Last updated: November 1, 2025.

Welcome to Civic Win ("Civic Win", "we", "our", or "us"). Civic Win values the privacy of the visitors to its website and the users of the services provided thereon (individually, "User" or "you", and collectively, "Users"), and makes it a priority to protect any personally identifiable information ("Personally Identifiable Information") it obtains from its Users. This Privacy Policy explains Civic Win's collection, use, and protection of your personal information on and in connection with the civicwin.com website ("Website") and all content, services and/or products provided through the Website (collectively, the "Services"). If you have any questions that this policy does not address, please contact us at: info@civicwin.com

By accessing the Services, registering as a User, using our Services, uploading or submitting any material or content through the Website or by email to us, or by otherwise submitting any personal information to us (including without limitation by participating in any online forums or subscribing to any newsletter), you agree to the terms and conditions contained in this Privacy Policy and the Terms of Use, available at: www.civicwin.com/info/terms. Registered Users will also be subject to our Market Rules.

The term "personal information" refers to non-public information that personally relates to or identifies you (such as, without limitation, your name, password, age, gender, email address, postal mailing address, zip code, home/mobile telephone number, Social Security number and/or taxpayer identification number, bidding objectives, experience, assets and income, and other similar information).

Non-personally identifiable information ("Non-Personally Identifiable Information") collected on the Website may include, without limitation, website pages viewed, details of any requests or transactions you make through the Website, sites visited before visiting the Website, frequency of visits, clickstream data, browser type, operating system, organization name, articles, internet connection speed, materials viewed, time spent viewing pages of our website or using certain features of our website, demographic data such as server locations, clickstream data, location services, server location, cookies existing on your computer, search criteria used and results, date and time of access or visits to our website, frequency of visits to our website, connection speed, any information submitted by you to the Website in the form of comments, contributions to discussions, or messages to other users, and other information which does not specifically identify you.

Our Pledge to You

Civic Win makes commercially reasonable best efforts to maintain the confidentiality, integrity and security of our Users' personal information. Keeping User information secure and using it as described in this Privacy Policy are matters of principle for all of us at Civic Win. With this in mind, here is our commitment to each and every User:

• Except as you may otherwise expressly approve, we will limit the collection and use of User information to what we believe would be useful to service your accounts, administer our business and provide the Services, or to tell you about our Services;
• We will restrict employee access to User information to those who need to know in order to provide Services to you;
• We will educate our employees according to our internal policies to reinforce the importance of confidentiality and User privacy;
• We will maintain commercially reasonable and customary security standards and procedures to protect information about you; and
• We will promptly review a request from you to review inaccurate personal information we have about you.

Updates and Changes to Privacy Policy

In the event of a change in this policy, a revised Privacy Policy will promptly be posted to our Website, and the "Last Updated" date will be changed. If the revised Privacy Policy contains a material change to how we collect or use personal information, notice of the change will either be emailed to you (if we have contact information for you) or we will post the revised Privacy Policy on the Website. Please revisit the Website to familiarize yourself with any changes to the Privacy Policy. You agree that our posting of a revised Privacy Policy to our Website is sufficient to provide you actual notice of such revised Privacy Policy. Your continued use of the Website or any of our Services after such posting will constitute your agreement and consent to all of the terms of the then-current Privacy Policy.

How and Why We Gather Information

When you register for an account for the Services, we collect personal information from you to open an account, transact business, communicate with you, verify your identity and fulfill legal and regulatory requirements. We call this your "Profile." From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences. If you choose to provide such information, during registration or otherwise, you are giving Civic Win permission to use and store it consistent with this Privacy Policy. We may also obtain your personal information from your transactions with us or other Users through the Services, or from third parties. If we combine or associate information from other sources with personal information that you provide directly to us through or in connection with the Website or the Services, we will treat the combined information as personal information in accordance with this Privacy Policy.

When you visit the Website or use our Services, whether or not you register for an account, we may use cookies, web beacons, and server logs. "Cookies" are small text files containing a string of alphanumeric characters that may be placed on your web browser. Cookies make it easier for you to navigate our Website by, among other things, "remembering" your identity so that you do not have to input your password multiple times as you navigate between web pages on the Website and/or as you access the Services. This use of cookies for authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set or to prevent cookies from being set. A "web beacon" is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email which allows the website to record the simple actions of the user opening the page that contains the beacon. "Server logs" can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server. Please note that if you decline to use cookies, you may experience reduced functionality or slower site response times. Declining to use our authentication-related cookies may prevent you from using the Website altogether.

Civic Win or our service providers may also collect web surfing data related to your use of the Services (e.g., information regarding which of our web pages you access, the frequency of such access, your product and service preferences, and other use analytics). This may be accomplished by using cookies, web beacons, page tags or similar tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Website. Web surfing data and similar information may be used: for administrative purposes; to assess the usage, value and performance of our online products and services; and to improve our Services.

How Information Helps Both You and Us

Information about you and your accounts plays a key role in our ability to succeed in our mission. It also helps us service your accounts and administer our business. For example, we use information about you to:

• Provide you with the Services available through the Website or otherwise;
• Enable you to participate in any online forums and communities through the Website;
• Establish and set up your account, issue an account number, and maintain your transaction history;
• Respond more accurately and efficiently to your requests;
• Identify opportunities to give you more convenience and control by developing new services that may benefit you;
• Verify your identity and contact information to help protect you and Civic Win from fraud; and
• Comply with applicable legal and regulatory requirements.

We generally use the information that you provide or that we collect to establish and enhance our relationship with you, and to operate, maintain, enhance, and provide the Services and the Website. We may use such information to periodically provide you with information, updates on markets, newsletters or offers about features, opportunities, and services available through the Services that may be of interest to you. We may also send information or offers to groups of Users on behalf of other Users or third parties. However, you will have the option to opt out of receiving such information by requesting to opt out at: info@civicwin.com

We may use aggregated information provided by or collected from our Users to understand and analyze the usage trends and preferences of our Users, to improve the way the Services and the Website work and look, and to create new features and functionality. We may use aggregated information about our Users' bids or other actions to generate statistics and maps that we deem helpful in the provision of the Services or any part thereof. We do not sell analytics about a User without written consent from the User.

Sharing Your Information with Others

We may allow you to share certain information with other Users of the Services, which may include the ability to share your Profile with all other Users, or only with such other Users as are designated by you. You are not required to share your Profile or any other information with other Users. If you do share your Profile, anyone you designate may be able to see information about you, such as claim markets you are following, supporting and/or bidding on. If you bid, or indicate an interest in bidding through the Services, we may notify the party or parties who receive or would receive your bid or who are or would be the subject of your bid (the "Beneficiary") of your interest and may notify other Users with whom you have chosen to share information. By bidding or indicating an interest in a bid and/or sharing your Profile with other Users, you consent to this disclosure of your information. We may also collect and store information, which could include Non-Personally Identifiable Information or Personally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.

Social Media Features

We may offer single sign-on services through third-parties such as LinkedIn or Facebook Connect. If you choose to use such features, they will be used to authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate sign up forms. Services like Facebook Connect give you the option to post information about your activities on our Website to your Profile page to share with others within your network. Any time you interact with a third-party service through our Services, you may also be subject to that party's privacy policy, and terms of use or service, which we encourage you to read carefully.

Our Website and Services may also include social media features such as the Facebook Like button, Twitter, and share buttons. These features are interactive mini-programs and may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy and any terms of use or service of the company providing them.

How and Why Civic Win Discloses Your Information to Third Parties

We limit the sharing of personal information outside Civic Win. We do not sell, license, lease, or otherwise disclose your personal information to third parties, except as noted below:

• We may disclose your personal information when such disclosure is legally required or appropriate pursuant to any court orders, subpoenas or any regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies, and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
• To help us improve our Services, we may engage third parties to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business and the operation of our Website and Services. Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us. Use of any personal information we share with these third parties is limited to the performance of the task we request. The third parties with which we share personal information are required to protect it in a manner similar to the way we protect your personal information.
• If you bid or indicate an interest in making a bid through the Services, we may notify the Beneficiary of your interest and may provide your personal information to the Beneficiary.
• To engage in any other legitimate business purpose or lawful activity we believe is consistent with this Privacy Policy and the Services.
• If you elect to share your User Content (as that term is defined in the Terms of Use) with other Users, any personal information that you choose to include in, or that is associated with, your User Content may be accessible by other Users. Once you make your personal information available to others in any of these ways, it may be collected and used by the recipients without restriction.
• We may make certain automatically collected information about your interactions and activities on and with the Services, such as the business, market, or areas of interest to you or on which you have bid, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users.
• In the event that Civic Win is acquired by or merged with a third-party entity, it reserves the right to transfer or assign the information that it has collected from its Users as part of such merger, acquisition, sale, or other change of control.
• We may also disclose your information to credit reporting or collection agencies, or when we deem necessary to protect our rights or property.

We further reserve the right to disclose any of your personal information as we believe appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Services, or to protect the rights, property or personal safety of Civic Win, its Users, Beneficiaries, or others.

Civic Win may also use and disclose Personally Identifiable Information and Non-Personally Identifiable Information: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Website, Services, or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of Civic Win's business or assets. Any successor in interest to our business would acquire the information we maintain, including Personally Identifiable Information, and may alter the terms of this Privacy Notice. Civic Win does not and will not sell any of your information, including non-personally identifiable or Personally Identifiable Information, to any third party for purposes of advertising, soliciting, or telemarketing without your permission. We may, however, have to disclose your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to other companies or entities in the event that Civic Win may be sold or is sold. In that case, your information, including Personally Identifiable Information and Non-Personally Identifiable Information, may be sold or transferred to such acquiring person, company or entity.

Our Privacy Policy Does Not Apply to Third-Party Activities or Sites

The Website may provide links to third-party websites for your convenience and information. If you access those links, you will leave the Website. Any information submitted by you to a third party, including Beneficiaries, will be controlled by that third party's privacy policy and terms of use or service, which may differ from Civic Win's. This Privacy Policy does not cover your use, access, or interaction in any manner with such third party services or other third parties, such as our business partners. We do not control how these third party services or third parties collect information or by what means such third party services or third parties may use their own cookies to collect information about you. We do not endorse, screen, or approve, and are not responsible for the privacy practices, terms of use or service, or the content of, any other websites or services. We encourage you to review the policies of any company before submitting your personal information.

Keeping Information Safe

We limit access to your personal information to those employees who have a legitimate business need to access such information to provide you with the Services. In keeping with industry standards and practices, we maintain commercially reasonable physical, electronic and procedural safeguards and controls to protect your information, but no system is one-hundred percent secure. The Website is built on a secure infrastructure with multiple layers of protection, and we use industry standard encryption technologies to safeguard your information.

Users are required to identify and authenticate themselves prior to accessing restricted portions of the Services. Generally, identification and authentication take place through the use of your user name and a password and/or while logging in with one of our technical support staff. You are responsible for keeping your password confidential.

We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, notify us immediately.

The transmission of information via the Internet is not completely secure, and for this reason we cannot guarantee the security of information sent to us electronically. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Opt-out Policy

We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, you may unsubscribe completely by emailing us at: info@civicwin.com<.

Please note that opt-out requests may take up to twenty-four (24) hours to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations, which are communications you will not be able to opt-out of. You will be able to modify the information concerning your account by visiting your Profile page and editing any information you wish to change. You will be able to change your e-mail address, password, contact information, or other login information by visiting your account's settings page subject to our website policy. If you wish to delete your account or need help modifying account information, please contact us at: info@civicwin.com. Please remember that deleting your account will not remove your prior activities from our Website or the Services. For more information, please see the Terms of Use (www.civicwin.com/info/terms) or the Market Rules (www.civicwin.com/info/market-rules).

You may adjust your browser setting to restrict the placement of cookies on your computer by adjusting your web browser preferences. If you do so, you may still use our Website, but it may interfere with some of its functionality.

You may also clear cookies from your computer via your web browser settings but the Website does not respond to Do-Not-Track signals. You may also wish to use a Google Analytics opt-out web browser add-on.

If you would like us to remove your Personally Identifiable Information from our database, please send a request to: info@civicwin.com.

We are not responsible for removing your Personally Identifiable Information from the lists of any third party services or other third party who has previously been provided your information.

Reviewing, Changing or Correcting Information

You are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, or if you have any questions regarding this Privacy Policy, please contact us.

You may, of course, decline to share any or all of your personal information with us or ask us to delete your personal information from our systems at any time, in which case we may not be able to provide to you some of the features and functionality found on or through the Website and the Services. Non-registered Users will not have access to the interactive features of our Services.

International Visitors

The Services may be accessed and/or used by Users located outside the United States in accordance with our Terms of Use and other policies and procedures posted on the Website. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.

Children's Privacy Policy

No one under eighteen (18) years of age is permitted to use our Services. The Civic Win Website is not intended for use by children, and we do not knowingly solicit or collect Personally Identifiable Information from children under the age of thirteen (13). If Civic Win learns that personal information has been collected from persons under thirteen (13) years of age through the Services without their legal guardian's consent, then Civic Win will take appropriate steps to delete this information. If you believe that a minor has disclosed Personally Identifiable Information to Civic Win, please report this to us immediately by emailing us at: info@civicwin.com.

Applicable Law and Jurisdiction

The Website is maintained in the United States of America. By accessing our Website and using our Services, you consent to and authorize the export of Personally Identifiable Information to the United States of America and its storage and use as specified in this Privacy Notice.

This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of Oregon applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard either in the Oregon State Courts located in Bend, Oregon, or the federal district court for Eugene, Oregon. You consent to the personal jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT AND THE USE OF OUR SERVICES TO THE FULLEST EXTENT PERMITTED BY LAW.

Contact Information

Please contact Civic Win with any questions about this Privacy Policy, your personal information, or your choices with regard to our collection and use of your personal information, by completing our contact form or email us at: info@civicwin.com