Last Updated: May 18, 2026 Effective Date: May 18, 2026

1. Introduction

Welcome to 88NewWin.com (the "Site"), operated by 88 NewWin LLC, a California limited liability company ("88 NewWin," "we," "our," or "us"). 88 NewWin LLC is an affiliate referral platform connecting businesses and consumers with independent third-party financial, professional, and merchant service providers in the United States and Canada. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit the Site, contact us, or otherwise interact with our services. By using the Site, you acknowledge that you have read and understood this Privacy Policy. If you are a resident of California, Canada (including Quebec), or another jurisdiction with specific privacy rights, please review the jurisdiction-specific sections below for additional disclosures.

2. Personal Information We Collect

In the last twelve (12) months, we have collected the following categories of personal information as defined by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA"): (A) Identifiers — Name, postal address, email, phone, IP address, online identifiers, account name. Collected: Yes. (B) Personal info under Cal. Civ. Code §1798.80(e) — Name, signature, contact info, financial info (if voluntarily provided). Collected: Yes. (C) Characteristics of protected classifications — Age, marital status, citizenship. Collected: No. (D) Commercial information — Records of services inquired about or considered. Collected: Yes. (E) Biometric information — Fingerprints, voiceprints. Collected: No. (F) Internet or network activity — Browsing history, search history, interactions with Site, ads, emails. Collected: Yes. (G) Geolocation data — Approximate location derived from IP address. Collected: Yes. (H) Sensory data — Audio, electronic, visual information. Collected: No. (I) Professional/employment-related — Job title, company, industry (if voluntarily provided). Collected: Yes. (J) Non-public education information — Education records. Collected: No. (K) Inferences — Profile reflecting preferences, behavior, attitudes, predispositions. Collected: Yes. (L) Sensitive personal information — SSN, driver's license, financial account, precise geolocation, race, religion, health, sexual orientation. Collected: Generally no; financial-account information may be transmitted to third-party lenders only when you affirmatively initiate a financing application. We collect personal information from the following sources: directly from you (when you submit forms, contact us, or communicate with us); automatically through cookies, web beacons, pixels, and similar tracking technologies; from third parties (advertising networks, data providers, marketing partners, lenders or service providers you authorize us to contact); and from publicly available sources (business directories, government databases, professional networks).

3. How We Use Personal Information

We use personal information for the following business purposes: to operate, maintain, and improve the Site; to provide referral services and connect you with independent third-party providers you have requested; to respond to inquiries and communicate about services, offers, and promotions; to deliver personalized advertising and marketing content; to analyze Site usage, user behavior, and the performance of our marketing campaigns; to detect, prevent, and respond to fraud, security incidents, and unauthorized activity; to comply with legal obligations and enforce our Terms of Service; and to create aggregated, de-identified, or anonymized data, which we may use and disclose without restriction. We may combine information collected automatically with information from third-party sources to create a more complete profile for marketing, analytics, and service-improvement purposes.

4. How We Disclose Personal Information

We may disclose personal information to: independent third-party providers (lenders, accountants, tax experts, banks, private equity investors, brokers, merchant service providers, and other affiliate partners) to facilitate the referral services you request; service providers and processors (hosting providers, analytics platforms, email and CRM systems, marketing platforms, customer support tools) who process data on our behalf under written contractual obligations; advertising and analytics partners (e.g., Google, Meta/Facebook, LinkedIn) for cross-context behavioral advertising — see Section 5 for details on "sharing" under CCPA; legal and regulatory authorities when required by law, subpoena, court order, or in response to a government request; successors in interest in connection with a merger, acquisition, sale of assets, financing, or business restructuring; and other parties with your consent.

5. "Sale" and "Sharing" of Personal Information Under CCPASale.

We do not sell personal information in exchange for monetary consideration. Sharing. Under CCPA, "sharing" includes disclosing personal information to third parties for cross-context behavioral advertising, even without monetary payment. We may "share" the following categories of personal information for cross-context behavioral advertising: identifiers (e.g., online identifiers, IP address); internet or other electronic network activity information; and inferences drawn from any of the above. We share this information with third-party advertising networks including Google Ads, Meta/Facebook, and LinkedIn to deliver targeted advertising. We do not knowingly share the personal information of consumers under 16 years of age. Your right to opt out. California residents may opt out of this sharing at any time by visiting our Do Not Sell or Share My Personal Information page, or by enabling Global Privacy Control (GPC) signals in their browser. We honor GPC signals automatically.

6. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, local storage, and similar technologies to collect information automatically. These include strictly necessary cookies (required for the Site to function); performance and analytics cookies (Google Analytics or similar); functional cookies (preferences, language); and advertising and targeting cookies (Google Ads, Meta Pixel, LinkedIn Insight Tag, retargeting partners). You can manage cookies through your browser settings. Disabling certain cookies may affect Site functionality. Do Not Track (DNT) signals. There is currently no industry standard for responding to DNT browser signals; however, we honor Global Privacy Control (GPC) signals as an opt-out request for "sharing" under CCPA.

7. Your California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have the following rights: Right to Know. You may request that we disclose the categories and specific pieces of personal information we have collected, the sources, the business or commercial purposes for collecting or sharing it, and the third parties with whom it is disclosed, in the preceding 12 months (or longer if requested). Right to Delete. You may request that we delete personal information we have collected from you, subject to certain exceptions (e.g., to complete a transaction, detect security incidents, exercise free speech, comply with legal obligations). Right to Correct. You may request that we correct inaccurate personal information we maintain about you. Right to Data Portability. You may receive a copy of the specific pieces of personal information we have collected in a readily usable, structured format. Right to Opt Out of Sale or Sharing. You may opt out of the "sale" or "sharing" of personal information at any time. See our Do Not Sell or Share My Personal Information page. Right to Limit Use of Sensitive Personal Information. You may request that we limit the use and disclosure of sensitive personal information to that which is necessary to perform services you have requested. We do not currently use sensitive personal information for purposes beyond those permitted by the CCPA's "necessary" exemptions. Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights. We will not deny services, charge different prices, or provide a different level of service because you exercised your rights.

8. How to Exercise Your California Privacy Rights

To exercise any of the rights described above, please contact us using one of the methods below: toll-free phone (949) 258-3418; email advisors@88newwin.com (subject line: "CCPA Privacy Rights Request"); or our Do Not Sell or Share My Personal Information page for opt-out requests. Verification. To protect your privacy, we will verify your identity before responding to a request. We may ask for your name, contact information, and at least two pieces of personal information matching what we already have on file. For deletion or sensitive requests, we may require a signed declaration under penalty of perjury. We will respond to verifiable consumer requests within 45 days, with one 45-day extension if necessary. Authorized Agent. You may designate an authorized agent to submit a request on your behalf. The agent must provide written permission signed by you, and we will verify the agent's authority and your identity directly before processing.

9. Children's Privacy

The Site is not directed to children under 16. We do not knowingly collect, "sell," or "share" personal information from children under 16. If we learn we have collected such information without verifiable parental consent, we will delete it. Parents or guardians who believe their child has provided personal information may contact us at advisors@88newwin.com.

10. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods: contact form submissions and inquiry data — 36 months from last contact; marketing list data — until unsubscribe plus 12 months; analytics and Site usage data — 26 months (Google Analytics standard); financial referral records — 7 years (consistent with general financial recordkeeping); legal hold or dispute-related data — until the matter is resolved. Aggregated or de-identified data may be retained indefinitely.

11. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. However, no internet transmission or electronic storage method is 100% secure, and we cannot guarantee absolute security.

12. International Data Transfers

If you access the Site from outside the United States, your personal information may be transferred to, stored in, and processed in the United States and other jurisdictions, where privacy laws may differ from those in your home country. By using the Site, you consent to such transfers.

13. Canadian Users (PIPEDA, CASL)

If you are located in Canada, we collect, use, and disclose personal information in compliance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws (including British Columbia's PIPA and Alberta's PIPA). Consent. By using the Site and providing personal information, you consent to the collection, use, and disclosure described in this Privacy Policy. You may withdraw consent at any time, subject to legal or contractual restrictions, by contacting us at advisors@88newwin.com. Your rights under PIPEDA. You have the right to access, correct, and request information about the personal information we hold about you. To exercise these rights, contact us using the information in Section 17. CASL — marketing emails. Marketing communications to Canadian recipients are sent only with express consent as required under Canada's Anti-Spam Legislation. Every marketing email includes a one-click unsubscribe link. You may also withdraw consent by replying with "UNSUBSCRIBE" or contacting us at advisors@88newwin.com.

14. Quebec Residents (Law 25)

f you are a resident of the Province of Quebec, Canada, the following additional rights apply under An Act respecting the protection of personal information in the private sector (commonly referred to as Quebec Law 25): right to know the source of personal information collected about you; right to know whether your personal information is used for automated decision-making, and if so, the principal factors and parameters used; right to data portability — to receive personal information in a structured, commonly used technological format; right to request de-indexing of personal information that is inaccurate, incomplete, or out of date, or where the dissemination contravenes the law. Privacy Officer. 88 NewWin LLC has designated Danny N. as the person responsible for the protection of personal information. Contact: advisors@88newwin.com or (949) 258-3418. Note on services in Quebec. As stated in our website Disclaimer, services advertised on this Site are not currently offered to residents of the Province of Quebec.

15. California Shine the Light Act

California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure of personal information to third parties for the third parties' direct marketing purposes. To make such a request, contact us at dannyn@88newwin.com with "Shine the Light Request" in the subject line.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. Material changes will be communicated by posting a prominent notice on the Site. Continued use of the Site after any change constitutes acceptance of the revised Privacy Policy.

17. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact: 88 NewWin LLC Attn: Privacy Officer — Danny Nguyen Email: advisors@88newwin.com Phone: (949) 258-3418 Thank you.