” date. Material changes may also be communicated through CoShares, email, or another reasonable method when appropriate. Contact CoShares Questions, concerns, privacy requests, or questions about CoShares data practices may be sent to: CoShares info@co-shares.com