Effective Date: June 2025

The following Privacy Policy governs the online information collection practices of SC DIRECT RESPONSE SRL ("we" or "us"). Specifically, it outlines the types of information that we gather about you while you are using the {domain} website (the "Site"), and the ways in which we use this information.

This Privacy Policy, including our children's privacy statement, does not apply to any information you may provide to us or that we may collect offline and/or through other means (for example, at a live event, via telephone, or through the mail).

Please read this Privacy Policy carefully. By visiting and using {domain}, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. Because the Web is an evolving medium, we may need to change our Privacy Policy at some point in the future, in which case we will post the changes to this Privacy Policy on this website. You will be able to check the Effective Date and you can see the "Last updated" date of the policy at the beginning of this page.

By continuing to use {domain} after we post any such changes, you accept the Privacy Policy as modified.

How We Collect and Use Information

We may collect and store personal or other information that you voluntarily supply to us online while using {domain} (e.g., while on {domain} or in responding via email to a feature provided on {domain}). {domain} only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our messaging, attended one of our events, or have purchased one of our products.

{domain} collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and e-mail address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our products. All this information is provided to us by you.

We also collect and store information that is generated automatically as you navigate online through {domain}. For example, we may collect information about your computer's connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on {domain}. We also may use a standard feature found in browser software called a "cookie" to enhance your experience with {domain}.

Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use {domain}, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of {domain} where you may have entered preference information before.

{domain} also may use web beacons (single-pixel graphic files also known as "transparent GIFs") to access cookies and to count users who visit {domain} or open HTML-formatted email messages.

We use the information we collect from you while you are using {domain} in a variety of ways, including using the information to customize features; advertising that appears on {domain}; and, making other offers available to you via email, direct mail or otherwise. We also may provide your information to third parties, such as service providers, contractors and third-party publishers and advertisers for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using {domain} in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services.

If you do not wish your information to be used for these purposes, you must send a letter to the Online Privacy Coordinator whose address is listed at the end of this Privacy Policy requesting to be taken off any lists of information that may be used for these purposes or that may be given or sold to third-parties.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online - for example on message boards, web logs, through email, or in chat areas - that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

Some of our third-party advertisers and ad servers that place and present advertising on {domain} also may collect information from you via cookies, web beacons or similar technologies. These third-party advertisers and ad servers may use the information they collect to help present their advertisements, to help measure and research the advertisements' effectiveness, or for other purposes. The use and collection of your information by these third-party advertisers and ad servers is governed by the relevant third-party's privacy policy and is not covered by our Privacy Policy. Indeed, the privacy policies of these third-party advertisers and ad servers may be different from ours. If you have any concerns about a third party's use of cookies or web beacons or use of your information, you should visit that party's website and review its privacy policy.

{domain} also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through {domain}, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services.

We may also make some content, products and services available through our Site or by emailing messages to you through cooperative relationships with third-party providers, where the brands of our provider partner appear on {domain} in connection with such content, products and/or services. We may share with our provider partner any information you provide, or that is collected, while visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly, in which cases the privacy policy of our provider partner may apply to the provider partner's use of your information.

The privacy policy of our provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law or to protect the rights, property, or safety of users of {domain} or the public.

Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all our assets, or one or more of our websites is acquired by another company, information about our users may be among the transferred assets.

Google Analytics

We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Platform integrations
• Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site.

Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order.

The "Remarketing" feature allows us to reach people who previously visited our Site and match the right audience with the right advertising message.

You can opt out of Google's use of cookies by visiting Google's ad settings and/or you may opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.

Facebook

As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.

We abide by Facebook's Data Use Restrictions.

• Any ad data collected, received, or derived from our Facebook ad ("Facebook advertising data") is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data, or any other information obtained from us, limit our use of all that information, and keep it confidential and secure.
• We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers' campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
• We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
• We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.

How do we store your information?

Your information is stored at the list server that delivers {domain} content and messaging. Your information can only be accessed by those who help manage those lists to deliver email to those who would like to receive {domain} material.

All the messaging or emails that are sent to you by {domain} include an unsubscribe link in them. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communication that we send you.

General Data Privacy Regulation (GDPR)

The GDPR took effect on May 25, 2018 and is intended to protect the data of European Union (EU) citizens.

As a company that markets its site, content, products and/or services online we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data that you provide to us during your use of our site, content, products and/or services is governed by GDPR, we will abide by the relevant portions of the Regulation.

If you are a resident of the European Economic Area (EEA), or are accessing this site from within the EEA, you may have the right to request: access to, correction of, deletion of; portability of; and restriction or objection to processing, of your personal data, from us. This includes the "right to be forgotten."

To make any of these requests, please contact our GDPR contact: {support}.

Nevada Privacy Rights

Under Nevada law, Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them.

To exercise this right, please contact us: {support}

California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act ("CCPA") and applies only to "personal information" that is subject to the CCPA.

This policy applies to information we collect:

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Under California Civil Code Section 1789.3, users of the Website from California are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

As a California resident, you are entitled to make certain requests regarding your personal information under the California Consumer Privacy Act (CCPA).

To submit your request, please email us at {support} and include the following:

Your full name

The nature of your request (choose one or more):

Do not sell my personal information

Right to know what personal information we have collected

Right to delete my personal information

A statement confirming you are a California resident

Personal information we collect, disclose for a business purpose, and sell

We collect the categories of personal information about California consumers identified in the chart below. In the past 12 months we have collected and disclosed California consumers' personal information to third parties for business or commercial purposes - details are set out in the chart below.

We did not sell any information collected in the past 12 months.

Disclosures of Personal Information for a Business or Commercial Purpose

Categories of sources

DIRECT RESPONSE obtains the categories of Personal Information listed above from the following categories of sources:

• Directly from you - Personal Information that you input into our websites. For example, from:
• forms you complete, responses to surveys that we might ask you to complete for research or marketing purposes.
• products and services, you purchase through our partners Stripe or Digistore24.
• Records and copies of your correspondence (including email addresses), if you contact us in relation to our products or services.
• Indirectly from you. For example, from observing User actions in the Google Analytics or other platforms
• Records and copies of your correspondence (including email addresses), if you contact us in relation to our products or services.
• Your responses to surveys that we might ask you to complete for research or marketing purposes.
• Your search queries on the Website
• Details of transactions you carry out through our partners (Stripe, Digistore24 etc) and of the fulfilment of your orders.
• Affiliates in our group companies
• Consumer data resellers
• Comments or reviews you left on our website

You also may provide information to be published or displayed (hereinafter, "Posted") on public areas of the Website, including product reviews ("User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

How and Why We Use, collect and share Your Personal Information

We use the Personal Information to satisfy your requests, improve the quality of the SC DIRECT RESPONSE SRL products, engage in research and analysis relating to the SC DIRECT RESPONSE SRL offers, personalize your experience, track usage of our products, market our products, provide customer support, message you, and comply with legal obligations. Even when we do not retain such Personal Information, it still must be transmitted to our servers initially and stored long enough to process.

We also use Personal Information that we collect about you or that you provide to us, including any Personal Information used to fulfil our contractual obligations to you:

We may use and disclose the personal information we collect from you for our commercial and business purposes as set out in this privacy policy for one or more of the following business purposes:

For commercial purposes, including marketing, advertising, and enabling commercial transactions

SC DIRECT RESPONSE SRL will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services.

The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

The technologies we use for this automatic data collection may include:

Our Do Not Track Policy

Some browsers have a "do not track" feature that lets you tell websites that you do not want to have your online activities tracked. Currently, we do not respond to browser "do not track" signals.

Recipients of California Personal Information

We may disclose the categories of personal information listed above to the categories of third parties listed below for business purposes:

We may share aggregated information about our users without restriction.

Your Rights Regarding Personal Information

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

SC DIRECT RESPONSE SRL will not sell your personal information. California law requires that we maintain a separate webpage that allows you to opt out of the sale of your personal information. Please read below for more details.

To exercise any of the above rights, please contact us as follows:

Send us an email {support} including:

Your full name

The nature of your request (choose one or more):

Do not sell my personal information

Right to know what personal information we have collected

Right to delete my personal information

A statement confirming you are a California resident

Verification Process and Authorized Agents

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. At a minimum you will need to provide your name and email address.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may designate an authorized agent to make a CCPA request on your behalf by informing our customer service team {support}. You will need to provide your name and address, your agent's name and address, and a copy of the document by which you appointed the agent.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing using email.

We will deliver our written response by email.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Non-Discrimination

We will not discriminate against you for exercising any Personal Information rights. Unless permitted by applicable regulations, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Policy

We reserve the right to amend this Statement at our discretion and at any time. It is our policy to post any changes we make to our privacy policy on this page and update the effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen and provides important information regarding their rights under federal law with respect to such information.

This Site is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of {domain}. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information.

• If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of {domain}, we will delete such information from our records.
• If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of {domain}.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of {domain}, we also do NOT knowingly distribute such information to third parties.
• We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through {domain}.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of {domain}, we do NOT condition the participation of a child under thirteen in {domain} online activities on providing personally identifiable information.

Disclaimer

This policy may be changed at any time at our discretion. If we should update this policy, we will post the updates to this page on our Website.

Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at: {support}