Cookie Policy

Cookie Policy

Updated March 2026

This Cookie Policy explains how SEC Tokenization (sectokenization.com), operated by The Vanderbilt Portfolio AG, uses cookies and similar tracking technologies when you visit our site. We cover what cookies are, the categories of cookies we deploy, how Google AdSense and third-party analytics services use cookies, the consent mechanisms available to you, your rights under the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR), and how to control or disable cookies through your browser settings.

Please read this policy together with our Privacy Policy and Terms of Use, which provide additional context on how we collect and process personal data. If you have questions, contact info@sectokenization.com.

What Are Cookies?

Cookies are small text files placed on your device — computer, tablet, or smartphone — when you visit a website. They are widely used to make websites function properly, to improve user experience, and to provide information to website owners. Cookies do not contain executable code and cannot carry viruses or install malware.

Cookies may be first-party (set by the website you are visiting) or third-party (set by a domain other than the one you are visiting). They may be session cookies, which expire when you close your browser, or persistent cookies, which remain on your device for a specified period or until you delete them.

Beyond traditional cookies, similar tracking technologies include web beacons (clear GIFs), pixel tags, local storage objects (LSOs), and fingerprinting scripts. Where we refer to “cookies” in this policy, we mean all such technologies unless noted otherwise.

Categories of Cookies We Use

1. Strictly Necessary (Essential) Cookies

Essential cookies are required for the basic operation of this site. They enable core functions such as storing your cookie consent preferences, maintaining session state, and delivering secure page loads. Without these cookies, services you have requested — such as remembering your consent choices — cannot be provided.

These cookies do not collect information that could be used for marketing, and they are not used to track your activity across other sites. Because they are strictly necessary, they are placed on your device without requiring your prior consent under applicable law; however, you retain the right to manage them through your browser.

Examples of essential cookies on sectokenization.com:

2. Analytics Cookies

Analytics cookies help us understand how visitors interact with SEC Tokenization — which pages are most visited, how long users spend on regulatory analyses such as our Howey Test guides or Reg D vs Reg A+ comparisons, and how users navigate from one section to another. This data helps us improve content quality and site structure.

We use Google Analytics for this purpose. Google Analytics sets a number of cookies, including _ga, _ga_[ID], and _gid, which collectively identify unique visitors and track session behavior. The data is aggregated and anonymized; we do not use it to identify individual users.

Google Analytics data is processed under a Data Processing Agreement with Google LLC. You can opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on. You may also control analytics cookies through our consent mechanism (see below) or through your browser settings.

Examples of analytics cookies:

3. Advertising and Targeting Cookies

SEC Tokenization uses Google AdSense to display advertisements. Google AdSense is operated by Google LLC and sets advertising cookies to serve ads that are relevant to your interests based on your browsing behavior across websites in the Google Display Network.

These are third-party cookies. Google uses the DoubleClick cookie (IDE) and related identifiers to track ad impressions, measure click-through rates, prevent fraud, and customize the ads shown to you. Advertising cookies may collect your IP address, browser type, device identifiers, and browsing history across multiple sites and sessions.

Google’s use of advertising cookies is governed by Google’s Privacy & Terms and the Google Advertising Policies. You can review and manage your ad personalization settings through Google’s Ad Settings or opt out of interest-based advertising through the NAI opt-out tool.

Examples of advertising cookies:

Google AdSense and Interest-Based Advertising

Google AdSense may use cookies, web beacons, and similar tracking technologies to serve contextual and interest-based advertising on SEC Tokenization. Interest-based advertising means that advertisements shown to you are tailored based on your browsing history, inferred interests, and demographic information.

Google and its advertising partners may combine information from this Site with information from other websites you have visited to build a profile used to serve relevant ads. If you are signed into a Google account while visiting this Site, Google may associate your browsing data with your account.

For information about how Google uses data when you use partners’ sites or apps, see the Google Privacy Policy at https://policies.google.com/privacy. For information on controlling your Google ad personalization, visit https://adssettings.google.com/.

SEC Tokenization complies with the IAB Transparency and Consent Framework (TCF) to manage consent for advertising cookies in EU jurisdictions.

Third-Party Cookies

In addition to Google Analytics and Google AdSense, third-party services embedded in our content may set their own cookies. These may include:

• Social sharing buttons — If you interact with social media share buttons (e.g., LinkedIn, X/Twitter), those platforms may set cookies to track your interaction.
• Embedded content — If we embed regulatory data visualizations or external tools, the providers of that content may set cookies.
• Content delivery networks (CDNs) — Infrastructure providers may set performance and security cookies.

We do not control the cookies set by these third parties and are not responsible for their content or privacy practices. We encourage you to review the privacy and cookie policies of any third-party services you interact with.

Consent Mechanism

When you first visit sectokenization.com, you will be presented with a cookie consent banner. This banner allows you to:

• Accept all cookies — including essential, analytics, and advertising cookies.
• Reject non-essential cookies — declining analytics and advertising cookies while allowing essential cookies to function.
• Customize your preferences — selecting which categories of cookies you accept on a granular basis.

Your consent choices are stored in an essential cookie (cookie_consent) and will be remembered for 12 months. You may change your preferences at any time by revisiting the cookie settings link in the site footer or by clearing your browser cookies (which will reset your consent and trigger the banner on your next visit).

Where required by law (e.g., for users in the EU/EEA or UK), we obtain your prior consent before placing non-essential cookies. For California residents, we honor opt-out requests for the sale or sharing of personal information, including information collected through advertising cookies.

Managing Cookies Through Browser Settings

You can control and delete cookies through your browser settings. Instructions for the major browsers are available at the following links:

• Google Chrome: chrome://settings/cookies
• Mozilla Firefox: support.mozilla.org
• Apple Safari: support.apple.com
• Microsoft Edge: support.microsoft.com

Please note that disabling or deleting cookies may affect the functionality of this Site. In particular, disabling essential cookies may prevent the site from storing your consent preferences, which could result in repeated consent prompts.

You may also use browser extensions such as Privacy Badger or uBlock Origin to control tracking across websites.

Your Rights Under CCPA (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information, including information collected through cookies:

• Right to Know — You have the right to know what personal information we collect, use, disclose, and sell.
• Right to Delete — You have the right to request deletion of your personal information.
• Right to Opt Out — You have the right to opt out of the sale or sharing of your personal information. Advertising cookies placed by Google AdSense may constitute a “sale” or “sharing” of personal information under California law. You may opt out through our cookie consent tool or by signaling your preference through a recognized opt-out preference signal such as the Global Privacy Control (GPC).
• Right to Non-Discrimination — You have the right not to receive discriminatory treatment for exercising your privacy rights.

To exercise your CCPA rights, contact info@sectokenization.com with the subject line “CCPA Request.” For more information, see our Privacy Policy.

Your Rights Under GDPR (EU/EEA and UK Residents)

If you are located in the European Union, European Economic Area, or United Kingdom, the General Data Protection Regulation (GDPR) or UK GDPR provides you with the following rights:

• Right to be Informed — This Cookie Policy fulfills our obligation to inform you about cookies and tracking.
• Right of Access — You can request access to the personal data collected about you through cookies.
• Right to Erasure — You can request deletion of your personal data.
• Right to Restrict Processing — You can request that we restrict our use of your data.
• Right to Object — You can object to the processing of your data for marketing purposes at any time.
• Right to Withdraw Consent — Where processing is based on consent, you may withdraw that consent at any time by adjusting your cookie settings.

The legal basis for processing through essential cookies is our legitimate interest in operating a functional website. The legal basis for analytics and advertising cookies is your consent, which you provide through our cookie consent banner.

To exercise your GDPR rights, contact info@sectokenization.com with the subject line “GDPR Request.”

Cookie Policy Updates

We may update this Cookie Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Updated” date at the top of this page. We encourage you to review this policy periodically. Continued use of the Site following any changes constitutes your acceptance of the updated policy.

Contact

For questions about this Cookie Policy, our privacy practices, or to exercise your CCPA or GDPR rights:

Email: info@sectokenization.com (subject: “Cookie Policy”)

Related Policies:

• Privacy Policy
• Terms of Use
• Methodology
• Contact

External Resources:

• Google Cookie Policy
• IAB Transparency and Consent Framework