Revised: August 3, 2026

This privacy notice for Welwyn (“we,” “us,” or “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), including our brand TruCBN, such as when you:

• Visit our website at tru-cbn.com, or any website of ours that links to this privacy notice;

• Purchase products or otherwise transact with us; or

• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@tru-cbn.com.

Summary of Key Points

This summary provides key points from our privacy notice. You can find more details on any topic using the table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission or storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information.

How do you exercise your rights? The easiest way is to contact us at hello@tru-cbn.com. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

1. What information do we collect?

2. How do we process your information?

3. What legal bases do we rely on to process your information?

4. When and with whom do we share your personal information?

5. Do we use cookies and other tracking technologies?

6. How long do we keep your information?

7. How do we keep your information safe?

8. Do we collect information from minors?

9. What are your privacy rights?

10. Controls for do-not-track features

11. Do United States residents have specific privacy rights?

12. Do we make updates to this notice?

13. How can you contact us about this notice?

14. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include the following:

• names

• email addresses

• usernames

• passwords

• contact preferences

• contact or authentication data

• billing addresses

• debit/credit card numbers

• phone numbers

• mailing addresses

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Authorize.net. You may review their privacy notice at https://www.authorize.net/about-us/dpa.html.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

• To facilitate account creation and authentication and otherwise manage user accounts. So you can create and log in to your account and keep it in working order.

• To fulfill and manage your orders. To process your purchases, payments, returns, and subscriptions.

• To send you marketing and promotional communications. Where permitted, and which you can opt out of at any time.

• To save or protect an individual’s vital interest. Such as to prevent harm.

3. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law — for example, with your consent, to comply with laws, to provide you with services, to fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. We may rely on the following:

• Consent. Where you have given us permission to use your information for a specific purpose, which you can withdraw at any time.

• Legal Obligations. Where necessary for compliance with our legal obligations.

• Vital Interests. Where necessary to protect your vital interests or those of a third party.

If you are located in Canada, this section applies to you.

We may process your information if you have given us express consent, or where your permission can be inferred (implied consent). You can withdraw your consent at any time. In some exceptional cases we may be legally permitted to process your information without your consent, as allowed under applicable law.

4. When and with whom do we share your personal information?

In Short: We may share information in the specific situations described in this section and/or with the following third parties.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

• Service Providers. We share information with vendors who perform services for us, such as payment processing (Authorize.net), order fulfillment and shipping, email and marketing, and analytics.

• Google Analytics. We may share your information with Google Analytics to track and analyze use of the Services. To opt out, visit https://tools.google.com/dlpage/gaoptout.

5. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. You can usually set your browser to remove or reject cookies; doing so may affect certain features of the Services.

6. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or securely store and isolate it from further processing until deletion is possible.

7. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorized third parties will not be able to defeat our security. Transmission of personal information to and from our Services is at your own risk.

8. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to their use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under 18, please contact us at hello@tru-cbn.com.

9. What are your privacy rights?

In Short: In some regions, such as the EEA, UK, Switzerland, and Canada, you have rights that allow greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. To make a request, contact us at hello@tru-cbn.com. We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent, you have the right to withdraw it at any time by contacting us at hello@tru-cbn.com or by updating your preferences. This will not affect the lawfulness of processing before its withdrawal.

Opting out of marketing communications: You can unsubscribe at any time by clicking the unsubscribe link in our emails or by contacting us at hello@tru-cbn.com. We may still send you service-related messages necessary for the administration of your account or orders.

Account Information: To review or change the information in your account or to terminate your account, log in to your account settings, or contact us. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, though we may retain some information to prevent fraud, troubleshoot problems, assist investigations, enforce our legal terms, and/or comply with applicable legal requirements.

10. Controls for do-not-track features

Most web browsers and some mobile operating systems and applications include a Do-Not-Track (“DNT”) feature or setting. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. If a standard is adopted that we must follow in the future, we will inform you in a revised version of this notice.

11. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.

Categories of personal information we have collected in the past twelve (12) months:

• A. Identifiers (e.g., name, postal address, IP address, email address, account name) — Collected: YES

• B. Personal information under the California Customer Records statute (e.g., name, contact and financial information) — Collected: YES

• C. Protected classification characteristics (e.g., gender, date of birth) — Collected: NO

• D. Commercial information (e.g., transaction and purchase history) — Collected: YES

• F. Internet or other network activity (e.g., browsing/search history, interactions with our website and ads) — Collected: YES

• G. Geolocation data (e.g., device location) — Collected: YES

• Sensitive personal information — Collected: NO

We have not sold or shared personal information to third parties for a business or commercial purpose in the preceding twelve (12) months, and we will not sell or share personal information belonging to website visitors, users, and other consumers in the future.

Your rights

Depending on your state, you may have the right to request access to your personal information, correct inaccuracies, request deletion, obtain a copy of the data you shared with us, and opt out of processing for targeted advertising, the sale of personal data, or certain profiling. We will not discriminate against you for exercising your privacy rights.

How to exercise your rights: Email us at hello@tru-cbn.com. We may need to verify your identity before processing your request. If we decline to act on your request, you may appeal by emailing us at hello@tru-cbn.com; we will respond within the timeframe required by your state’s law.

12. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and will be effective as soon as it is accessible. If we make material changes, we may notify you by prominently posting a notice or by directly sending you a notification.

13. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at hello@tru-cbn.com or contact us by post at:

Welwyn

6915 NE 79th Ct.

Portland, OR 97218

United States

14. How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email us at hello@tru-cbn.com.