VIREO CLUB

Privacy Policy

Operated by DPB Firm LLC

Effective Date: April 2026

Last Updated: April 2026

This Privacy Policy describes how DPB Firm LLC ("Vireo Club," "we," "us," or "our") collects, uses, and protects information you provide when you access our website at vireoclub.com (the "Site") or submit a Founding Member Deposit. We are committed to protecting your privacy and complying with applicable law, including the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA").

1.  Information We Collect

1.1  Information You Provide Directly

When you use the Site or submit a Founding Member Deposit, we may collect:

• Full name

• Email address

• Payment information (processed and stored by our payment processor; Vireo Club does not store full card numbers)

• Any other information you voluntarily submit through contact forms or communications with us

1.2  Information Collected Automatically

When you visit the Site, we and our service providers may automatically collect certain technical information, including:

• IP address and approximate geographic location

• Browser type and version

• Operating system

• Pages viewed and time spent on the Site

• Referring URL (how you arrived at the Site)

• Device identifiers

This information is collected through standard server logs, cookies, and similar tracking technologies.

1.3  Cookies & Tracking Technologies

We may use cookies, web beacons, and similar technologies to operate and improve the Site, analyze usage patterns, and understand how visitors interact with our content. You may configure your browser to refuse cookies; however, some features of the Site may not function properly if you do so.

We do not currently use third-party advertising cookies or sell your data to advertisers. If this changes, we will update this Policy and provide notice as required by applicable law.

2.  How We Use Your Information

We use the information we collect for the following purposes:

• To process and manage your Founding Member Deposit

• To communicate with you about your deposit, membership conversion, and Vireo Club updates

• To send you emails about the progress of Vireo Club's launch and opening milestones

• To respond to your inquiries and customer service requests

• To operate, maintain, and improve the Site

• To detect, prevent, and address fraud, security issues, and technical problems

• To comply with legal obligations and enforce our Terms of Use

• To analyze Site usage and improve our offerings

We will not use your information for any purpose that is inconsistent with this Privacy Policy without your prior consent.

3.  How We Share Your Information

3.1  Service Providers

We share personal information with trusted third-party service providers who assist us in operating the Site and running the Founding Member Deposit program. These providers include:

• Payment processors (for processing deposit transactions)

• Email service providers (for sending membership and launch communications)

• Website hosting and analytics providers

Our service providers are contractually required to use your information only as necessary to provide services to us and to protect your information in accordance with applicable law.

3.2  Legal Requirements

We may disclose your information if required to do so by law or in response to a valid legal process (such as a court order or subpoena), or if we believe in good faith that disclosure is necessary to: protect our rights or property; prevent fraud or illegal activity; protect the safety of our users or the public; or comply with applicable law.

3.3  Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or a portion of DPB Firm LLC's assets, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control and your options with respect to your information.

3.4  No Sale of Personal Information

We do not sell, rent, or trade your personal information to third parties for their marketing or commercial purposes.

4.  Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Policy, including to maintain records of your deposit, process potential refunds, comply with legal obligations, resolve disputes, and enforce our agreements.

If you request a refund and do not convert your deposit to an active membership, we will retain a minimal record of your transaction for accounting and legal compliance purposes, and will delete or de-identify other personal information within a reasonable period following your refund.

5.  Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. Payment information is handled by our third-party payment processor and is subject to their security standards.

No method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. If you have reason to believe your interaction with us is no longer secure, please contact us immediately at contact@vireoclub.com.

6.  Your California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have the following rights with respect to your personal information under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

6.1  Right to Know

You have the right to request that we disclose what personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purposes for collecting it, and the categories of third parties with whom it is shared.

6.2  Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (such as information we are required to retain by law or that is necessary to complete a transaction you requested).

6.3  Right to Correct

You have the right to request that we correct inaccurate personal information we hold about you.

6.4  Right to Opt-Out of Sale or Sharing

We do not sell or share your personal information for cross-context behavioral advertising. You therefore have no opt-out right to exercise with respect to such activities.

6.5  Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not deny you goods or services, charge you different prices, or provide you a different level of service because you exercised your rights under the CCPA/CPRA.

6.6  How to Submit a Request

To exercise any of the rights described above, please contact us at:

Email: contact@vireoclub.com

Subject line: "California Privacy Rights Request"

We will respond to a verifiable consumer request within 45 days of receipt, as required by the CCPA. We may extend this period by an additional 45 days when reasonably necessary and with prior notice. We will not charge a fee for processing your request unless your request is excessive, repetitive, or manifestly unfounded.

To verify your identity, we may ask you to confirm the name and email address associated with your account or deposit. We cannot fulfill requests that we cannot verify.

7.  Children's Privacy

The Site is not directed at or intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information promptly. If you believe we may have collected information from a child under 18, please contact us at contact@vireoclub.com.

8.  Third-Party Links

Our Site may contain links to third-party websites, social media platforms, and services. This Privacy Policy applies only to information collected through our Site. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal information.

9.  Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Site's features. When we make material changes, we will update the "Last Updated" date at the top of this page. For depositors, we will provide notice via the email address on file. Your continued use of the Site following notice of any changes constitutes your acceptance of the revised Policy.

10.  Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Vireo Club — DPB Firm LLC

Email: contact@vireoclub.com

Website: vireoclub.com

This Privacy Policy is provided for informational purposes and does not constitute legal advice. Vireo Club recommends that this Policy be reviewed by qualified legal counsel before publication.