Legal

Privacy Policy

The Attention Capital Corporation — Effective Date: April 11, 2026

This Privacy Policy describes how The Attention Capital Corporation ("Attention Capital," "Company," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with attncap.com (the "Site") and the sale of research products, subscriptions, and related services.

Section 1

Scope

This Privacy Policy applies to personal information we collect:

This Privacy Policy does not apply to third parties that operate independently of us to the extent they process information under their own terms, notices, and legal obligations.

Section 2

Site Architecture

The Site is a public-facing website. It does not currently provide user accounts, customer logins, or persistent member profiles. We do not operate third-party advertising scripts on the Site, and we do not use Site-collected personal information for behavioral advertising or cross-context behavioral advertising.

Section 3

Information We Collect

We collect a limited set of information necessary to operate the Site, process transactions, deliver purchased products, administer subscriptions, respond to inquiries, and protect our business.

A. Information Collected in Connection with Purchases

When you purchase a product through the Site, we may receive order-related information such as:

B. Payment Information

We do not receive or store full payment card credentials. Payment card numbers and other full payment credentials are collected and processed in the payment environment used to complete checkout, not by Attention Capital. We may receive limited transaction-related information, such as confirmation that payment was made, the product purchased, and certain billing or subscription status details, but we do not store full card numbers, bank account numbers, or card security codes.

C. Direct Communications

If you contact us directly, including through email, we may collect and retain the information you provide, such as your name, email address, company or organizational affiliation if provided, the contents of your message, attachments or documents you send us, and any follow-up correspondence.

D. Technical, Usage, and Security Information

When you visit the Site, our infrastructure and service providers may collect standard web traffic, device, and security-related information, such as IP address, browser type and version, device and operating system information, referring pages or URLs, pages requested or visited, date and time of requests, diagnostic and performance data, and security and fraud-prevention signals. This information is generally used to host, secure, route, optimize, and maintain the Site.

Section 4

Sources of Personal Information

We collect personal information directly from you; from payment and order processors; from hosting, security, and infrastructure providers; and automatically from your browser or device when you use the Site.

Section 5

How We Use Information

We use personal information for legitimate business purposes, including to:

We do not use personal information collected through the Site for third-party advertising, ad-tech profiling, or third-party marketing campaigns.

Section 6

How We Disclose Information

We do not sell personal information for money. We also do not share personal information for cross-context behavioral advertising based on our current Site operations. We may disclose personal information in the following limited circumstances:

Section 7

Cookies and Similar Technologies

The Site may use cookies and similar technologies that are necessary for core functionality, security, network management, fraud prevention, load balancing, and performance. We do not use analytics, advertising cookies, or cross-site tracking technologies beyond what is necessary for Site operation and security. Some cookies may be set by infrastructure providers and may be necessary to keep the Site secure and operational. Disabling certain cookies may affect Site functionality. If our practices change and we begin using non-essential cookies or similar tools, we will update this Privacy Policy and any required notices or consent mechanisms.

Section 8

Retention of Information

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to fulfill and document transactions; provide purchased products and subscription services; maintain appropriate business, tax, accounting, and legal records; resolve disputes; enforce agreements; and comply with applicable legal, tax, accounting, and regulatory obligations. Retention periods may vary depending on the nature of the information, the sensitivity of the data, the purpose for which it was collected, and our legal obligations. When we no longer reasonably need personal information, we may delete it, deidentify it, anonymize it, or securely archive it where deletion is not immediately practical.

Section 9

Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. These include limiting access to personal information to those with a legitimate business need, relying on specialized third-party providers for payment processing, using infrastructure and security services to protect Site traffic and availability, and maintaining reasonable internal controls over business records. However, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.

Section 10

International and Cross-Border Transfers

Attention Capital is a U.S.-based company. Personal information may be processed in the United States and in other jurisdictions where we or our service providers operate. If you access the Site from outside the United States, you understand that your information may be transferred to, stored in, and processed in countries that may have data protection laws different from those of your jurisdiction. Where applicable, we take reasonable steps to use appropriate safeguards for cross-border transfers as required by law.

Section 11

California Privacy Notice

This section applies to the extent Attention Capital is subject to applicable California privacy law.

11.1 Categories of Personal Information

Depending on how you interact with us, we may collect categories of personal information that include identifiers such as name, email address, IP address, and online identifiers; commercial information such as products purchased and order history; internet or electronic network activity information such as browser and Site interaction data; professional or employment-related information you choose to provide, such as company affiliation; and other information you provide in communications with us.

11.2 Purposes

We collect and use these categories for the business and commercial purposes described in Section 5 of this Policy.

11.3 Sale and Sharing

We do not sell personal information for money. We do not share personal information for cross-context behavioral advertising based on our current business model and current Site implementation.

11.4 Sensitive Personal Information

We do not knowingly use or disclose sensitive personal information for purposes that would require us to offer a separate right to limit under California law, based on the data practices described in this Policy. We do not receive or store full payment card credentials entered during checkout.

11.5 California Rights

Subject to applicable exceptions and verification requirements, California residents may have the right to request access to categories and specific pieces of personal information we have collected about them; information about sources, purposes, and categories of disclosures; deletion of certain personal information; correction of inaccurate personal information; and information about whether we sell or share personal information. To submit a privacy request, contact [email protected]. We will verify requests using commercially reasonable methods appropriate to the nature of the request and the sensitivity of the information. We will not require you to create an account to make a request.

Section 12

EEA, UK, and Similar Jurisdictions

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with similar data protection laws, you may have additional rights under applicable law. Depending on the circumstances, our processing may be based on one or more of the following lawful bases: performance of a contract or steps taken at your request before entering into a contract; compliance with legal obligations; our legitimate interests, including operating, securing, and improving the Site and administering transactions; or your consent where required by law. Subject to applicable law, you may have rights to request access, correction, deletion, restriction, objection, withdrawal of consent where processing is based on consent, and data portability. Nothing in this Policy is intended to expand or waive any legal standard, exemption, or defense available to Attention Capital.

Section 13

How to Exercise Rights

To submit a privacy request, contact [email protected] and include enough information for us to understand and evaluate your request. We may ask for additional information to verify your identity or authority. If you use an authorized agent where permitted by law, we may require proof of authorization and may take reasonable steps to verify the request. We will respond within the time required by applicable law.

Section 14

Children and Minors

The Site and our research products are intended for a professional and business audience and are not directed to children. We do not knowingly collect personal information from individuals under 18 years of age. If you believe a minor has provided personal information to us, please contact us so we can review and take appropriate action.

Section 15

Third-Party Services

We use third-party providers to support core Site and transaction functions, including payment processing, hosting, content delivery, DNS, security, and related operational services. Those providers may process personal information only as reasonably necessary to perform services for us or under their own independent legal terms where applicable.

Section 16

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, service providers, legal requirements, or Site functionality. When we do, we will update the Effective Date at the top of this page. Changes become effective when posted unless otherwise stated.

Section 17

Contact

For questions about this Privacy Policy or to submit a privacy-related request:

The Attention Capital Corporation

[email protected]