Privacy Information

General Privacy Policy

Empyreal Enterprise, LLC’s General Privacy Policy

Effective Date: May 2018, Updated September 1, 2025

Section I: Introduction

1. Introduction

Empyreal Enterprises LLC, d/b/a Empyreal Logistics (“Empyreal”, “us”, “our”, or “we”) respects your right to privacy and security when providing personal information, client information or payments through digital mediums. This policy does not apply to our collection and use of personal information from California residents. California residents should see our California Privacy Policy here.

Below outlines the policies of Empyreal with respect to the collection of data, information security, and privacy standards.

Section II: Information Collection

2. Information Collection

As a part of our business operations, we routinely collect and retain information about our customers. This information is necessary in allowing us to provide our services or provide information about our services and company. Use of this information Empyreal includes but is not limited to: administration of records; execution of accounting and funding; compliance with laws or regulations; and/or the development of future products. Empyreal is the sole owner of the information collected.

Many of our customers are businesses or other non-person legal entities. While most of the information we receive and collect is not of a personal nature, portions of the transaction information we receive may include public and non-public information about individuals as well as about the entities with which they conduct business activities.

Regardless of the nature of the information, whether it is information we solicit directly from our customers, from visitors to our website, or whether we collect the information during the processing of transactions, we regard all such information as “private” and take steps to protect its integrity and confidentiality.

No private information regarding specific persons will be provided to any third party except:

to obtain commercial and credit information to establish, maintain or renew a customer’s contract(s);
as may be required to provide any of the services for which a customer has subscribed, as may be legally permitted;
to assist in preventing or prosecuting fraud, or to otherwise comply with a requirement or request of the government;
to comply with the rules and regulations of any state or local entity; or
with the person’s written consent.

This policy does not preclude our unrestricted use of non-personal, summarized, derived, or aggregate information (i.e., volumes, totals, averages, etc.). In addition, we may provide information, from time to time and as allowed by our customers’ respective contracts, to entities that may have products or services that may be of interest to them.

Section III: Information Collected via Digital Channel

3. Information Collected via our Digital Channel

We may solicit, collect or retain public or personal information regarding customers or visitors to our website, portal, and/or social media sites in order to allow us to respond to requests about products and services, for investor information, etc. Such information (e.g., name, address, telephone number, e-mail address) is voluntarily supplied by the visitor and will be used to contact the visitor to follow up on the visitor’s request.

Section IV: Commitment to Security

4. Commitment to Security, Privacy, and Standards

We take our responsibility to protect the security and privacy of the information we receive seriously. We have established effective policies that define our commitment to data security and the information technology we administer. We continually review our policies and procedures to assure that they are appropriate and effective in meeting our commitments to our community, our customers, and ourselves. Strict internal procedures and control mechanisms require that individuals’ access to information is controlled according to job responsibility and legitimate “need to know.” To the degree reasonably possible, access controls are narrowly defined in order to restrict information access to that which is necessary and consistent with the respective job function(s) of our personnel.

Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. All suspected computer mischief will be reported to the appropriate authorities.

Section V: Security Practices

5. Security Practices

We use a variety of controls and measures to protect personal or sensitive information. These include industry standard encryption, physical access security, secured networks and servers,

anti-virus protection, vulnerability scans, firewalls, intrusion detection, defense monitoring and other appropriate technology. We test, review, and update this technology from time to time to improve and enhance our security systems.

Section VI: Cookies

6. Cookies

Empyreal’s website may create a file, or “cookie,” on the hard drive of your computer in order to retain information that is used by our website. These files are used during your online session to ensure access to our site is authorized and to control certain parameters of your communication session with our site. We do not use these files to monitor the behavior of visitors to our sites.

Section VII: IP Addresses

7. IP Addresses

An IP (Internet protocol) address is a number assigned to your computer for accessing the Internet. All computer identification on the Internet is conducted using IP addresses to allow other computers and servers to recognize and communicate with each other. If a visitor requests pages from the Empyreal website, our servers enter the visitor’s IP address into a log. We do not associate IP addresses with personal information received from visitors. We collect IP addresses in order to conduct site analysis. We also use IP address information to conduct system administration, manage communication traffic patterns and to investigate threats, mischief, or “attacks” directed at our site or to our visitors.

Section VIII: External Links

8. External Links

We may provide links on the website, via advertising and otherwise, to third-party websites that are not under our control. Empyreal does not endorse or make any warranty of any type regarding the content contained on such third-party websites or products and services offered therein. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of such third-party websites. Users should be aware when they leave the Empyreal site and should read the privacy statements of each and every Web site that may collect personally identifiable information. The privacy statement set forth herein applies solely to information collected by us.

Section VIII: Customer Responsibility

9. Customer Responsibility

You may be provided with a unique identifier such as an user name, account number, password, or “PIN” (personal identification number), which is intended to authenticate your identity when accessing our systems. Such identifying items are intended to be secret and to be known, possessed, and used only by you. The effectiveness of these mechanisms for authenticating your identity depends on the maintenance of the confidentiality of these identifying items. Accordingly, these identifying items should be kept in your exclusive possession, carefully protected from the discovery, access, or possession of others. Failure to keep such identifying information in your exclusive possession renders you responsible for the actions of other persons who use this information to access Empyreal’s systems. Should you become aware or have reason to suspect that a personal identifier has been lost or disclosed to a third-party, you should notify us immediately.

Section X: Changes to Privacy Policy

10. Changes to Information Security and Privacy Statement

In order to ensure that our information security and privacy policies are appropriate and effective and that these policies reflect the ongoing changes in our industry, we review our policies and practices from time to time and may make changes to these policies and practices as we determine them to be warranted. When changes are made that affect this Privacy Statement, our website will reflect such changes.

Section XI: Use of Customer Information

11. Use of Customer Personal Information

You can choose not to allow Empyreal to use your personal information for direct marketing purposes by indicating your preference at the time of collection, by responding to the promotional email in the manner provided for or by contacting our Privacy Officer in the manner described below.

Empyreal may periodically send you information about various products and services as directed by you via email. If you would like to “Opt-Out” of these mailings, please see our Opt-Out information at the end of this document.

Section XII: Disclosure and Sharing of Information

12. Disclosure and Sharing of Information

Empyreal also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal or financing of all or any portion of Empyreal or of any of the business or assets or shares/units of Empyreal or a division thereof in order for you to continue to receive the same products and services from the third party.

Section XIII: Access of Information

13. Access of Information

You may contact our Privacy Officer in the manner described below in order to access, correct or update your personal or business information.

Section XIV: Contact Information

14. Contact Information

If you have any questions, concerns, or wish to opt out of direct marketing, please contact our Privacy Officer, who can be reached at:

To opt out of direct marketing please contact Empyreal by mail at Empyreal Enterprises LLC

Attn: Privacy Officer

P.O. Box 101111

Denver, CO 80250

Or by email to: privacy@empyreallogistics.com

California Privacy Policy

Empyreal Enterprise, LLC’s California Privacy Policy

Effective Date: September 1, 2025

This California Privacy Policy describes how Empyreal Enterprise, LLC d/b/a Empyreal Logistics ("Empyreal," "we," or "us") collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act ("CCPA") requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, and sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This Privacy Policy does not apply to our collection and use of personal information in an employment capacity. Employees, job applicants, contractors, interns, or other workers seeking more information our employment-related personal information policies and practices should see our employee privacy notice in the Empyreal California Employee Handbook.

This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy notice here.

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). Personal information does not include:

Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
Lawfully obtained, truthful information that is a matter of public concern.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act.]

Personal Information Categories

The information below identifies which categories of personal information we collected from our consumers within the last 12 months.

A. Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, driver's license number, passport number, or other similar identifiers.

Collected? YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records").

Examples: A name, signature, address, and telephone number

Collected? YES

C. Protected classification characteristics under California or federal law ("Protected Classes").

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision making, military and veteran status, or genetic information (including familial genetic information).

Collected? NO

D. Commercial information.

Examples: Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected? YES

E. Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected? NO

F. Internet or other similar network activity.

Examples: Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.

Collected? YES

G. Geolocation data.

Examples: Physical location or movements, such as the time and physical location related to use of our internet website, application, or device, and GPS location data from mobile devices of consumers who visit our websites or use our mobile apps.

Collected? YES

H. Sensory data.

Examples: udio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring and store video surveillance.

Collected? NO

I. Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected? NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99) ("FERPA Information").

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected? NO

K. Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected? NO

L. Sensitive personal information.

Examples: Further identified in the chart below.

Collected? NO

Sensitive Personal Information Categories

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The information below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

L.1. Government identifiers, such as your driver's license, state identification card, or passport number, if provided as part of the onboarding process for services.

Collected to Infer Characteristics? YES

L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.

Collected to Infer Characteristics? YES

L.3. Precise geolocation, such as physical store visits or physical locations when visiting websites or using mobile apps.