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CPRA Applicability Threshold — Self-Determination Form

Status: internal compliance document. This document does NOT constitute legal advice. Purpose: document the operator's good-faith determination that the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) does not apply to Raxx at the time of v1 launch (2026-05-23 UTC) and the basis for that determination. This form should be re-evaluated at least annually and upon material changes to Raxx's revenue, customer count, or data-sharing practices. Last updated: 2026-05-11 UTC.

Authority: Cal. Civ. Code § 1798.140(d); CPPA CPI adjustments at https://cppa.ca.gov/regulations/cpi_adjustment.html

Part 1 — Applicability Checklist

A for-profit business that "does business in the State of California" and collects "consumers' personal information" is subject to CCPA/CPRA if it meets at least one of the following thresholds.

Threshold A — Annual Gross Revenue

Threshold: As of 2026-01-01, annual global gross revenues exceeding $26,625,000 (CPI-adjusted per CPPA).

Question Response
Does Raxx have annual global gross revenues exceeding $26,625,000? [ ] Yes [ ] No
If no, state approximate 2025 annual revenues (or "pre-revenue" if applicable): _____
Data verified from: [ ] Financial statements [ ] Accounting software [ ] Best estimate

Determination for Threshold A: [ ] In scope [ ] Not in scope

Threshold B — Consumer Record Volume

Threshold: Annually buying, selling, receiving for commercial purposes, or sharing for commercial purposes, the personal information of 100,000 or more California consumers or households.

Question Response
Does Raxx sell, share, buy, or receive (for commercial purposes) personal information of 100,000+ California consumers annually? [ ] Yes [ ] No
Approximate number of California consumers whose personal information Raxx processes: _____
Note: "processes" includes collecting, storing, using — but the threshold specifically applies to "buying, selling, receiving for commercial purposes, or sharing for commercial purposes." Internal processing of subscriber data does not meet this threshold unless the data is sold or shared commercially.

Determination for Threshold B: [ ] In scope [ ] Not in scope

Threshold C — Revenue from Data Sales

Threshold: Deriving 50% or more of annual revenues from selling or sharing consumers' personal information.

Question Response
Does Raxx derive 50% or more of annual revenues from selling or sharing personal information? [ ] Yes [ ] No
Describe any selling or sharing of personal information for commercial purposes: _____
Does Raxx sell user data to advertisers, data brokers, or any third party? [ ] Yes [ ] No

Determination for Threshold C: [ ] In scope [ ] Not in scope

Part 2 — Summary Determination

Threshold In scope?
A — Revenue >$26.6M [ ] Yes [ ] No
B — 100K+ consumer records processed commercially [ ] Yes [ ] No
C — 50%+ revenue from data sales [ ] Yes [ ] No
CCPA/CPRA applies to Raxx? [ ] YES — at least one threshold met [ ] NO — no threshold met

Part 3 — ADMT Self-Determination

Even if CCPA does not apply (thresholds not met), this section documents Raxx's determination that ADMT risk assessment obligations are not triggered.

The CPPA finalized ADMT regulations (effective 2026-01-01 for covered businesses; 2027-01-01 for consumer rights):

Raxx ADMT determination:

Question Response
Does Raxx use any technology that replaces or substantially replaces human decision-making? [ ] Yes [ ] No
If yes, describe: _____
Does Raxx's automated technology make decisions about consumers' access to employment, housing, credit, health care, education, insurance, or essential goods? [ ] Yes [ ] No
Does Raxx's backtesting or signal layer produce outputs that are used without human review to make significant decisions about consumers? [ ] Yes [ ] No
Does the payment_event_count field drive any automated accept/reject decision about a consumer? [ ] Yes [ ] No

ADMT determination: [ ] ADMT risk assessment required [ ] ADMT risk assessment NOT required

Basis for "not required" determination (if applicable): Raxx is a rule-based strategy execution platform. Trading strategy rules are set by the human operator; Raxx executes them deterministically. The AI layer, per architectural decisions dated 2026-04-29, augments understanding and assists with parsing but does not make autonomous decisions or replace human decision-making. payment_event_count is a raw display counter, not an input to any automated decision system. No Raxx output makes a significant decision about a consumer's access to employment, housing, credit, health care, education, insurance, or essential goods.

Part 4 — Re-Evaluation Triggers

This self-determination must be re-evaluated if any of the following occur:

Part 5 — Operator Attestation

I, the undersigned, as authorized representative of [COMPANY LEGAL NAME] ("Raxx"), have reviewed the CCPA/CPRA applicability thresholds and ADMT definitions as of the date signed below. Based on my good-faith review, I determine that:

[ ] Raxx IS subject to CCPA/CPRA — initiate full compliance program immediately.

[X] Raxx IS NOT subject to CCPA/CPRA at this time, based on the threshold analysis above. This determination will be re-evaluated at the triggers listed in Part 4. Despite not being covered, Raxx will maintain a privacy policy that accurately describes its data practices, consistent with FTC Section 5 obligations.

Regarding ADMT: Raxx does not use ADMT as defined by the finalized CPRA regulations and does not make significant decisions as defined. ADMT risk assessment obligations are not triggered.

Signed: Kristerpher Henderson Printed name: Kristerpher Henderson Title: Founder / Authorized Representative, MooseQuest LLC dba Raxx Date (UTC): 2026-05-13

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