COOKIE POLICY

Effective Date: January 1, 2026

This Cookie Policy (“Policy”) constitutes a legally binding disclosure governing the use of cookies, tracking technologies, and related data collection mechanisms by Next Fraga Investments LLC, a limited liability company organized under the laws of the State of Florida (“Company,” “we,” “us,” or “our”).
This Policy applies to all users, investors, visitors, and other persons (“User,” “you,” or “your”) who access or use the Company’s website, applications, communications systems, and investment-related digital platform (collectively, the “Platform”).
This Policy forms an integral part of, and is hereby incorporated by reference into, the Company’s Terms of Service.

BY ACCESSING OR USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE USE OF COOKIES AND TRACKING TECHNOLOGIES AS DESCRIBED HEREIN, SUBJECT TO YOUR RIGHTS UNDER APPLICABLE LAW.

1. NATURE AND PURPOSE OF THIS POLICY

This Policy is designed to provide transparency regarding the collection of non-personal and technical data through cookies and similar technologies.

Cookies are used to:

  1. Enable core platform functionality
  2. Enhance user experience
  3. Maintain security and operational integrity
  4. Analyze platform performance and usage patterns
  5. Support compliance and risk management functions

 

Cookies do not independently identify users without additional contextual data.

2. WHAT ARE COOKIES

Cookies are small text files placed on your device (computer, mobile device, or similar technology) when you visit a website. Cookies may be:
Cookies may be:
  1. Session-based (deleted when you close your browser)
  2. Persistent (remain on your device until deleted or expired)

The Platform may also use similar technologies, including:

  1. Pixel tags
  2. Local storage objects
  3. Web beacons
  4. Analytical scripts

Collectively, these are referred to as “Cookies.”

3. TYPES OF COOKIES WE USE

The Company uses the following categories of Cookies:

  A. Strictly Necessary Cookies

These cookies are essential for the operation of the Platform and cannot be disabled in our systems.

They are typically used for:

  1. Security and authentication
  2. Session management
  3. Access control to restricted areas
  4. Fraud prevention and platform integrity

 

Without these cookies, certain services may not function properly.

  B. Functional Cookies

These cookies enable enhanced functionality and personalization, such as:

  1. Remembering user preferences
  2. Maintaining session continuity
  3. Improving navigation experience

 

Disabling these cookies may reduce functionality but will not prevent basic access to the Platform.

C. Analytical and Performance Cookies

These cookies allow us to:

  1. Measure platform traffic and usage patterns
  2. Understand user interaction behavior
  3. Improve system performance and architecture
  4. Identify technical issues and optimize content delivery

 

Data collected through these cookies is aggregated and generally does not directly identify users.

D. Security and Compliance Cookies

These cookies support:

  1. Risk monitoring and fraud detection
  2. Compliance with legal obligations
  3. Audit trails and access logs
  4. Prevention of unauthorized access or misuse

 

Such cookies may be retained longer due to compliance obligations.

E. Third-Party Cookies

In limited circumstances, third-party service providers may place cookies through the Platform for:

  1. Analytics services
  2. Infrastructure and hosting
  3. Communication and CRM tools

 

These third parties operate under their own privacy and cookie policies.

The Company does not control third-party cookies once deployed.

4. LEGAL BASIS AND RIGHTS LIMITATION

To the extent required under applicable law, Cookies are processed based on:

  1. Legitimate business interests 
  2. Contractual necessity (Platform functionality) 
  3. Legal and regulatory compliance 
  4. User consent (where explicitly required)

TO THE MAXIMUM EXTENT PERMITTED UNDER FLORIDA AND APPLICABLE LAW, THE USER AGREES THAT:

  1. IMPLIED CONSENT THROUGH PLATFORM USE SHALL BE LEGALLY SUFFICIENT NON-ESSENTIAL COOKIE RESTRICTIONS MAY LIMIT ACCESS OR FUNCTIONALITY 

  2. CERTAIN COOKIES MAY BE DEPLOYED IRRESPECTIVE OF USER PREFERENCES WHERE                     REQUIRED FOR SECURITY OR LEGAL PURPOSES

5. CONSENT FRAMEWORK AND ENFORCEMENT

Where required by law:

  1. Users may be presented with a consent banner or preference center 
  2. Non-essential Cookies may be accepted or rejected 

 

HOWEVER:

  1. Continued use of the Platform constitutes ongoing consent 
  2. Withdrawal of consent does not affect prior lawful processing 
  3. The Company reserves the right to restrict access where Cookie refusal impairs system integrity

6. USER CONTROL AND ASSUMPTION OF RISK

Users may manage Cookies via browser settings.

By disabling Cookies, the User acknowledges and accepts that:

  1. Platform functionality may be materially degraded 
  2. Security protections may be reduced 
  3. Access to certain services may be denied 

 

THE USER ASSUMES ALL RISKS ASSOCIATED WITH DISABLING COOKIES.

The Company disclaims liability for any resulting loss, interruption, or security vulnerability.

7. DATA COLLECTED AND EXPANDED TECHNICAL SCOPE

Cookies may collect and process:

  1. IP address and geolocation approximations 
  2. Device fingerprints and identifiers 
  3. Browser configuration and metadata 
  4. Session activity, clickstream data, and behavioral patterns 
  5. Network and performance data 
Such data may be combined with other datasets for security, analytics, and compliance purposes.

8. DATA SHARING, DISCLOSURE, AND NON-SALE REPRESENTATION

Cookie-derived data may be shared with:

  1. Authorized service providers 
  2. Infrastructure and analytics vendors 
  3. Legal, regulatory, and enforcement authorities 
  4. Cybersecurity and compliance partners 

 

THE COMPANY DOES NOT SELL PERSONAL DATA; HOWEVER, DISCLOSURE MAY OCCUR WHERE NECESSARY FOR LEGITIMATE BUSINESS OR LEGAL PURPOSES.

9. DATA RETENTION AND LEGAL HOLD RIGHTS

The Company retains Cookie-related data:

  1. For the duration necessary to fulfill operational purposes 
  2. As required for legal, regulatory, or compliance obligations 
  3. As necessary to enforce contractual rights or defend claims 

 

THE COMPANY RESERVES THE RIGHT TO EXTEND RETENTION UNDER LEGAL HOLD OR INVESTIGATIVE REQUIREMENTS.

10. SECURITY AND LIABILITY DISCLAIMER

The Company implements industry-standard safeguards; however:

TO THE MAXIMUM EXTENT PERMITTED BY LAW:
  1. THE COMPANY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED 
  2. THE COMPANY DOES NOT GUARANTEE UNINTERRUPTED OR SECURE DATA TRANSMISSION 
  3. THE COMPANY SHALL NOT BE LIABLE FOR UNAUTHORIZED ACCESS, CYBERATTACKS, OR SYSTEM BREACHES

11. INTERNATIONAL DATA TRANSFERS AND JURISDICTIONAL WAIVER

Users acknowledge that data may be transferred to and processed in the United States and other jurisdictions.

BY USING THE PLATFORM, THE USER:
  1. EXPRESSLY CONSENTS TO CROSS-BORDER DATA TRANSFERS 
  2. WAIVES ANY CLAIM BASED ON DIFFERING DATA PROTECTION REGIMES, TO THE EXTENT PERMITTED BY LAW

12. MODIFICATIONS AND UNILATERAL AMENDMENT RIGHTS

The Company reserves the absolute right, at its sole discretion, to amend this Policy at any time.

  1. Changes are effective immediately upon posting 
  2. Continued use constitutes binding acceptance 

 

NO PRIOR NOTICE SHALL BE REQUIRED EXCEPT WHERE MANDATED BY LAW.

13. GOVERNING LAW AND VENUE

This Policy shall be governed exclusively by the laws of the State of Florida.

Any dispute arising hereunder shall be subject to the exclusive jurisdiction of the state or federal courts located in Florida.

14. NO CONFLICT WITH TERMS OF SERVICE

This Cookie Policy is intended to supplement, and not contradict, the Company’s Terms of Service.

In the event of any inconsistency:

  1. The Terms of Service shall govern matters of platform access, eligibility, risk allocation, and liability
  2. This Cookie Policy shall govern only the use of cookies and similar tracking technologies

Approved by:
Next Fraga Investments LLC Management