Privacy Policy

SWING TRUST Privacy Policy Effective Date: July 20, 2026 Operated by DrkGrws LLC

This Privacy Policy explains how DrkGrws LLC ("Swing Trust," "we," "us," or "our") collects, uses, shares, and protects your personal information when you visit swingtrust.com, create an account, purchase a subscription, or otherwise use the Swing Trust trading-education and simulation program (the "Service"). By using the Service, you agree to the practices described in this policy.

1. Information We Collect We collect information you provide directly, information collected automatically as you use the Service, and information from third-party service providers. Information you provide to us: • Account information — such as your name, email address, and password when you register. • Payment information — such as your billing details and transaction records. Payment card numbers are processed by our payment processor and are not stored on our servers. • Communications — messages, support tickets, and any information you submit when you contact us or participate in live sessions or community features. Information collected automatically: • Usage and device data — IP address, browser type, device information, pages viewed, referring URLs, and usage patterns, collected through cookies and analytics tools. • Simulation and learning data — activity within the simulated trading environment, course progress, and feature usage, which we use to operate and improve the Program. • Cookies and similar technologies — we and our analytics providers use cookies and similar technologies to run the Service, remember your session, and understand how the Service is used.

2. How We Use Your Information We use the information we collect to: • Provide, operate, and maintain the Service, including your account and access to educational content and the simulation environment. • Process your subscription payments and manage billing and renewals. • Send you transactional and account-related communications, such as receipts, password resets, and service notices. • Send you program-related updates and, where permitted, marketing communications (which you may opt out of). • Respond to your inquiries and provide customer support. • Analyze usage to improve, personalize, and secure the Service. • Detect, prevent, and address fraud, abuse, security issues, and violations of our Terms. • Comply with legal obligations and enforce our agreements.

3. How We Share Your Information We do not sell your personal information. We share information only in the limited circumstances described below: • Service providers — with third parties that help us operate the Service — for example, payment processing (Stripe), email delivery (Resend), analytics (Google Analytics), and hosting. These providers may access your information only to perform services on our behalf. • Business transfers — if we are involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. • Legal requirements — when required by law, subpoena, or other legal process, or to protect the rights, property, or safety of Swing Trust, our users, or others. • With your consent — we may share information for any other purpose disclosed to you at the time we collect it or with your consent.

4. Third-Party Services The Service relies on third-party providers that have their own privacy policies governing how they handle your data. These include, among others, Stripe (payment processing), Resend (email), and Google Analytics (usage analytics). We encourage you to review the privacy policies of these providers. We are not responsible for the privacy practices of third-party websites or services that may be linked from the Service.

5. Cookies and Tracking Technologies We use cookies and similar technologies to keep you signed in, remember preferences, measure and analyze traffic, and improve the Service. You can control cookies through your browser settings; however, disabling certain cookies may affect how the Service functions. Analytics providers may set their own cookies to measure usage in aggregate.

6. Data Retention We retain your personal information for as long as your account is active or as needed to provide the Service, and thereafter as necessary to comply with our legal obligations, resolve disputes, maintain business and financial records, and enforce our agreements. When information is no longer needed, we take reasonable steps to delete or de-identify it.

7. Data Security We use reasonable administrative, technical, and organizational measures designed to protect your personal information against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage over the internet is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

8. Your Privacy Rights Depending on where you live, you may have rights regarding your personal information, including the right to access, correct, delete, or receive a copy of the information we hold about you, and the right to opt out of certain uses. To exercise any of these rights, contact us at the address below. We will respond consistent with applicable law and may need to verify your identity before acting on your request. California residents. If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA/CPRA), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the "sale" or "sharing" of personal information. As noted above, we do not sell your personal information. To exercise your rights, contact us at support@swingtrust.com.

9. Your Communication Choices You may opt out of marketing emails at any time by using the unsubscribe link in those messages or by contacting us. Even if you opt out of marketing, we may still send you transactional or account-related messages that are necessary to operate the Service, such as billing notices and security alerts.

10. Children's Privacy The Service is intended for adults aged 18 and older and is not directed to children. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will take steps to delete it. If you believe a minor has provided us information, please contact us.

11. International Users The Service is operated from the United States. If you access the Service from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data-protection laws may differ from those in your jurisdiction. By using the Service, you consent to this transfer.

12. Changes to This Privacy Policy We may update this Privacy Policy from time to time. When we do, we will revise the "Effective Date" above and, where appropriate, provide additional notice through the Service or by email. Your continued use of the Service after the changes take effect constitutes your acceptance of the updated policy.

13. Contact Us If you have questions or requests regarding this Privacy Policy or your personal information, contact us at: DrkGrws LLC Email: support@swingtrust.com Website: swingtrust.com By using Swing Trust, you acknowledge that you have read and understood this Privacy Policy