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PRIVACY POLICY

OPOLIS, INC.

PRIVACY POLICY

Last Updated: June 4, 2026

Employment Commons LCA is a Colorado public benefit limited cooperative association. Opolis, Inc., a Delaware corporation, serves as the designated Trustee of Employment Commons LCA and administers all operations, services, technology, and affairs on its behalf. In its capacity as Trustee, Opolis, Inc. is the data controller and custodian of all personal information collected in connection with the platform and services described in this Privacy Policy. This document is presented by Opolis, Inc. in its capacity as Trustee.

  1. INTRODUCTION This Privacy Policy applies to Opolis, Inc., a Delaware corporation, including its affiliates and assigns (“Opolis,” “we,” “us,” or “our”). Registered Address: Opolis, Inc. 1580 N. Logan St., Ste 660, #93720 Denver, CO 80203

    1. Opolis provides administrative and operational services that support employment, payroll, insurance, and related shared services for organizations and their members and/or employees.

    2. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you access or use Opolis websites, products, services, and platforms (collectively, the “Services”).

    3. By using the Services, you acknowledge that your personal information may be collected, processed, stored, and transferred within the United States as described in this Privacy Policy.

    4. This Privacy Policy is incorporated by reference into our Terms of Service available at https://opolis.co/terms-of-service. Where data protection laws grant you specific rights (including under the GDPR, CPA, or CCPA/CPRA), this Privacy Policy controls to the extent of any conflict.

  2. INFORMATION WE COLLECT

    1. Personal Information You Provide We may collect personal information that you voluntarily provide, including:

      1. First and last name

      2. Email address

      3. Phone number

      4. Date of birth

      5. Mailing address (street, city, state, ZIP code)

      Depending on the Services you use, we may also collect:

      1. Social Security number or tax identification number

      2. Bank account information for payroll or payments

      3. Employment history, compensation, and tax information

      4. Benefits enrollment information, including health information

      5. Immigration and work authorization documentation

      6. Disability or accommodation information (where applicable)

      7. Other information required to provide Services or comply with legal obligations

    2. Sensitive Personal Information Where required by law, we collect and process sensitive personal information only with your affirmative, opt-in consent or another lawful basis, including for:

      1. Payroll and tax administration

      2. Benefits administration

      3. Employment law compliance

      You may withdraw consent at any time by contacting support@opolis.co, subject to legal or contractual limitations.

    3. Information Collected Automatically When you use the Services, we may automatically collect:

      1. IP address

      2. Browser type and operating system

      3. Device identifiers

      4. Access times and referring URLs

      5. Pages viewed and interactions

      6. Cookies and similar tracking technologies

      This information is used for security, analytics, service improvement, and functionality.

  3. LEGAL BASES FOR PROCESSING (GDPR) Where the GDPR applies, we process personal data based on one or more of the following legal grounds:

    1. Performance of a contract

    2. Compliance with legal obligations

    3. Legitimate business interests (balanced against individual rights)

    4. Your consent

  4. USE OF PERSONAL INFORMATION We use personal information to:

    1. Provide and operate the Services

    2. Process payroll, benefits, and payments

    3. Verify identity and eligibility

    4. Communicate with you about your account or Services

    5. Comply with legal and regulatory requirements

    6. Improve our products and Services

    7. Prevent fraud and ensure security

    Marketing communications are sent only where permitted by law, and you may opt out at any time.

  5. COOKIES AND TRACKING TECHNOLOGIES We may use cookies and similar technologies to support functionality, analytics, and user experience. Where required by law, we obtain consent for non-essential cookies. You can manage cookie preferences through your browser or device settings.

  6. SHARING OF INFORMATION We may share personal information:

    1. With affiliates and service providers who perform services on our behalf

    2. With payment processors (e.g., Dwolla, Stripe, Plaid, or other providers disclosed at onboarding)

    3. As required by law, regulation, or legal process

    4. In connection with a merger, acquisition, or asset sale

    5. With your consent

    We do not sell personal information for monetary consideration.

  7. INTERNATIONAL DATA TRANSFERS Personal information is processed and stored in the United States. Where required, international transfers are safeguarded using Standard Contractual Clauses or other lawful transfer mechanisms recognized under applicable data protection laws.

  8. DATA RETENTION We retain personal information only for as long as necessary to:

    1. Provide the Services

    2. Comply with legal, tax, and employment obligations

    3. Resolve disputes and enforce agreements

    Unless otherwise required by law, personal information is retained for up to seven (7) years following account closure.

  9. BLOCKCHAIN AND ONCHAIN DATA Some services involve recording data on public blockchain networks, including wallet addresses and token transactions ("Onchain Data"). Onchain Data is not collected or controlled by Opolis, Inc. and is outside the scope of this Privacy Policy. Due to the immutable nature of blockchain technology, Onchain Data cannot be modified or deleted, and privacy rights requiring deletion do not apply to such data.

  10. SECURITY We implement administrative, technical, and physical safeguards designed to protect personal information, including:

    1. Role-based access controls and multi-factor authentication

    2. Encrypted data transmission using SSL/TLS

    3. Secure, non-public data storage with regular backups and defined retention limits

    4. Network protections such as firewalls, monitoring, and threat prevention

    5. Ongoing system updates, access reviews, and incident response procedures

    We continuously evaluate and improve our security practices to protect personal data from unauthorized access, use, or disclosure. No method of transmission or storage is entirely secure, and we cannot guarantee absolute security.

  11. YOUR PRIVACY RIGHTS

    1. Colorado Privacy Act (CPA) Colorado residents have the right to:

      1. Access personal data

      2. Correct inaccuracies

      3. Delete personal data

      4. Obtain a portable copy

      5. Opt out of targeted advertising, profiling, or certain data processing

      Appeal Rights: If we deny a request, you may appeal by emailing support@opolis.co with “Colorado Privacy Appeal” in the subject line. We will respond within 45 days.

    2. California Privacy Rights (CCPA / CPRA) California residents have the right to:

      1. Know what personal information we collect and use

      2. Request deletion or correction

      3. Opt out of the sale or sharing of personal information

      4. Limit use of sensitive personal information

      5. Be free from discrimination for exercising rights

      Requests may be submitted to support@opolis.co.

    3. GDPR Rights (EEA/UK Residents) Where applicable, you may request access, correction, deletion, restriction, portability, or object to processing by contacting support@opolis.co.

  12. CHILDREN’S PRIVACY The Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18, except where required to administer benefits for dependents.

  13. THIRD-PARTY LINKS The Services may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their policies.

  14. CHANGES TO THIS POLICY We may update this Privacy Policy from time to time. Material changes will be communicated via email or prominent notice before taking effect.

  15. CONTACT US If you have questions or wish to exercise your privacy rights, contact us at: Email: support@opolis.co Mail: Opolis, Inc. Attn: Data Privacy 1580 N. Logan St., Ste 660, #93720 Denver, CO 80203

© 2026 OPOLIS, INC.

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