PRIVACY POLICY

Introduction

This Privacy Policy ("Policy") applies to information collected through Momentum Playbook, Inc. ("Momentum," "Company," "we," "us," and "our") websites, platforms and any of our other online products and services that display or link to this Policy, information collected offline, and information obtained from third parties (collectively, the "Services").

We understand that your data is important to you and that you care about how your information is collected and used. We have compiled the information below to explain how we gather, use, and store your information.

Please read through this Policy carefully. By using our Services, you understand and agree to the terms as outlined in this Policy. Our Policy is also subject to our Terms of Use, which is incorporated herein by reference.

This Privacy Policy is organized into the following sections:

1. We May Collect Your Information when You Use our Services, from Third Parties, or Automatically
2. We May Use Your Information to Provide You with our Services
3. We May Disclose Your Information to Provide You with our Services and for Marketing Purposes
4. We Use Cookies and Similar Tracking Technologies for a Variety of Purposes
5. We May Use Analytics Services Provided by Others
6. We May Use Advertising Services Provided by Others
7. We Take Measures to Protect Your Information
8. Our Services are not Intended for Minors
9. We are Based in the United States
10. You May have Rights Under Applicable State Laws
11. We May Retain Your Information in Accordance with our Legal Obligations
12. Updates to this Policy
13. Contact Us

1. We May Collect Your Information when You Use our Services, from Third Parties, or Automatically

(a) What We Collect

Personal Information. To ensure that we provide you with the best possible experience, we will store, use, and disclose personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device ("Personal Information"). The Personal Information that we may receive and collect depends on what you do when you visit our Services.

Information of Other Individuals. You may have the opportunity to provide information of other individuals. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and Momentum shall not be responsible or held liable for your failure to obtain the necessary consents.

Aggregated and De-Identified Data. We may also collect, use and disclose aggregated and de-identified data such as statistical or demographic data for any purpose. Aggregated and de-Identified data could be derived from your Personal Information but is not considered Personal Information under applicable law, as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de-identified data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting Momentum to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Username and Password; Other Sources. We may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Additionally, we may receive information about you from other sources and add it to the information you have provided to us.

(b) How We Collect Your Personal Information

Information Directly from You. When you use our Services, we may collect the information you provide us. This may happen when you ask a question, create an account, conduct transactions, use a form provided through the Services, make payments, contact us, complete surveys, provide feedback or complaints. This information may include your name, address, email address, and phone number; payment information; user feedback; analytics pertaining to your use of the Services; records of services requested or purchased; and other information you provide to us.

Information From Third Parties. We may collect information about you from third parties. This may include your name, address, email address, and phone number; information on your interests and other publicly available data (such as from social media); demographic information; or device identification information.

Automatically Collected Information. We may collect information automatically using cookies and similar online technologies or when you use our Services, send us an email, or interact with our emails or advertisements. Such information may include internet protocol address; device and advertising identifier; browser type and language; operating system; date and time stamp; session ID; internet service provider; web pages and advertisements visited; internet protocol address, geolocation or other location information; click or touch stream data, movement, scroll, and in some cases, keystroke activity; third-party sites or services you were using before and after interacting with our Services.

2. We May Use Your Information to Provide You with our Services

We may collect and use your Personal Information in a variety of ways, including for the following purposes:

• to offer you our Services;
• to operate and maintain our Services;
• to facilitate transactions;
• to manage your account;
• to present our content to you (including customized content, targeted offers and advertising);
• to communicate with you;
• for marketing and service-related purposes;
• to develop and improve our Services;
• to notify you about changes to our Services and business;
• to enhance and optimize your experience;
• for any other disclosed purposes to which you consent;
• to enforce our legal terms and applicable policies;
• to protect our rights;
• to analyze usage patterns and performance of our Services;
• to evaluate advertisement interactions;
• for business purposes;
• as required or permitted by law; and
• as otherwise described to you at the point of collection.

If you provided your Personal Information for a job application, we may use that information for human resources, job placement, qualification, or other related purposes.

We use automatically-collected information to conduct analyses about our Services; associate the different devices you use; remember your browser or device; remember your preferences and interactions; deliver relevant advertisements or other content; and market our Services to you.

We may use cookies and similar online technologies for providing our Services, security, authentication, analytics, product or service improvement, advertising, fraud detection, and for other similar purposes.

3. We May Disclose Your Information to Provide You with our Services and for Marketing Purposes

We do not sell or lease your Personal Information to any third party. However, in addition to disclosing your Personal Information as described at the time of collection, we may disclose your Personal Information with the following persons or entities or in the following circumstances, among others:

• when we have your consent or at your direction;
• to provide requested Services;
• to process payments; with a parent, subsidiary, or affiliate entity within the Momentum corporate family;
• with a third party, when a division or product line of Momentum is bought, sold or otherwise transferred, or the third party is in the process of a potential transaction as among the transferred business assets or as a result of another corporate transaction;
• with our business partners;
• with our distributors or sellers who facilitate the sale of our Services;
• with our service providers, as needed to perform their functions for us;
• with third parties, to provide you with a product or service;
• where required by law, or a regulatory authority or at the request of governmental, law enforcement, or regulatory authorities;
• with other entities for fraud protection or credit risk reduction; and
• when we believe such disclosure is necessary, such as to protect the rights or safety of visitors to the Services, customers, employees or others or to address national security situations.

Though we do not sell the Personal Information we collect in the ordinary course of our business, we may disclose your data with third parties in accordance with the purposes described above.

We may also maintain aggregate data or other deidentified information about you, such as usage statistics, online traffic patterns and user feedback. This aggregated or deidentified information is not Personal Information. In addition to using this information for the purposes discussed in this Policy, we may disclose this aggregated or other deidentified information to third parties without restriction.

In some instances, we may use your Personal Information to contact you about goods and services that you may find valuable. We may also disclose your Personal Information for marketing purposes. From time to time, we may send you email newsletters and marketing emails. You may opt out of them at any time by selecting the "unsubscribe" link at the bottom of each email or by contacting us at hello@momentumactuarial.com. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Even if you opt-out of receiving marketing material, we may still need to contact you with important information about your account or to respond to your requests or questions.

4. We Use Cookies and Similar Tracking Technologies for a Variety of Purposes

We use cookies, web beacons, log files, and similar technologies to automatically collect information for the following purposes, among others:

• after you have entered Personal Information into a form or data field on one of our Services, cookies enable the Services to 'remember' that information, should you so choose;
• to deliver content that is tailored to your interests and preferences based on your past activity on the Services; and
• to compile aggregate statistics concerning use of our Services, analyze trends, and otherwise administer and improve the Services.

(a) Cookies. A Cookie is a small data file stored on your computer that contains information and is used to track information as you navigate different sites. These technologies work together and collect information about:

• the type of device you are using;
• browsers you prefer;
• domain names you may access;
• your activities on the device; and
• your IP address.

For information about cookies and similar technologies, including how to manage and delete cookies on your device, you can visit the help section of your browser. However, if you disable cookies on your device, you may be prohibited from full use of the Services' features or lose access to some functionality.

(b) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.

(c) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

(d) Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Services and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

5. We May Use Analytics Services Provided by Others

In some instances, we may receive information from our third-party partners and vendors about our users. We may also incorporate third-party marketing and analytic services, such as BigCommerce, Facebook, Google, Pinterest, TikTok, HubSpot, and others for audience measurement and analytics purposes. These analytics services may use cookies or similar technologies to collect information to help us analyze users and how they use our Services. The information collected by these technologies is used to assess how often you visit our Services, what pages you view when you visit our Services and what other websites you visited before coming to our Services. Information generated by these services may be transmitted to and stored by these providers and they may use this information for purposes such as evaluating your use of our Services, compiling statistics reports on the website's activity, and providing other services relating to website and platform activity and other internet usage. Our Privacy Policy only governs Momentum's use of your Personal Information; however, we may use these third-party services to analyze and enhance your experience.

Google Analytics. Google Analytics is a tool used to discover user demographics and behavior. You can reference Google's privacy policy regarding how they handle information collected by visiting https://policies.google.com/privacy. To opt out of being tracked by Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on.

We may use Google reCAPTCHA on our Services, which checks whether our Services are being used by humans or bots.

6. We May Use Advertising Services Provided by Others

We may use service providers and partners to serve advertisements on our behalf on our Services and across the internet, and to track and report on the performance of those advertisements. These service providers may include Bing Ads, DoubleClick, Google, and others. Data collected and maintained by such third-party ad providers will be subject to the terms of use and privacy policies of those providers. You may learn more about online interest-based advertising by visiting this Federal Trade Commission website.

You may opt out of receiving interest-based advertisements from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting the NAI website. You may also opt out of receiving interest-based advertisements from other companies that perform interest-based advertising services who are members of the Digital Advertising Alliance (DAA) by visiting the DAA website.

When using the ad industry opt-out tools described above, you may need to execute opt-outs for each browser or device that you use. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests. If you use industry opt-out tools, your opt out will only apply to companies who are participating in those industry organization tools.

You may continue to see generic or non-targeted advertisements after opting out.

7. We Take Measures to Protect Your Information

We have designed and adopted certain technological and organizational measures to safeguard your Personal Information. However, we cannot guarantee that your Personal Information will not be lost, accessed without authorization, disclosed, altered, or destroyed. Any information you provide to us is at your own risk.

Additionally, if you have registered for an account through our Services, you should not share your password or username with any other third parties. It is your responsibility to keep your account information confidential.

8. Our Services are not Intended for Minors

Individuals under the age of eighteen (18) are prohibited from accessing our Services. Additionally, we do not use our Services to knowingly collect Personal Information from minors. Please contact us if you learn or have reason to suspect that a child under the age of eighteen is using the Services. We will take prompt action to delete any Personal Information about the minor.

9. We are Based in the United States

If you are visiting our Services from outside the United States, please be aware that we are based in the United States and the information we collect will be transferred to, processed, and stored on our servers in the United States in accordance with this Policy and applicable laws. The data protection laws and regulations applicable to your Personal Information transferred to the United States may be different from the laws in your country of residence.

10. You May have Rights Under Applicable State Laws

California

• Do Not Track Signals. Browsers and devices allow individuals to send "do not track" signals to websites. At this time, our website does not respond to "do not track" signals. You may visit the Future of Privacy Forum's website for additional information about Do Not Track signals.
• Shine the Light Law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

Nevada

Nevada law permits customers in Nevada to opt-out of the sale of certain kinds of Personal Information. We do not sell your Personal Information to third parties as defined in Nevada law. If you are a Nevada resident and have any questions, you can contact us at hello@momentumactuarial.com.

Your State Consumer Privacy Rights

You may have rights under applicable U.S. state privacy laws (such as the California Consumer Privacy Act, as amended). However, Momentum Playbook, Inc. does not currently meet the regulatory thresholds of a "controller" or "business" as defined under U.S. state privacy laws. Regardless, all Personal Information will be processed in accordance with this Policy and applicable laws.

11. We May Retain Your Information in Accordance with our Legal Obligations

We may retain your Personal Information for as long as reasonably necessary to fulfill the purposes described in this Policy, to comply with applicable legal and regulatory requirements, and to support internal investigations, audits, and dispute resolution.

Retention periods are determined based on business necessity, legal obligations, and risk considerations.

12. Updates to this Policy

This Policy describes our current policies and practices with regard to the information we collect through the Services. We are continually improving and adding to the features and functionality of the Services along with the products and services we offer through the Services. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the "Last Revised" block at the top of this Policy. You can get to this page from our Services by clicking on the "Privacy Policy" link (usually at the bottom of the screen).

13. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our Services, please contact us via email at admin@momentumactuarial.com,