PRIVACY POLICY

Smart People Network, Inc.

Including Lang & Co Holdings and All Associated Affiliates, Programs, Divisions, and Brands

Effective Date: January 1, 2025

Smart People Network, Inc., together with Lang & Co Holdings and all associated affiliates, subsidiaries, divisions, brands, programs, and operating entities (collectively, the “Company,” “we,” “us,” or “our”), is committed to protecting your privacy and handling your personal information with transparency, accountability, and care.

This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you visit our websites, interact with our brands, enroll in our programs, use our services, submit applications, communicate with us, or otherwise engage with the Company.

By using our websites, products, programs, services, communications systems, and related platforms, you acknowledge that you have read and understood this Privacy Policy.

SECTION 1

Overview

We collect and process personal information in order to operate our business, provide products and services, communicate with clients and prospective clients, administer memberships and programs, process payments, improve user experience, and comply with legal and contractual obligations.

We do not rent or sell your personal information, including mobile phone numbers or SMS consent data, to third parties for their own marketing purposes.

This Privacy Policy applies to information collected through:

• our websites and landing pages

• forms, applications, and intake systems

• client portals and online platforms

• consulting, coaching, training, and advisory programs

• memberships, events, and communities

• email, phone, and SMS communications

• surveys, promotions, and questionnaires

• any other digital or offline interaction with the Company

SECTION 2

Why We Collect Personal Information

We collect personal information for legitimate business purposes, including to:

• provide, manage, and improve our services, programs, and platforms

• process transactions, payments, invoices, and account administration

• communicate with you about your account, purchases, applications, and services

• respond to support requests and operational inquiries

• personalize user experience and service delivery

• administer memberships, applications, grants, events, and advisory programs

• send newsletters, alerts, updates, and promotional communications

• conduct internal reporting, analytics, and operational planning

• prevent fraud, misuse, unauthorized access, and payment abuse

• enforce contractual rights, billing terms, and platform rules

• comply with legal, regulatory, and compliance obligations

SECTION 3

What Personal Information We Collect

We may collect personal information when you voluntarily provide it to us, when you interact with our systems, or when such collection is otherwise lawful.

The categories of personal information we may collect include:

• full name

• email address

• mobile and other phone numbers

• mailing, billing, and business address

• company name, title, and related business information

• payment and billing information

• account credentials and profile information

• preferences regarding products, services, communications, or content

• demographic information you choose to provide

• application responses, intake data, and uploaded documents

• communications you send to us

• device data, browser type, IP address, and usage information

• website activity, interaction data, and analytics information

• social login or authentication data you authorize a third party to share

We may also receive information from affiliates, payment processors, CRM providers, analytics vendors, event platforms, referral partners, public sources, and other lawful third-party sources.

SECTION 4

Cookies and Similar Technologies

We use cookies, pixels, tags, scripts, and similar technologies to support website functionality, improve user experience, analyze traffic, personalize content, and measure marketing effectiveness.

These technologies may help us:

• remember user preferences

• maintain secure sessions

• understand how users interact with our websites

• measure traffic and engagement

• improve site performance

• deliver relevant content and advertising

You can control cookies through your browser settings. Disabling cookies may affect the functionality or performance of portions of our websites or services.

SECTION 5

Information Collected from Other Sources

We may obtain information from third-party sources and combine it with information we already have, where permitted by law.

These sources may include:

• social media platforms

• authentication or single sign-on providers

• payment processors

• advertising and analytics partners

• event and webinar platforms

• business partners and affiliates

• public databases or directories

• referral or lead-generation partners

If you connect a third-party service to our systems or log in through a third-party authentication provider, you authorize us to access and use the information made available to us under that provider’s authorization procedures and privacy settings.

Your interactions with social media features, embedded content, or third-party widgets are governed by the privacy policies of the companies providing those features.

SECTION 6

How We Protect Personal Information

We use commercially reasonable physical, technical, electronic, contractual, and administrative safeguards designed to protect personal information from unauthorized access, use, alteration, disclosure, or destruction.

These safeguards may include:

• SSL or comparable encryption technologies

• secure payment processing providers

• access controls and credential protections

• restricted internal access to sensitive information

• secure storage practices

• vendor confidentiality obligations

• monitoring for unauthorized or suspicious activity

Although we take reasonable steps to protect information, no method of internet transmission or electronic storage is completely secure. You are responsible for protecting your passwords, devices, and login credentials.

SECTION 7

How We Use Personal Information

We may use personal information to:

• deliver and administer services, memberships, products, and programs

• process payments and verify transaction authorization

• provide customer support and service communications

• communicate about purchases, invoices, renewals, applications, and updates

• personalize content, communications, and user experience

• provide newsletters, promotional messages, and special offers

• improve our websites, services, products, systems, and internal operations

• administer surveys, promotions, webinars, live events, and community engagement

• facilitate networking, application review, grant-related opportunities, and advisory access

• investigate payment disputes, misuse, fraud, or suspected unlawful conduct

• maintain internal records, reporting, and business operations

• enforce agreements, payment policies, platform rules, and legal rights

We may also use aggregated, anonymized, or de-identified data for operational, analytical, marketing, or strategic purposes.

SECTION 8

How and When We Disclose Personal Information

We may disclose personal information as reasonably necessary for business, legal, security, and operational purposes.

We may disclose information:

• to affiliates, subsidiaries, divisions, and associated entities within Smart People Network, Inc. and Lang & Co Holdings

• to service providers, contractors, consultants, and vendors who support our operations

• to payment processors, billing partners, communications providers, cloud storage providers, analytics vendors, CRM platforms, and software providers

• to attorneys, accountants, auditors, insurers, and compliance professionals

• to partners involved in delivering a service, event, or opportunity you requested

• to regulators, courts, law enforcement, or government authorities as required by law or legal process

• to investigate fraud, misuse, unauthorized activity, security incidents, or payment reversals

• to protect our rights, business operations, users, team members, property, or the public

• in connection with a merger, acquisition, financing, asset transfer, restructuring, bankruptcy, or sale of all or part of our business

We may also disclose de-identified or aggregate information that does not reasonably identify a particular individual.

SECTION 9

Legal Bases for Processing and Your Rights

Depending on your jurisdiction, we may process personal information based on one or more of the following:

• performance of a contract

• compliance with legal obligations

• our legitimate business interests

• your consent

• protection against fraud, abuse, and unlawful conduct

Subject to applicable law, you may have the right to:

• request access to certain personal information

• request correction of inaccurate information

• request deletion of certain information

• request restriction of certain processing

• object to certain processing

• request portability of certain information

• withdraw consent where processing is based on consent

You may also opt out of promotional emails by clicking the unsubscribe link included in the message. SMS opt-out procedures are set forth below.

If you are located in a jurisdiction that provides privacy-specific complaint rights, including the European Economic Area or United Kingdom, you may also have the right to file a complaint with an appropriate supervisory authority.

SECTION 10

Community Forums, Public Areas, and Testimonials

If you post in community forums, discussion spaces, chat areas, mastermind groups, or other public or semi-public environments operated by the Company, any information you submit may be visible to others and may be collected or used by those users.

Please do not post confidential, sensitive, or private information in public-facing areas unless you understand the risks of disclosure.

From time to time, we may publish testimonials, endorsements, reviews, or success stories. Where required, we will obtain permission before using your name, likeness, title, organization, or testimonial content.

To request removal or revision of a testimonial, contact us using the information below.

SECTION 11

Mobile Terms and SMS Communications

By providing your mobile phone number and affirmatively opting in, you agree that Smart People Network, Inc., Lang & Co Holdings, and their associated brands, programs, and affiliates may send you text messages, including SMS and MMS messages, related to your account, services, scheduling, updates, promotions, and other business communications.

Message frequency may vary. Message and data rates may apply depending on your carrier plan.

You may opt out of SMS communications at any time by replying STOP to any message. You may request assistance by replying HELP where available or by contacting us directly.

Your consent to receive text messages is not a condition of purchasing any goods or services unless expressly stated in connection with a specific program.

We do not sell, rent, or transfer mobile numbers or SMS consent data to unaffiliated third parties for their own marketing purposes.

Carriers are not liable for delayed or undelivered messages.

SECTION 12

Third-Party Websites and Services

Our websites, emails, and communications may contain links to third-party websites, applications, tools, or services. We are not responsible for the privacy practices, security, or content of those third-party services.

You should review the applicable privacy policies of any third-party service before providing personal information through that service.

SECTION 13

Data Retention

We retain personal information for as long as reasonably necessary to:

• provide services and support

• maintain business and financial records

• administer accounts, applications, memberships, and programs

• comply with legal, tax, accounting, and regulatory requirements

• resolve disputes and enforce agreements

• protect our legal and operational interests

Retention periods may vary depending on the nature of the information, the reason it was collected, and applicable law.

SECTION 14

Children’s Privacy

Our websites, products, and services are generally intended for business, professional, educational, and organizational users and are not directed to children under 13 unless expressly stated as part of a youth-centered initiative operated with proper authorization and supervision.

We do not knowingly collect personal information from children under 13 without legally sufficient authorization where required.

SECTION 15

Changes to This Privacy Policy

We reserve the right to revise or update this Privacy Policy at any time. Any updates will become effective when posted with a revised effective date unless otherwise stated.

Your continued use of our websites, programs, products, services, or communications after an updated Privacy Policy is posted constitutes acknowledgment of the revised Policy to the extent permitted by law.

You are responsible for reviewing this Privacy Policy periodically.

SECTION 16

Contact Us

If you have questions about this Privacy Policy, your personal information, your privacy rights, or our data practices, please contact:

Smart People Network, Inc.

Including Lang & Co Holdings and All Associated Affiliates, Programs, Divisions, and Brands

Privacy Contact: [email protected]

Support Contact: [email protected]

Call: (312) 478-9831