PRIVACY POLICY

PRIVACY POLICY

Last Updated: March 16, 2026

1. Introduction

101 MGMT, LLC ("Company," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit or use 101co.com and any related pages, features, content, applications, products, or services that link to this Privacy Policy (collectively, the "Services").

This Privacy Policy does not cover websites, apps, or services that link to or are operated by third parties.

2. Who we are (controller/ business)

Company Name: 101 MGMT, LLC, a Delaware Limited Liability Company

Address: One Towne Square, 5th Floor, Southfield, MI 48076

Email: contact@101co.com

3. Information we collect

We collect personal information from you and about your use of the Services.

A. Information you provide

- Contact details (e.g., name, email, phone number, company)

- Form submissions (e.g., inquiries, support requests, demo requests)

B. Information collected automatically

- Device and usage data (e.g., IP address, device identifiers, browser type, operating system, pages viewed, time spent, links clicked, referring URLs)

- Approximate location inferred from IP address

- Log data and security data (e.g., audit logs, authentication events)

C. Cookies and similar technologies

We and our partners may use cookies, pixels, SDKs, local storage, and similar technologies to:

- Provide core functionality and security

- Remember preferences

- Understand usage and performance

- Measure marketing effectiveness (if enabled)

See Section 5 for details and your choices.

D. Information from third parties (optional)

We use personal information to:

- Provide, operate, maintain, and improve the Services

- Respond to inquiries 

- Analyze performance and usage trends

- Detect, prevent, and investigate fraud, security incidents, and misuse

- Comply with legal obligations and enforce our agreements

4. How we use information

We use personal information to:

- Provide, operate, maintain, and improve the Services

- Respond to inquiries 

- Analyze performance and usage trends

- Detect, prevent, and investigate fraud, security incidents, and misuse

- Comply with legal obligations and enforce our agreements

5. Cookies, Analytics, and Preferences

A. Cookie categories

- Strictly Necessary: required for the Services to function (security, network management, basic site functionality)

- Analytics: helps us understand usage and improve the Services

- Marketing: used to measure campaigns and deliver relevant advertising (if enabled)

- Preferences: remembers choices to improve experience

B. Managing cookies and tracking

You can control cookies and similar technologies by:

- Adjusting your browser settings (note: strictly necessary cookies may still be required)

- Using opt-out mechanisms described in Section 8 

C. Do Not Track

Some browsers offer a "Do Not Track" signal. Our Services may not respond to all such signals.

6. How we disclose information

We may disclose personal information to:

- Service providers/processors that help us run the Services (hosting, analytics, CRM, email delivery, customer support, security)

- Affiliates (if applicable)

- Authorities or other parties when required by law or to protect rights, safety, and security

7. International Transfers

If you access the Services from outside the United States, your information may be transferred to and processed in countries where we or our service providers operate. Where required, we use appropriate safeguards for international transfers.

8. Your privacy rights and choices

Your rights depend on where you live.

Because we do not ‘sell’ or ‘share’ your personal information as those terms are defined under California law, certain opt-out rights may not apply to our current practices.

A. California (CCPA/CPRA) – if applicable

California residents may have rights to:

- Know/access personal information we collect, use, and disclose

- Delete personal information (subject to exceptions)

- Correct inaccurate personal information

- Opt out of the "sale" or "sharing" of personal information (as defined by law)

- Limit the use/disclosure of sensitive personal information (where applicable)

- Not be discriminated against for exercising rights

How to exercise rights:

- Submit a request: email contact@101co.com

- Verification: We may verify your request using information you provide.

Authorized agents:

- You may use an authorized agent to submit certain requests on your behalf, subject to verification.

Residents of other U.S. states may have similar rights regarding their personal information under applicable state laws. You can contact us at contact@101co.com to exercise these rights, and we will respond as required by law.

B. EEA/UK (GDPR/UK GDPR) – if applicable

You may have rights to:

- Access, correct, delete, or restrict processing

- Object to processing

- Data portability

- Withdraw consent at any time (where processing is based on consent)

- Lodge a complaint with a supervisory authority

Legal Bases for Processing. Where GDPR or UK GDPR applies, we process your personal information on the following legal bases:

-Contractual necessity: to respond to your inquiries and provide the Services you request.

-Legitimate interests: to operate, secure, and improve the Services; to analyze usage trends; to detect and prevent fraud; and to communicate with you about the Services, where our interests are not overridden by your rights.

-Consent: for analytics and marketing cookies or other processing where we request your consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

-Legal obligation: to comply with applicable laws, regulations, and lawful requests from authorities.

C. Brazil (LGPD) – if applicable

You may have rights to confirm processing, access, correction, anonymization/blocking/deletion (where applicable), portability, information about sharing, and other rights under LGPD.

D. Marketing communications

You can opt-out of marketing emails by contacting us at contact@101co.com. You may still receive transactional or service-related messages.

9. Data retention

We retain personal information only as long as necessary for the purposes described in this Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements.

Retention periods may vary depending on the type of data and purpose.

10. Security

We use administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure.

11. Children's Privacy

The Services are not directed to children under the age of 18. We do not knowingly collect personal information from children under that age. If you believe a child has provided us personal information, contact us at contact@101co.com

Our Services are intended for use by adults, including institutional and sophisticated investors.

12. Changes to this privacy policy

We may update this Policy from time to time. We will post the updated version and revise the "Last Updated" date. Material changes may be communicated through the Services or by email.

13. Contact Us

For questions or requests regarding this Privacy Policy:

Email: contact@101co.com

© 2026, 101 MGMT, LLC. All rights reserved.

© 2026, 101 MGMT, LLC. All rights reserved.

© 2026, 101 MGMT, LLC.
All rights reserved.