Privacy policies

Dated August, 2021

Your privacy is very important. Therefore Chrislugica Art Studio© (along with its subsidiaries and other affiliated entities) is committed to maintaining your privacy. This privacy policy is intended to inform you about:

• The types of information we collect

• How we use the information we collect

• How we share the information we collect

• How we protect the information we collect

• Other important privacy information

This policy applies each time you access or use any domain or subdomain of our website at https://sites.google.com/view/paper-chlgc/chrislugica-art-studio?authuser=0 (the "Website" ) or when you access, use, or download any product, service, feature, content, widgets, materials, or other tools offered by Chrislugica Art Studio© (collectively, "Services"). This policy does not govern the information you choose to share directly with other users of the website, including communications or transactions with other users via the secondary market bulletin board, as we have no direct control over the collection or use of that information. Please use appropriate precautions when sharing information with these users. In addition, please note that your relationship with Chrislugica Art Studio© is also governed by our Terms of Use and the transaction documents that you may enter in connection with making an investment through our website. You are encouraged to review these documents carefully.

1. Types of information we collect

To provide our Services and facilitate exchanges between users of the Website, we obtain personal information directly from you and indirectly through electronic communications and from third parties.

Membership Information provided by User: Depending on the Services you are seeking to access, we may ask to provide some or all of the following types of personal information:

• Name

• Phone number

• Financial information

• Accreditation status. Payment information. Address

• Entity information. Use of information of the Joint Owner

• Investment experience

• Email address

• SSN (or equivalent)

• Date of birth

• Citizenship

• Information on the suitability of the investment

Our membership registration process, surveys, and questionnaires may ask you to provide other information that, at your choice, you may choose to provide or retain. Any information provided will be subject to this policy.

Verification Information: If necessary to help us verify your identity, a copy of your driver's license, passport, or other government-issued identification can be provided. If necessary to help us verify your residency, a utility bill, a lease agreement, or other proof of residency may be provided. Other verification documents, such as bank statements showing the source of funds, may also be provided to comply with the US Bank Secrecy Act or the Anti-Money Laundering Act, or to comply with rules or regulations of the US Department of the Treasury or other legal requirements.

If you are looking to invest through an entity, you can provide us with documentation related to the jurisdiction of formation, legal status and ownership of the entity. By providing the verification information and documents mentioned above, you also provide us with information within those records, which may include some characteristics of protected classifications such as your gender, age, nationality and citizenship.

Banking information: To make an investment in securities offered through our website, you must provide us and/or our financial partners with certain account information and other payment information, such as the information necessary to make payment by ACH, wire transfer , electronic checks, cryptocurrencies, foreign currency or any other payment method accepted by us at any given time.

For members wishing to participate in our secondary market bulletin board, we may use the services provided by AirTm, a financial services software company, with the purpose of facilitating the creation of a bank account and the initiation of bank deposits and withdrawals (i.e. , electronic funds transfers or EFT) directly through the website.

Information collected automatically or passively: In addition to the information that you provide directly, we collect information automatically or passively when you access or use our services (IP address, device identifiers, click path, use of our website and others electronic data). We may also record page visits (visit counts) and other general statistical and tracking information, which will be added to that of other users to understand how our website is used for security and control purposes. To determine if your computer is compatible with our system, we may collect additional technical information, including your operating system and browser, as well as the presence of any software that our website may require to operate your computer or other software on your computer.

A "cookie" is a small amount of data, often including an anonymous unique identifier, that is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a personalized user experience and to make it easier for you to use a website in future visits. We may include and use cookies to recognize you when you visit our website again. You can configure your browser so that it does not accept cookies. Cookies must be enabled in your web browser if you wish to access certain personalized functions of our Services. By using the website, you are giving consent to that use.

We may also use so-called "pixel tags", small graphic images (also known as "web beacons" or "one-pixel GIFs") to inform us which parts of our website have been visited or to measure the effectiveness of searches customers perform on our site. Pixel tags also allow us to send email messages in a format that customers can read and inform us if emails have been opened, to help ensure that our messages are of interest to our users. You can "opt out of receiving these types of communications" from us by following the instructions provided elsewhere in this policy.

Some browsers transmit "do not track" signals to websites. Currently, our Services are not designed to respond to these signals or similar browser mechanisms.

We may send emails that use a "clickable URL" linked to the content of our website. When you click on one of these URLs, it goes through our web server before reaching the destination web page. We track this click data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, just do not click the text or graphic links in the email or notify the Customer Service.

Information related to the use of the Services: We collect certain information about you when you visit the website and interact with any of our Services. We collect information about when you use the Services, the pages within the website you visit, the links you click on, the type, size and names of the files uploaded and downloaded and the search terms used. If you invite others to use the website, we retain information about that recommendation.

We collect information in connection with the transactions you are a party to through our Services, including your participation in primary offers through the website and secondary purchase and sale transactions through the secondary market bulletin board. Transaction data includes, but is not limited to, the terms on which you buy or sell securities and information related to price, size, volume, class of securities, offers, acceptances, transfer restrictions and any derivative information related to them.

Third Party Information: We collect information about you from third parties with whom we have various business relationships. We use a third-party identity verification service provider to help us confirm your identity, prevent fraud, money laundering and other illegal activities, and to satisfy legal requirements related to the Services. We also receive information about you and your activities from third-party service providers, such as Google, LinkedIn, and other advertising, social media, and market research partners that provide us with information about you and your participation and interest in our Services. We may also receive information about you from our third-party marketing partners, under referral programs, IRA service providers, partnership agreements or joint marketing agreements.

2. How we use the information we collect

We may use your personal information for the following business purposes:

To administer, operate, facilitate and manage your relationship with Chrislugica Art Studio© and provide the Services.

To facilitate our business operations, including meeting our legal and regulatory requirements, such as identity verification, validation, money laundering and "Know Your Customer" protocols. Determine your eligibility to invest.

To enable you to subscribe to securities, make and receive payments, and execute transactions.

To satisfy our record keeping and transfer agency obligations under applicable laws, rules and regulations.

To communicate with you about the Services and guide our marketing, advertising and sales efforts to improve your user experience and increase engagement. These communications may inform you about new Services, offers, features, content, and promotional events.

Provide you with information about our current Services, including incorporation materials, the availability and terms of new investment opportunities, reminders, and information about your previous investments.

To verify your identity, accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of the policies of the Service. We also use your information to debug, identify and correct errors in an anonymous, aggregated form, for research and development activities, including the analysis of how you use the Services to help us understand usage patterns and know if there are problems with the Services or areas to improve.

Communicate with you or, if applicable, your designated representative(s) by mail, phone, text message, email, fax, etc., in connection with your relationship with Chrislugica Art Studio©, including with information and updates about our Services.

In addition, if we are involved in a merger, acquisition, due diligence financing, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of the assets of Chrislugica Art Studio©, or other corporate transaction affecting Chrislugica Art Studio©, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or contract. By using the Services, you give consent to receive calls and messages, including calls with auto-dialed and prerecorded messages, and SMS messages (including text messages) from us, at any phone number that you have provided or may provide in the future (including any cell phone number). Your cell phone or mobile provider will impose charges on you based on the type of plan. You can "opt out" of receiving these types of communications from us by following the instructions provided elsewhere in this policy. If your relationship with Chrislugica Art Studio© ends, we will continue to process your personal information to the extent that we retain it, as described in this policy.

3. How we share the information we collect

We do not share personal data with third parties for their direct marketing or similar purposes without your consent. We also do not offer financial incentives, preferential service agreements or any other difference in our prices or Services in exchange for data.

How partners, service providers, and others with whom we share and / or disclose your information is governed by the policies of those parties. We will have no responsibility for the privacy practices or other actions of those parties. Generally, you can easily recognize when one of our partners is associated with a service. However, some parties may provide services anonymously and in this case we will only share information that is directly related to the corresponding services. This may include incorporating your personal information into databases maintained to validate information for identity verification, including verification of anti-money laundering and "Know Your Customer" protocols.

The main situations in which we share your data are the following:

Partnership Agreements: We employ other companies to perform functions on our behalf, such as the site that hosts our content as a provider of services that assist in the administration of our website and our advertising and marketing efforts. We may need to share your information with this company.

Potential business combination: We may also transfer your personal information to a third party as a result of a business combination, merger, sale of assets, reorganization or similar transaction or to government authorities when we reasonably believe that it is required by law or appropriate to respond to a legal process. We will also share your information with third party companies, organizations or individuals if we have a good faith belief that access, use, preservation or disclosure of your information is reasonably necessary to detect or protect against fraud or security concerns, enforce our terms of use, comply with any enforceable government request, defend against legal claims or protect against harm to our legal rights or safety. In such event, and to the extent permitted by law, we will notify you and, if there are material changes in relation to the processing of your personal information, we will give you the opportunity to give consent to any such changes.

Service Providers: To operate the Services, we share information about you as necessary with our service providers, including financial institutions, brokers, accountants, auditors, attorneys, payment processors, information technology consultants, advisors, and our affiliates. We only share information to the extent necessary to comply with our obligations to you and the regulators and to operate the website and the services.

Affiliates: We routinely share information with companies closely related to us, our "Affiliates," for certain purposes of this policy. By "Affiliate", we mean an entity that controls, is controlled by, or is under common control with Chrislugica Art Studio©, whether the control results from equity ownership, contract, overlapping management, or otherwise. In this context, "control" means the ability to replace officers or directors or to materially influence or control management decisions. Our affiliates will have the right to enjoy our rights under this policy and we will be responsible for the behavoiur of our affiliates under this policy.

Regulators: We may share information about you with state or international regulators or with FINRA when we believe that doing so is necessary or appropriate to comply with any law, regulation or other legal process or law enforcement requests, such as court orders or subpoenas.

Third Party Sites: The website may contain links to third party websites and may redirect you to third party websites. These sites include, but are not limited to, service providers that have a relationship with Chrislugica Art Studio©. Third-party websites are not under our control and we are not responsible for any third-party websites, nor for the accuracy, sufficiency, correctness, reliability, truthfulness, completeness or timeliness of their information, links, changes or updates. Inclusion or access to these websites does not imply endorsement by Chrislugica Art Studio©, or the provider of such content or services, or any third-party website. Please note that when you enter a third party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of such website.

4. How we protect your personal information

Security systems and processes: We implemented security systems designed to prevent unauthorized access or disclosure of personally identifiable information. We take all reasonable steps to secure and safeguard this information, including:

The password-protected section of our website requires users to provide us with unique identifiers, such as their user ID and password, and to authenticate before accessing the Services;

We use standard encryption technology for any information we store;

Chrislugica Art Studio© employees must acknowledge that they understand and will comply with this policy regarding the confidentiality of any Personal Information;

Where applicable, the companies we do business with agree to comply with this policy and apply similar safeguards to Personal Information;

We provide access to our databases containing personal information only when necessary; and

We use automated tools to monitor network traffic in order to identify unauthorized attempts to upload information, change information, or try to "hack" our systems.

Therefore, our security systems are structured to deter and prevent hackers and others from accessing the information provided. However, please understand that this information should not be construed as a guarantee that our security systems are fail-safe. Due to the nature of Internet communications and evolving technologies, we cannot provide and also disclaim the assurance that the information you provide to us will remain free from loss, misuse, or alteration by third parties who, despite our best efforts, gain unauthorized access.

Credit card security: Chrislugica Art Studio© will safeguard the confidentiality and security of the information obtained. This notice describes our policy regarding the collection, protection and disclosure of such information resulting from credit card transactions only. Chrislugica Art Studio© will collect and use information obtained from credit card transactions for business purposes only. Credit card information provided to Chrislugica Art Studio© will be kept confidential. Our employees can access such information only when there is a suitable business reason to do so, such as when a refund must be issued to the credit card. We maintain physical, electronic, and procedural safeguards to protect your information. Our employees must follow these privacy standards. The transmission of information, including any payment information, is encrypted and protected using TLS/SSL technology. Chrislugica Art Studio© does not disclose any non-public information (such as credit card number and its expiration date), except as required by law. Chrislugica Art Studio© discloses information only when necessary for the conduct of government business or in circumstances where any such disclosure is required by law. Any information may also be disclosed for auditing purposes, to regulatory agencies, or for other general administrative services.

5. Other important privacy information

Opt out of receiving communications: If you wish to stop receiving marketing or promotional communications or choose not to use your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking "Unsubscribe" (or a language similar opt-out) in those communications. You can also contact us at our customer service to opt out. Despite your stated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt out of receiving certain communications required to comply with applicable laws, rules and regulations or other legal and related notices regarding your relationship with the website.

Change or delete information: All users can review, update, correct or delete the Personal Information provided by a user by contacting our customer service or, in certain cases, by accessing their member account. Upon request, we will take reasonable steps to remove your name and other personal information from our databases. Please understand that, however:

• it may be impossible to completely delete information, due to IRS and regulatory reporting requirements, platform investments and rights, and data backups and deletion records;

• if you request the deletion of your information, you will not be able to use certain functions of the website and associated Services; and certain personal information may remain in our databases after deletion of your account in accordance with our data retention policy.

Data Retention: We retain the information we collect while you use the Services (including your ownership of securities in Chrislugica Art Studio© entities) or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies, as required pursuant to record retention obligations or as otherwise required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Lost or Stolen Information: You must notify us immediately if any information provided or submitted to the website is lost, stolen, or used without permission.

Download or access personal information: You can request a copy of your personal information, including a copy in machine-readable format, by sending an email to our customer service.

Children and Teens: Due to federal law (as reflected in the Children's Online Privacy Protection Act), WE DO NOT ALLOW INDIVIDUALS UNDER THE AGE OF 18 TO PARTICIPATE IN OUR WEBSITE OR SERVICES. YOU MUST BE AT LEAST 18 YEARS OLD TO USE OUR WEBSITE AND OUR SERVICES. Please understand that we cannot necessarily verify if a user provides her true age. If a parent or guardian learns that her child has provided us with information without her consent, such parent should contact us at our customer service. We will remove such information from our files within a reasonable time.

Changes to this policy: Every time you visit our website or use our services, the current version of this privacy policy will apply. When you use our website, you should check the date of the last policy update (listed at the top of the policy) and review any changes since the last version. Our business changes frequently and this policy is subject to change from time to time. Unless otherwise stated, our current policy applies to all information we have about you. We may ask you to affirmatively accept a revised version of this policy as a condition of using the website or our services.

Additional Resources: For more information on privacy policies in general and on online social media and security, you should visit the FTC website.

Residents of the European Economic Area: If you are a person who is a resident of the European Economic Area ("EEA"), we collect and process information about you only when we have legal bases to do so in accordance with applicable EU laws, including the General Regulation of data protection ("GDPR"). The legal bases depend on the Services you use and how you use them. This means that we collect and use your information only when:

• it is necessary to provide the Services to you, including to operate the Services, perform a contract with you, take the necessary steps before executing a contract or when requested, provide customer support and protect the security of the Services;

• satisfies a legitimate interest (which is not overridden by your data protection interests), such as research and development, marketing and promoting the Services, personalizing the services you receive, and protecting our legal rights and interests;

You give us your consent to do so for a specific purpose or for when we need to process your data to comply with a legal requirement. If you have given your consent for us to use your information for a specific purpose, you can change your mind at any time, but this will not affect any processing that has already taken place. Where we use your information because we or a third party (for example, your employer) has a legitimate interest to do so, you can object to that use although, in some cases, this may mean that you no longer use the Services. To do so, send an email to our customer service.

In the event of a data breach, we will endeavor to notify you within 72 hours of detecting any such breach that we conclude poses significant risks to your rights and freedoms under the GDPR. You can also file a complaint with a supervisory authority in the EEA member state in which you reside.

California Residents: Pursuant to California Civil Code Section 1798.83, California residents have the right to request from a company with which the California resident has an established business relationship what types of personal information, if any, they share with third parties for direct marketing purposes by those third parties and the identities of third parties with whom the company has shared such information in the immediately preceding calendar year. To access this information, please contact us by email at our customer service.

Vermont Residents: We do not share the non-public personal financial information we collect about Vermont residents with unaffiliated third parties, except for our day-to-day business purposes or as permitted by law. If you wish to revoke any authorization to share your private personal financial information, please contact us for customer service assistance, although we will no longer be able to provide Services or access to the website.

Contact Us: If you have any questions about this policy, the practices of this website, or your dealings with this website, please contact us via email at our customer service.