Privacy Policy

Trajan Asset Holdings, LLC  ·  Effective June 8, 2026  ·  Last updated June 8, 2026

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01 Introduction

Trajan Asset Holdings, LLC (“Trajan Holdings,” “we,” “our,” or “us”) respects your privacy and is committed to handling personal information responsibly and with discretion. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at trajanholdings.com (the “Site”) or otherwise interact with us (collectively, the “Services”).

Trajan Holdings is a privately held holding company headquartered in Sheridan, Wyoming. We operate with the discretion of a private family office and maintain a deliberately minimal public footprint. The Site is informational in nature and is not used to solicit investment, offer securities, or provide financial, legal, or tax advice to the public.

By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Site.

02 Scope

This Privacy Policy applies to information we collect through:

• The Site and any pages or features made available through it;
• Email and other written correspondence directed to us, including messages sent to legal@trajanholdings.com; and
• Any other interactions you may have with Trajan Holdings in connection with the Services.

This Privacy Policy does not apply to information collected by any third party, including third parties whose websites or services may be linked from the Site. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy notices independently.

03 Information We Collect

We collect only the information reasonably necessary to operate the Site, respond to inquiries, and protect the integrity of our Services.

3.1 Information You Provide Directly

When you contact us — for example, by emailing legal@trajanholdings.com or otherwise corresponding with us — you may voluntarily provide:

• Your name;
• Your email address and other contact details;
• Your employer, role, or professional affiliation;
• The content of your message and any attachments; and
• Any other information you choose to share.

You are under no obligation to provide personal information, but doing so may be necessary for us to respond to your inquiry.

3.2 Information Collected Automatically

When you access the Site, certain information may be collected automatically by our hosting provider and supporting infrastructure, including:

• Internet Protocol (IP) address;
• Browser type and version;
• Device and operating system information;
• Referring URL and pages viewed on the Site;
• Date, time, and duration of your visit; and
• General geographic location inferred from IP address (e.g., country or region).

This information is generally collected in aggregated or pseudonymous form and is used for security, troubleshooting, and basic analytics purposes.

3.3 Cookies and Similar Technologies

The Site may use a limited number of cookies or similar technologies that are strictly necessary for the Site to function or that help us understand basic usage patterns. We do not use cookies for advertising or cross-site behavioral tracking.

You may set your browser to refuse some or all cookies or to alert you when cookies are being sent. If you disable or refuse cookies, some portions of the Site may become inaccessible or function improperly.

3.4 Information from Third Parties

We generally do not purchase or receive personal information about Site visitors from third-party data brokers. In limited circumstances, we may receive information about you from professional intermediaries, advisors, or counterparties in connection with a potential business relationship.

04 How We Use Information

We use the information we collect for the following purposes:

• To respond to inquiries. To reply to messages sent to legal@trajanholdings.com or otherwise directed to us, and to maintain related correspondence records.
• To operate the Site. To provide, maintain, secure, and improve the Site and its features.
• To analyze usage. To understand how visitors interact with the Site in an aggregated manner and to make informed decisions about Site design and content.
• To protect our interests. To detect, prevent, investigate, and address security incidents, fraud, abuse, unauthorized access, and other unlawful or harmful activity.
• To comply with legal obligations. To comply with applicable laws, regulations, court orders, subpoenas, and other lawful requests, and to enforce our rights and agreements.
• For other legitimate business purposes. Such as record-keeping, audits, due diligence, and the evaluation of potential business relationships.

We do not sell personal information, and we do not share personal information with third parties for cross-context behavioral advertising.

05 Legal Bases for Processing (EEA / UK Visitors)

If you are located in the European Economic Area or the United Kingdom, we process your personal information on one or more of the following legal bases under applicable data protection law:

• Consent. Where you have given us clear consent to process your personal information for a specific purpose.
• Contract. Where processing is necessary to take steps at your request prior to entering into, or to perform, a contract.
• Legal obligation. Where processing is necessary for compliance with a legal obligation to which we are subject.
• Legitimate interests. Where processing is necessary for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests — for example, to operate and secure the Site, communicate with you, and protect our business.

06 How We Share Information

We treat information about you with discretion and share it only as described below:

• Service providers. We may share information with third-party vendors that provide services on our behalf, such as website hosting, email delivery, security monitoring, IT support, and professional advisors (e.g., legal, accounting, and compliance counsel). These providers are bound by appropriate confidentiality and data protection obligations.
• Affiliates and portfolio entities. We may share information with our affiliates and entities within the Trajan Holdings portfolio where reasonably necessary in connection with the purposes described in this Privacy Policy.
• Business transactions. In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, information may be transferred or disclosed to participants in the transaction, subject to customary confidentiality protections.
• Legal and regulatory disclosures. We may disclose information where we believe in good faith that disclosure is required or permitted by law, regulation, legal process, or governmental request, or to establish, exercise, or defend legal claims.
• Protection of rights. To protect the rights, property, or safety of Trajan Holdings, our affiliates, our personnel, or others.
• With your consent. With your direction or consent in any other circumstance.

We do not sell personal information for monetary consideration, and we do not share personal information for purposes of targeted advertising.

07 Third-Party Links and Services

The Site may contain links to websites or resources operated by third parties. We provide such links for convenience and information only. We do not control, endorse, or assume responsibility for the content, privacy practices, or terms of any third-party site or service. We encourage you to review the privacy notices of any third party before providing information.

08 Data Retention

We retain personal information only for as long as is reasonably necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, regulatory, or reporting obligations, to resolve disputes, and to enforce our agreements.

When personal information is no longer required, we will take reasonable steps to delete, anonymize, or securely store it in a manner that prevents further use.

09 Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security, and you transmit information to us at your own risk.

If you have reason to believe that your interaction with us is no longer secure, please contact us promptly at legal@trajanholdings.com.

10 International Data Transfers

Trajan Holdings is based in the United States, and our Services are intended primarily for use within the United States. If you access the Site from outside the United States, please be aware that information we collect may be transferred to, stored in, and processed in the United States or other jurisdictions whose data protection laws may differ from those of your country.

Where required by applicable law, we will implement appropriate safeguards for cross-border transfers of personal information.

11 Your Rights and Choices

Depending on where you reside, you may have certain rights regarding your personal information.

11.1 General Choices

You may always choose not to provide personal information to us, although doing so may limit our ability to respond to inquiries or otherwise communicate with you. You may also unsubscribe from any non-essential correspondence by replying to the relevant message or contacting us directly.

11.2 Rights Under U.S. State Privacy Laws (Including California)

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or another U.S. state with a comprehensive consumer privacy law, you may have the following rights, subject to applicable exceptions:

• Right to know / access. The right to request confirmation of whether we process personal information about you and to access that information.
• Right to correct. The right to request correction of inaccurate personal information.
• Right to delete. The right to request deletion of personal information we have collected about you.
• Right to portability. The right to receive a copy of certain personal information in a portable format.
• Right to opt out of sale or sharing. The right to opt out of the sale or sharing of personal information. As noted above, we do not sell personal information or share it for cross-context behavioral advertising.
• Right to non-discrimination. The right not to receive discriminatory treatment for exercising your privacy rights.

To exercise any of these rights, please contact us at legal@trajanholdings.com. We will respond to verifiable requests as required by applicable law. We may need to verify your identity before fulfilling certain requests.

11.3 Rights Under EEA / UK Data Protection Law

If you are located in the European Economic Area or the United Kingdom, you may have the right to:

• Access the personal information we hold about you;
• Request rectification of inaccurate or incomplete information;
• Request erasure of your personal information in certain circumstances;
• Restrict or object to certain processing activities;
• Request data portability where applicable;
• Withdraw consent at any time where processing is based on consent (without affecting the lawfulness of prior processing); and
• Lodge a complaint with your local data protection authority.

To exercise any of these rights, please contact us at legal@trajanholdings.com.

12 Children’s Privacy

The Site is not directed to children under the age of sixteen (16), and we do not knowingly collect personal information from children. If you believe a child has provided personal information to us, please contact legal@trajanholdings.com and we will take appropriate steps to delete it.

13 Do Not Track

Some browsers offer a “Do Not Track” (“DNT”) signal. Because there is not yet a common industry or legal standard for recognizing or honoring DNT signals, the Site does not currently respond to them. We will continue to monitor developments in this area.

14 No Offer of Securities or Financial Services

Nothing on the Site constitutes an offer to sell, or a solicitation of an offer to buy, any security or investment product, nor does it constitute financial, legal, tax, or other professional advice. The Site is provided for general informational purposes only, in keeping with the discreet, relationship-driven nature of our business.

15 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we do, we will revise the “Last Updated” date above and post the revised policy on the Site. Material changes will be communicated through reasonable means. Your continued use of the Site following the posting of an updated Privacy Policy constitutes your acknowledgment of the changes.

16 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, please contact us at:

Trajan Asset Holdings, LLC
Sheridan, Wyoming
legal@trajanholdings.com

This Privacy Policy is provided as a general statement of our practices and does not create any contractual or other legal rights on behalf of any party.