Privacy Policy

1. Scope

This Privacy Policy applies to personal information we collect through:

• https://section16agent.com, or https://form4agent.com;
• the Section 16 Agent platform;
• communications with us relating to the Services; and
• beta access, onboarding, support, and account administration activities.

This Privacy Policy does not apply to third-party websites, platforms, or services that may be linked from or integrated with the Services, including third-party authentication, hosting, analytics, payment, or infrastructure providers, each of which is governed by its own privacy practices.

2. Business Context and Roles

The Services are business-facing services. We offer the Services to organizations and their authorized personnel for professional and compliance-related use, not for personal, family, or household purposes. The Services are not intended for consumer use or personal financial management purposes.

For information relating to website visitors, account creation, onboarding, support, product administration, billing, analytics, security, and our general operation of the Services, Form 4 Agent, LLC acts as the business responsible for deciding how and why that information is processed.

When authorized users submit filing-related information, transaction details, drafts, supporting materials, or related content through the Services on behalf of their organizations, we process that information in order to provide the Services requested by the user and the relevant organization. In that context, the information may also remain subject to the instructions, policies, and internal controls of the user's organization.

In many circumstances, we process filing-related information and related authorized user content solely on behalf of and under the instructions of the relevant organization using the Services.

3. Who May Use the Services

The Services are intended only for business and professional use by authorized users who are at least 18 years old. The Services are not directed to children, and we do not knowingly collect personal information from anyone under 18.

4. Categories of Information We Collect

A. Account and Contact Information

• name;
• business email address;
• telephone number;
• employer or affiliated organization;
• job title or role;
• account credentials and authentication-related information; and
• invitation and onboarding information.

B. Filing, Transaction, and Authorized User Content

We collect information that authorized users submit through the Services in connection with preparing, reviewing, generating, storing, or managing filing-related materials and related outputs. This may include highly sensitive business information, including information concerning securities transactions and related compliance matters. Depending on how the Services are used, this content may include personal information relating to officers, directors, shareholders, employees, and other relevant persons.

Depending on authorized user use, submitted materials may include confidential business information, draft regulatory filings, and material non-public information relating to securities transactions or corporate governance matters. Users should avoid submitting information that is unnecessary for the requested workflow or functionality.

C. Configuration and Operational Data

We collect information relating to user settings, company-level configurations, reporting person configurations, filing history, generated packages, and similar operational records needed to provide the Services.

D. Usage, Device, and Log Information

• IP address;
• browser type;
• device type;
• operating system;
• access times;
• pages or screens viewed;
• navigation and usage events;
• request metadata; and
• identifiers and fields associated with service operations, such as issuer CIKs and reporting person CIKs where relevant to the requested functionality.

Operational and diagnostic records may also include system-generated identifiers, error records, request traces, performance telemetry, and similar technical metadata associated with service operation and debugging.

E. Analytics Information

We use analytics to collect website and application analytics, including performance and web vitals information, to help us understand and improve the performance and usability of the Services.

F. Communications

If you contact us, request support, participate in beta testing, or otherwise communicate with us, we may collect your name, contact details, and the contents of those communications.

5. Sources of Information

We collect personal information:

• directly from you;
• from your employer or organization when they invite or provision your access;
• through your use of the Services;
• from service providers that support authentication, hosting, infrastructure, storage, analytics, communications, database support, and related operations; and
• from public sources and regulatory sources, such as SEC/EDGAR materials, where relevant to service functionality.

We may also receive information from organizational administrators, compliance personnel, legal teams, or other authorized representatives acting on behalf of authorized user organizations.

6. How We Use Information

We may use personal information to:

• provide, operate, maintain, and secure the Services;
• authenticate users and administer accounts;
• enable filing-related workflows, generation, storage, retrieval, and management of outputs;
• provide authorized user support, onboarding, and beta program administration;
• monitor usage, debug issues, and improve reliability, performance, and functionality;
• personalize and maintain user and company configurations;
• develop, improve, train, and refine our products, services, features, and core engine;
• communicate with you about the Services, updates, support matters, and administrative issues;
• detect, investigate, and prevent fraud, misuse, unauthorized access, and security incidents; and
• comply with legal obligations and protect our rights, users, and Services.

We may use customer-submitted content, generated outputs, operational records, and related service data to provide, operate, maintain, secure, test, support, improve, refine, develop, and enhance the Services and related products, features, functionality, workflows, models, systems, and the core engine underlying the Services. This may include internal testing, debugging, quality assurance, reliability improvements, feature development, workflow optimization, model and system refinement, analytics, security operations, and related product-development activities.

Because the Services involve generated content and workflow automation, certain submitted materials, generated outputs, configurations, operational records, and related service data may be reviewed, processed, or used as part of improving the performance, functionality, accuracy, reliability, usability, and operation of the Services and related systems.

7. How We Disclose Information

A. Service Providers and Infrastructure Providers

We may disclose information to vendors and service providers that perform services for us, such as hosting, infrastructure, storage, authentication, analytics, communications, database support, and related operational functions. Depending on the functionality used, information submitted through the Services may be processed by third-party artificial intelligence, large language model, or machine-learning service providers acting on our behalf. We seek to require service providers to process information only for authorized purposes and subject to appropriate confidentiality and security obligations.

B. Within Your Organization

If you access the Services through an account provided, sponsored, or managed by your employer or organization, certain information may be available to authorized administrators or representatives of that organization for account administration, compliance, operational, or support purposes.

C. Legal and Protection Purposes

We may disclose information if we believe doing so is necessary or appropriate to:

• comply with applicable law, regulation, legal process, or governmental request;
• enforce our agreements and policies; and
• detect, prevent, or address fraud, security, or technical issues or protect the rights, property, or safety of the Company, our users, authorized users, or others.

This may include responding to lawful requests relating to securities-law compliance, regulatory inquiries, investigations, or dispute resolution.

D. Corporate Transactions

We may disclose information in connection with an actual or proposed financing, merger, acquisition, reorganization, sale of assets, bankruptcy, or other corporate transaction.

E. With Consent or Direction

We may disclose information where you or your organization direct us to do so or otherwise consent.

8. No Sale or Advertising-Based Sharing

We do not sell personal information. We do not share personal information for cross-context behavioral advertising. For California residents, these rights are provided under the CCPA, as amended by the CPRA. Residents of other states with privacy laws (Virginia, Colorado, Connecticut, Utah, and others) may have similar rights under applicable state law.

9. Analytics, Cookies, and Similar Technologies

We and our service providers may use cookies, session technologies, and similar tools that are necessary to operate authentication, maintain sessions, secure the Services, remember preferences, and support performance and analytics. If we materially change our use of analytics, cookies, or advertising technologies, we will update this Privacy Policy accordingly.

We also use analytics tools, including Vercel Analytics, to understand usage patterns, performance, and service quality. We do not currently use third-party advertising pixels or cross-context behavioral advertising tools.

10. Third-Party Services and Integrations

We use third-party service providers, infrastructure providers, and technology integrations to help operate, secure, support, and improve the Services. Depending on the functionality used, these providers may process personal information, customer-submitted content, generated outputs, operational records, or related service data on our behalf. These providers may include providers of:

• cloud hosting and infrastructure services;
• authentication and identity management;
• database and storage services;
• analytics and performance monitoring;
• communications and email delivery;
• logging, debugging, and operational support tools;
• artificial intelligence, language model, and machine-learning functionality;
• security and fraud-prevention services; and
• backup, recovery, and reliability services.

Information processed through these providers may include account information, filing-related materials, transaction-related content, generated outputs, technical metadata, operational diagnostics, and related service information, depending on the nature of the Services used. We seek to require third-party providers to process information only for authorized purposes and subject to appropriate confidentiality and security obligations. However, third-party providers maintain and operate their own infrastructure, systems, and operational environments, and their processing may also be subject to their own legal and operational requirements.

Certain features or functionality of the Services may rely on third-party platforms, integrations, or providers that are not controlled by us. We are not responsible for the privacy, security, availability, or practices of third-party services except as required by applicable law. We may update or replace third-party providers from time to time as part of operating and improving the Services.

11. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain operational records, resolve disputes, enforce agreements, improve the Services, and comply with legal obligations. At present:

• account and configuration records may be retained until deleted or otherwise no longer needed for business or legal purposes;
• generated drafts and related stored outputs may remain in our systems until deleted;
• application logs are generally retained for up to 365 days; and
• certain backups or platform-level recovery copies may persist for limited periods consistent with service provider practices.

Retention periods may vary depending on the nature of the information, the sensitivity of the data, the context in which it was collected, and legal, operational, or security requirements. Deleted information may persist for limited periods in backups, archives, logs, disaster recovery systems, or security records.

12. Logging and Stored Outputs

We store generated filing documents, drafts, and related outputs as part of providing and operating the Services. These materials may include user-provided inputs and generated content.

Our systems are designed to minimize inclusion of substantive user prompts, filing narratives, and similar content in operational application logs except where reasonably necessary for service operation, debugging, security, abuse prevention, legal compliance, or support activities. Operational and infrastructure logs may still contain metadata, request identifiers, error records, technical diagnostics, and related system-level information.

13. Security

Given the nature of the Services, we recognize that certain submitted information may involve confidential securities-related or compliance-sensitive information. We use reasonable administrative, technical, and organizational measures designed to protect personal information. These measures may include access controls, encrypted storage, and other safeguards appropriate to the nature of the information we process.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a confirmed security incident affecting personal information, we may notify affected users or organizations as required by applicable law and consistent with our incident-response processes.

14. Your Privacy Choices and Rights

Certain rights may vary depending on your state of residence and the nature of your relationship with us or the organization using the Services. Subject to applicable law and verification, you may have the right to request that we:

• confirm whether we process your personal information;
• provide access to personal information we maintain about you;
• correct inaccurate personal information;
• delete certain personal information; and
• provide information about how we collect, use, and disclose personal information.

You may also have the right to appeal certain decisions we make about your privacy requests where required by law.

To submit a privacy request, contact us at privacy@section16agent.com.

We may decline requests that are fraudulent, infeasible, abusive, threaten the privacy or security of others, or are otherwise not required by applicable law. We may need to verify your identity before responding to a request. In some cases, we may deny or limit a request where permitted by law, including where retention is necessary to provide the Services, protect security, comply with law, complete a transaction, or maintain records related to the business relationship. Where your information is managed through an organizational account, we may direct certain requests to the relevant organization.

15. Business Accounts

If your access to the Services is provided through your employer or another organization, your use of the Services may be subject to that organization's policies and instructions. Organizational administrators may be able to access, review, export, manage, or monitor certain account information, usage records, configurations, stored outputs, or related content associated with organizational accounts.

In some circumstances, we may provide information relating to your account or use of the Services to authorized organizational administrators for legitimate business, administrative, support, security, or compliance purposes.

16. No Financial, Investment, Tax, Accounting, or Legal Advice

The Services are software tools and technology services only. The Services and any generated materials, outputs, workflows, summaries, drafts, suggestions, or other content made available through the Services are provided for informational and operational purposes only and do not constitute legal advice, investment advice, tax advice, accounting advice, financial advice, compliance advice, brokerage services, filing services, or other professional services.

Form 4 Agent, LLC is not a law firm, accounting firm, broker-dealer, investment adviser, or filing agent, and does not act as an attorney, fiduciary, compliance officer, or representative for users or their organizations.

Users and organizations are solely responsible for:

• reviewing and validating all information, outputs, and generated materials;
• determining the accuracy, completeness, sufficiency, and appropriateness of any filing-related materials or outputs;
• making all legal, compliance, securities-law, accounting, tax, and business determinations;
• determining whether any filing, disclosure, submission, or transaction is required or appropriate; and
• obtaining any necessary professional review, approvals, authorizations, or advice.

Use of the Services does not create an attorney-client, fiduciary, advisory, or other professional relationship between Company and any user, organization, issuer, reporting person, shareholder, director, officer, employee, or other person. Users and organizations should not rely on the Services or any outputs as a substitute for independent legal, compliance, accounting, tax, financial, or professional review.

17. U.S.-Only Services

The Services are currently intended for users in the United States. We do not currently market or intentionally offer the Services outside the United States. If that changes, we may update this Privacy Policy to address additional jurisdictions and legal requirements.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. For material changes, we may provide additional notice through the Services, by email, or through other reasonable means.