SMS Privacy Policy

1. Purpose of This Policy

This SMS Privacy Policy describes how Schwarz Capital ("we," "us," or "our") handles mobile telephone information in connection with our operational alert messaging program (the "Program"). It supplements our Privacy Policy. Where this policy addresses mobile information specifically, this policy controls.

2. The Core Commitment

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.

This commitment is unconditional. It applies to mobile telephone numbers, message content, consent records, and delivery data. We do not sell mobile information. We do not rent, trade, or license it. We do not use it for advertising, and we do not permit any third party to do so.

3. Mobile Information We Collect

We collect only what is necessary to operate the Program:

• Mobile telephone number — the number designated to receive operational alerts, provided directly by the individual
• Consent record — the date and time consent was given, and by whom
• Message content — the text of alerts we send
• Delivery metadata — message identifier, timestamp, delivery status, and error codes returned by our messaging provider
• Opt-out record — the date and time of any STOP request

We do not collect message content you send us other than opt-out and HELP keywords, contacts or address book data, device data, or location data.

We do not purchase, rent, append, or otherwise acquire mobile telephone numbers from any third party. Every number in the Program was entered directly by the individual to whom it belongs.

4. How We Use Mobile Information

• To deliver operational alerts describing the status of internal Schwarz Capital systems
• To honor opt-out and HELP requests
• To maintain records of consent and opt-out as required for compliance
• To diagnose delivery failures and confirm that alerts reached their recipient

Mobile information is never used for marketing, promotion, advertising, solicitation, profiling, or any automated decision affecting an individual.

5. Disclosure of Mobile Information

Messaging provider

We use Twilio Inc. to transmit messages. Twilio receives the recipient's mobile number and message content solely to deliver the message on our behalf, and is contractually restricted from using that information for its own purposes.

Mobile carriers

Your mobile carrier necessarily processes messages sent to your device in order to deliver them. Carrier handling is governed by your carrier's terms.

Legal disclosure

We may disclose mobile information where required by law, subpoena, court order, or other valid legal process, or where necessary to protect the rights, property, or safety of Schwarz Capital or others.

No other disclosure

We do not disclose mobile information to advertisers, ad networks, or data brokers; to affiliates for their own marketing or promotional purposes; to analytics or profiling vendors; or to any party for consideration.

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.

6. Consent

Enrollment requires express prior consent from the individual to whom the number belongs. There is no web form and no public sign-up. Enrollment occurs only when an authorized operator personally records their own mobile number in the platform's protected alert configuration, on a system to which access is restricted and authenticated.

Consent is specific, informed, documented, and revocable at any time. Consent is not a condition of any purchase.

7. Opting Out and Your Choices

You may withdraw consent at any time by replying STOP to any message. The keywords STOP, END, CANCEL, UNSUBSCRIBE, and QUIT are honored. You will receive one confirmation message, after which no further messages will be sent to that number.

You may also opt out by emailing support@schwarzcapital.com.

Depending on your jurisdiction, you may also have the right to access the mobile information we hold, correct inaccurate information, request deletion subject to the retention obligations below, object to or restrict processing, and lodge a complaint with a supervisory authority.

We do not discriminate against anyone who opts out or exercises a privacy right.

8. Retention

• Active participant's number — retained while enrollment remains active
• Consent record — retained as a compliance record after enrollment ends
• Opt-out record — retained indefinitely, so that we can honor the opt-out and avoid re-contacting the number
• Message content and delivery metadata — retained as part of operational and incident records for a limited period

We retain opt-out records deliberately. Deleting an opt-out record would create a risk of contacting someone who has asked us not to. This is the one category we keep specifically to protect you.

9. Security

Mobile information is protected by the safeguards described in our Privacy Policy, including:

• credentials stored outside source code and outside version control, in permission-restricted files accessible only to authorized processes
• transport encryption for all communication with our messaging provider
• least-privilege access controls over systems holding mobile information
• exclusion of mobile numbers and message content from application logs and diagnostic output
• documented change control over systems that transmit messages

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Children

The Program is available only to authorized personnel of Schwarz Capital and is not directed to or available to children. We do not knowingly collect mobile information from anyone under 18 in connection with the Program.

11. Contact

Schwarz Capital — SMS Program, Privacy
support@schwarzcapital.com

12. SMS Program Essentials

Summarized here so that this page is complete on its own. Full terms appear in our SMS Terms & Conditions.

• Program: operational and transactional system alerts for authorized Schwarz Capital personnel. No marketing messages are ever sent.
• Frequency: message frequency varies and is event-driven. A single event produces at most two messages. Typically fewer than ten messages per month.
• Cost: message and data rates may apply.
• HELP: text HELP at any time, or email support@schwarzcapital.com.
• STOP: text STOP to cancel at any time. These keywords are honored: STOP, END, CANCEL, UNSUBSCRIBE, QUIT.

Representative messages sent by this program:

SCHWARZ: BROKER CRITICAL. Broker disconnected. Paper trading HALTED. Time 15:31Z. Reason unreachable. ID SC-BROKER-20260805T153100Z

SCHWARZ: BROKER RESTORED. Connection restored. Paper trading resumed. Time 16:20Z. Outage 0h 49m 0s. ID SC-BROKER-20260805T153100Z

13. Changes to This Policy

We may update this policy from time to time and will revise the "Last Updated" date above. Material changes to how mobile information is collected, used, or disclosed will be communicated to enrolled participants, who may opt out at any time. We will not apply a material change retroactively to previously collected mobile information without consent, where consent is required by applicable law.

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.