Privacy Policy

Who We Are

PFTheory LLC ("PFTheory," "we," "us," or "our") is a Michigan-based limited liability company operating across two primary divisions: automotive performance fabrication and manufacturing, and IT/managed service provider (MSP) services. We also operate SanAs3 Racing, a motorsport competition arm, and serve as contracted IT infrastructure partner for affiliated entities including Vera Dynamics Inc. and Wade Enterprise Global LLC.

This Privacy Policy explains how PFTheory LLC collects, uses, stores, and shares personal information when you interact with our platforms, products, services, membership programs, and financial systems — including our membership interest certificate system, kit ordering, and any embedded financial services.

Information We Collect

We collect information you provide directly to us, information generated through your use of our services, and information from third-party partners where applicable.

Personal Identification Information

• Full legal name, date of birth, and government-issued ID details (for membership interest certificates and financial services)
• Email address, phone number, and mailing address
• Business entity name, EIN, and operating jurisdiction

Financial Information

• Payment card details (processed via Stripe — not stored on PFTheory servers)
• Bank account and routing numbers (for ACH transfers, processed via Stripe Treasury)
• Transaction history, membership interest purchase records, and consideration paid

Technical and Usage Information

• IP address, browser type, device identifiers, and operating system
• Pages visited, time on site, and interaction events
• API usage data for MSP and IT infrastructure clients

Automotive and Product Data

• Vehicle identification numbers (VIN) submitted for kit orders and build tracking
• Build configuration data, dyno logs, and performance records
• Lap logs and competition data submitted through the SanAs3 Racing portal

How We Use Your Data

PFTheory LLC uses collected information solely for legitimate business purposes in connection with our services:

• Processing and fulfilling product orders, kit configurations, and build requests
• Issuing and maintaining membership interest certificates and cap table records
• Operating embedded financial services including virtual card issuance, fund transfers, and financial account management
• Providing IT/MSP services to contracted clients including Vera Dynamics Inc. and Wade Enterprise Global LLC
• Communicating order status, account updates, and material company notices
• Complying with legal obligations including securities exemption filings and tax reporting
• Improving our products, services, and platform infrastructure
• Preventing fraud, unauthorized access, and misuse of our financial systems

Financial Data & Stripe

PFTheory LLC uses Stripe, Inc. as our payment infrastructure provider, including Stripe Treasury and Stripe Issuing for embedded financial services. When you submit payment or banking information through our platform:

• Payment card data is transmitted directly to Stripe and is never stored on PFTheory servers
• Bank account information for ACH transfers is processed and stored by Stripe under their own privacy policy
• Virtual cards issued through PFTheory's platform are subject to Stripe Issuing's terms and Stripe's privacy policy
• Financial account data is stored in the United States on Stripe's infrastructure

Membership interest purchase records, consideration paid, and certificate data are stored on PFTheory's US-based MySQL infrastructure at encrypted rest and in transit.

Third-Party Data Sharing

PFTheory LLC does not sell personal information to third parties. We may share data in the following limited circumstances:

Affiliated Entities

• Vera Dynamics Inc. — for IT infrastructure services rendered under contract
• Wade Enterprise Global LLC — for technology platform operations under common ownership
• SanAs3 Racing — for competition registration and sponsored driver records

Service Providers

• Stripe, Inc. — payment processing, treasury, and card issuance
• Hostinger — web hosting infrastructure (US data centers)
• T-Mobile — business telecommunications

Legal Requirements

• When required by law, subpoena, or valid legal process
• To comply with SEC securities exemption reporting obligations (Form D filings)
• To protect the rights, property, or safety of PFTheory LLC or its members

All third-party service providers are contractually obligated to handle data in compliance with applicable law and to use data only for the purposes specified by PFTheory LLC.

Data Storage & Retention

All personal data collected and processed by PFTheory LLC is stored exclusively within the United States. Our primary data infrastructure is located in Michigan and operates under US federal and Michigan state law.

• Application data — stored on jordi.pfth.net (US-based)
• Database records — stored on riker.pfth.net MySQL (US-based), encrypted at rest and in transit
• Financial records — retained for a minimum of 7 years per IRS and securities law requirements
• Membership interest records — retained permanently as part of the company's official cap table
• VIN and build data — retained for the duration of the customer relationship plus 5 years

We will not transfer your personal data outside the United States without your explicit consent.

Your Privacy Rights

Depending on your location and applicable law, you may have the following rights with respect to your personal information:

• Access — request a copy of the personal information we hold about you
• Correction — request correction of inaccurate or incomplete data
• Deletion — request deletion of your personal data, subject to legal retention obligations
• Portability — request your data in a structured, machine-readable format
• Opt-Out — opt out of non-essential communications at any time

Note: Membership interest certificate records and cap table entries cannot be deleted as they constitute legally required corporate records under Michigan law and applicable securities regulations.

To exercise any of these rights, contact us using the information in the Contact section below. We will respond within 30 days.

Data Security

PFTheory LLC implements industry-standard security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption at rest and in transit across all PFTheory data infrastructure
• TLS/SSL encryption for all web and API communications
• Role-based access controls limiting data access to authorized personnel only
• Regular security audits of IT infrastructure
• Stripe's PCI DSS Level 1 compliance for all payment data

No method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a data breach affecting your rights, we will notify you as required by applicable law.

Children's Privacy

PFTheory LLC's services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a person under 18, we will take steps to delete that information promptly.

If you believe we have collected information from a minor, please contact us immediately at fvernom@pftheory.com.

Changes to This Policy

PFTheory LLC reserves the right to update this Privacy Policy at any time. When we make material changes, we will update the effective date at the top of this document and, where appropriate, notify affected users via email or platform notification.

Your continued use of PFTheory LLC services following any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

Contact Us

For privacy-related inquiries, requests to exercise your rights, or questions about this policy, contact PFTheory LLC directly: