Privacy Policy

Effective Date: June 1, 2026

Randolph & Main Capital Group, LLC (“FraXion,” “FraXion Property Passport™,” “Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information and property-related data entrusted to us. This Privacy Policy explains how we collect, use, protect, disclose, and manage information when you access our website, use our platform, purchase our services, or interact with FraXion Property Passport™. By using our services, you agree to the practices described in this Privacy Policy.

1. Our Privacy Commitment

FraXion Property Passport is built on trust. We are committed to:

• Data Protection: Safeguarding client information.
• Data Minimization: Limiting data collection to what is strictly necessary.
• Security Controls: Maintaining strong administrative, technical, and physical security controls.
• Responsible Use: Using collected information ethically and responsibly.
• Transparency: Providing absolute clarity regarding our data practices.
• Legal Compliance: Fully complying with all applicable privacy laws.

2. Information We Collect

We collect several types of information from and about users of our platform, categorized as follows:

2.1 Personal Information

We may collect information that identifies or relates to an individual, including:

• Full name, email address, phone number, and mailing address.
• Business information and account credentials.
• User communication preferences.

2.2 Property Information

To provide Property Passport services, we may collect:

• Property address and parcel information.
• Property ownership information and documentation.
• Property characteristics, records, and history information.

2.3 User-Submitted Documents

Users may voluntarily upload documents to our platform, including:

• Deeds, title policies, closing documents, and surveys.
• Appraisals, inspection reports, and permit records.
• Renovation documentation and warranty records.

2.4 Technical & Usage Information

When you access our website or platform, we may automatically collect:

• IP address, device information, browser type, and operating system.
• Website activity, session information, cookies, and analytics data.

3. How We Use Information

The Company processes your information for the following specific business purposes:

• Service Delivery: Creating Property Passports, verifying ownership information, organizing property records, and delivering core platform functions.
• Communication: Responding to inquiries, providing account updates, sending service notifications, and delivering support communications.
• Platform Improvement: Enhancing user experience, improving platform functionality, developing new features, and monitoring service performance.
• Security & Compliance: Preventing fraud, detecting unauthorized activity, protecting client information, and meeting regulatory or legal obligations.

4. Information Sharing & Disclosure

FraXion does not sell personal information. We may share information only as necessary to provide services or comply with legal obligations under the following circumstances:

4.1 Service Providers

We share information with trusted third-party vendors who assist with cloud storage, customer support, payment processing, technology infrastructure, and security monitoring. These providers are contractually required to maintain appropriate safeguards.

4.2 Title & Verification Partners

Information may be shared with authorized title companies, verification partners, or service providers participating in the Property Passport verification process. Only information strictly necessary to perform required services will be shared.

4.3 Legal Requirements

We may disclose your information when required by court orders, subpoenas, government requests, applicable laws, or regulatory requirements.

5. Blockchain Data Disclosure

FraXion Property Passport™ may utilize blockchain technologies to support verification, timestamping, audit trails, and document validation.

• No Confidential Data: FraXion does not intentionally store confidential personal information directly on public blockchains.
• Recorded Data Type: Information recorded on blockchain systems may include document hashes, verification timestamps, audit references, and verification records.
• Purpose: Blockchain records are used solely for verification purposes and are not intended to replace public records or title records.

6. Data Security & Access Controls

• Security Measures: We implement reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, misuse, or loss. These include encryption, multi-factor authentication, access controls, audit logging, secure cloud infrastructure, and employee training.
• Access Restriction: Access to sensitive information is strictly restricted to authorized personnel with a legitimate business need. FraXion follows role-based access controls, least privilege principles, identity verification procedures, and security monitoring practices.
• Security Disclaimer: No system can guarantee absolute security, and users acknowledge that no method of transmission or storage is completely risk-free.

7. Data Retention

FraXion retains information for as long as necessary to provide services, maintain Property Passports, meet legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending upon the type of information and applicable legal requirements.

8. Cookies and Analytics

Our website may utilize cookies, analytics tools, and session tracking technologies to improve performance, analyze website traffic, understand user behavior, and enhance user experience. Users may adjust browser settings to manage cookie preferences.

9. Your Privacy Rights

Depending on your location and applicable local law, you may hold the following rights regarding your data:

• Right to Access: Request information regarding the personal data we maintain about you.
• Right to Correction: Request the correction of inaccurate information.
• Right to Deletion: Request the deletion of certain personal information.
• Data Portability: Request a copy of certain information in a portable format.
• Marketing Preferences: Opt out of marketing communications at any time.

FraXion will review and respond to all requests as required by applicable law.

10. Third-Party Links & Services

Our website may contain links to third-party websites or services. FraXion is not responsible for the privacy practices, content, or security measures of external websites. Users should review the privacy policies of external websites before providing information.

11. Age Restrictions

FraXion Property Passport is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from children.

12. International Users

If services are accessed from outside the United States, users acknowledge and agree that information may be processed and stored in the United States or other jurisdictions where our service providers operate.

13. Amendments & Changes

FraXion may update this Privacy Policy periodically. Updated versions will be posted on our website with a revised effective date. Continued use of our services after changes are posted constitutes acceptance of the updated policy.

14. Contact Information

If you have questions or concerns regarding this Privacy Policy or our privacy practices, please contact us at:

• Company: FraXion Property Passport™ (Operated by Randolph & Main Capital Group, LLC)
• Email: support@fraxionpassport.io
• Website: www.fraxionpassport.io