Privacy Policy

This Privacy Policy explains what information Frontieras North America, Inc. (“Frontieras,” “we,” “our”) collects when you use the FASForm 6-1 Spread Calculator dashboard (the “Service”), how we use that information, and what choices you have. The Service is provided as an access-controlled tool for qualified institutional investors evaluating Frontieras’ proprietary processing margin framework.

1. Information We Collect

1.1 Information you provide to us

When you request access to the Service, we collect:

• Identification: your full name, organization, professional title, and phone number (optional)
• Email address used to create your account
• Password (stored as a salted hash; we never see the plaintext)
• Investor type self-certification: whether you are a Qualified Institutional Buyer (Rule 144A), an accredited individual investor (Rule 501(a)), an accredited entity investor (Rule 501(a)(1)-(3),(7)-(13)), or do not qualify
• Legal acknowledgments: a timestamped record of every Privacy Policy, Terms of Service, No-Reliance Notice, and Investor Acknowledgment you accept, including the version accepted and the IP address used

1.2 Information we collect automatically

When you use the Service, we automatically collect:

• Account-activity telemetry: sign-in and sign-out events, the IP address used, the device user-agent (browser and operating system), and the time each event occurred
• Behavioral analytics: page views (URL path, referrer), and interaction events on the calculator (slider adjustments, chart period selections, scenario resets, methodology section opens). Each event includes a per-tab session identifier, your assigned user identifier, a timestamp, and the page on which it occurred
• Session cookies: a single HTTP-only, Secure, SameSite-Lax cookie named fasform_supabase_session that contains a JSON Web Token authenticating your session. The cookie has a 7-day maximum lifetime and is not used for cross-site tracking

1.3 AI-derived analytical content

To assist Frontieras’ investor relations team in understanding institutional interest in the FASForm 6-1 framework, the behavioral analytics described in Section 1.2 may be summarized with the assistance of artificial-intelligence services. These services receive the structured event stream and produce a short narrative describing the scenarios you appeared to test (for example, downside stress tests or bull-case modeling). The generated summary is stored in our database and may be shown to Frontieras administrators. Our AI service providers are bound by data-processing terms that prohibit them from retaining your information or using it to train their models.

2. How We Use Information

• Provide and secure the Service — authenticate you, maintain your session, prevent unauthorized access
• Understand institutional engagement — analyze how qualified investors use the calculator to inform investor relations strategy
• Maintain SEC and regulatory audit trail — preserve immutable records of which investors viewed which materials at which times, in support of Frontieras’ obligations under Regulation A, Regulation D, the Securities Act of 1933, and the Securities Exchange Act of 1934
• Send transactional communications about your account — signup confirmation, approval, denial, password reset, security alerts, and changes to these policies. These are not marketing emails and do not require separate consent
• Send marketing and outreach communications — only if you have given separate opt-in consent at signup. This may include updates on Frontieras’ capital raise, follow-up about your evaluation of the Service, invitations to events or briefings, and similar communications. You may withdraw this consent at any time using the unsubscribe link in any such email or by emailing investor.relations@frontieras.com
• Comply with law, valid legal process, and reasonable requests from law enforcement or regulators

3. How We Share Information

We do not sell, rent, or lease your personal information. We share information only as follows:

• Frontieras personnel with a need to know (executive, finance, IR, legal, IT)
• Service providers we use to operate the platform: Supabase (database and authentication hosting), Railway (application hosting), and artificial-intelligence service providers that assist with the analytics summaries described in Section 1.3 — each bound by contract or terms of service to use your information only to provide their service to us
• Auditors, underwriters, and counsel in connection with capital-markets activities, subject to confidentiality
• Government agencies and regulators if required by law, court order, or valid subpoena, or to protect rights and safety
• Successors in the event of merger, acquisition, financing, sale of assets, or similar transaction

4. How Long We Retain Information

• Account records and legal acknowledgments: retained for the longer of the period during which you have an account or seven (7) years after account closure, to satisfy SEC books-and-records requirements
• Behavioral analytics and AI-derived summaries: retained for the longer of three (3) years after generation or the period required by applicable securities law
• Authentication telemetry (sign-ins, sign-outs): retained for one (1) year for security purposes
• Audit-trail records (admin actions taken on your account): retained indefinitely for SEC compliance

5. How We Protect Information

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Specifically:

• All Service traffic is encrypted in transit over HTTPS (TLS 1.2 or higher)
• Database storage uses provider-managed encryption at rest
• Session tokens are HTTP-only and Secure-flagged
• Role-based access controls and database row-level security (RLS) restrict who can read which records
• Administrative actions on user records are timestamped and immutable

No method of electronic transmission or storage is 100% secure; we cannot guarantee absolute security.

6. Your Rights and Choices

You may, at any time and free of charge, request:

• Access to the personal information we hold about you
• Correction of inaccuracies in your account profile
• Deletion of your account, subject to our right to retain certain records for legal, audit, or compliance purposes
• Portability — a copy of the information you provided to us in a structured, machine-readable format
• Withdrawal of consent — though this may terminate your access to the Service

To exercise any of these rights, contact us using the details in Section 11.

7. Cookies and Similar Technologies

We use a single essential session cookie (fasform_supabase_session) to authenticate you. We do not use third-party advertising cookies, marketing pixels, or cross-site tracking technologies. Disabling this cookie will prevent you from signing in.

8. International Users

The Service is hosted in the United States. If you access it from outside the United States, your information will be transferred to, stored, and processed in the United States. By using the Service, you consent to this transfer.

9. Children

The Service is offered only to persons who are 18 years of age or older and who meet the qualified-investor criteria. We do not knowingly collect information from minors.

10. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will publish the new version with an updated effective date and version identifier. Material changes will be communicated to active users by email, and continued use of the Service after the effective date constitutes acceptance of the revised policy. You will be required to re-acknowledge the new version on your next sign-in.

11. Contact

Questions about this Privacy Policy may be directed to:

Frontieras North America, Inc.
Attn: Investor Relations — Privacy
Email: investor.relations@frontieras.com