Privacy Policy

Effective Date: February 1, 2025


I. General.

Heleus Holdings LLC (“Heleus”, “Company”, “us”, “our” or “we”) is committed to protecting your privacy.

This Privacy Policy describes the types of personal and other information we collect on our website (www.stackeleven.com) (the “Site”) and in the services we offer, how we use such information and to whom and under what circumstances we may disclose it. This Privacy Policy applies to the Site, our services and any other personal information obtained when you call, email, or otherwise communicate with us. By accessing the Site on any computer, mobile phone, tablet, or other device (collectively, “Device”) or otherwise interact with us or our services, you agree to the terms of this Privacy Policy. If you do not agree to terms and conditions in this Privacy Policy, please do not use the Site or our services. We may modify this Privacy Policy at any time and will post the current version on the Site. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the personal and other information we collect.

Personal information means any information that may be used to identify an individual, including, but not limited to, a first and last name, a physical address, an email address, IP address or other contact information including, gender, occupation, personal interests, location or other similar information.

II. Information We Collect.

Information You Give Us Directly -- For the 12-month period prior to the date of this Privacy Policy, we

explain here what categories of personal information we have collected, where we got it from, and with

whom we have shared it:

As a general matter, whenever you directly provide us with your personal Information, please be sure it is

accurate and complete. We cannot be responsible for any information you provide to us that is incomplete

or incorrect.

Be advised that by submitting your email address to the Site for any purpose or use, you agree to have

this email address included in our email mailing list and to be contacted by us.

In some jurisdictions, individuals may have the right to opt-in or withdraw consent for certain uses. If you

reside in such jurisdictions, you may have additional rights which are detailed in “Access, Correction &

Deletion” below.

Information We Collect Automatically -- When you access the Site, we may automatically collect certain

information about your Device and your interactions with the Site, including your Internet Protocol (IP)

address, MAC address, browser type, operating system, Device-identifying information, the specific web

pages visited immediately preceding your connection, and the domain name from which you accessed

the Site. In addition, we may collect information about your browsing behavior, such as the date and time

you visit the Site, the areas or pages of the Site you visit, the number of times you return to the Site and

other clickstream data.

When Administering Our Agreements -- We collect the personal Information of our customers and

partners who manage and administer their agreements and interactions with us. This personal information

may include these persons’ names and business contact information.

Information about Individual Consumers -- We may receive personal information of individual consumers

from our customers and partners in the course of providing our products and services to them. This

information may include: Customer ID, IP Address, online identifiers, device information (e.g., mobile ad

ID) and usage agent and data, and tracking pixels. Our access to and use of this personal information is

subject to the agreements with our customers and partners and not this Privacy Policy.

Information from Other Sources -- We may collect personal information about you from other sources,

such as third-party providers and publicly available sources (like social media platforms). This may

include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social

media profiles. This helps us to update and improve our products, services, and records; identify potential

new customers; suggest products and services that may interest you; deliver marketing or promotional

communications and serve targeted advertising. If you provide personal information to these third parties,

including social networks, these organizations’ privacy policies apply to their collection and use of your

personal information and not this Privacy Policy.

III. How We Use Your Information.

The table below explains what we use (process) your personal information for and our reasons for doing

so:

Do Not Track - Please note that we do not alter our Site's data collection and use practices when we receive a Do Not Track signal from your browser.

IV. Disclosure of Information.

We may disclose information collected from and about you as follows: (1) to our related companies and

service providers, to perform a business, professional or technical support function for us; (2) to our

business, sales and marketing partners and affiliates, advertisers or other third parties, who may contact

you with their own offers; (3) as necessary if we believe that there has been a violation of this Privacy

Policy, our rights or the rights of any third party; (4) to respond to legal process (such as a search

warrant, subpoena or court order) and provide information to law enforcement agencies or in connection

with an investigation on matters related to public safety, as permitted by law, or otherwise as required by

law; and (5) in the event that our Company or substantially all of its assets are acquired, or there is a re-

structuring, your personal information may be one of the transferred assets. We may also disclose your

personal information with your express consent. We may share aggregate, non-personally identifiable

information about Site users with third parties.

Please note that if you voluntarily submit any personal information for posting on the Site (if available),

such as a review or a blog post, the information becomes publicly available and can be collected and

used by others, so you should use care before posting information about yourself online.

V. Basis for Processing Personal Information.

We may process personal information under the following conditions:

Consent: You have given your consent for processing personal data for one or more

specific purposes.

Performance of a contract: Provision of personal data is necessary for the performance

of an agreement with you and/or for any pre-contractual obligations.

Legal obligations: Processing personal data is necessary for compliance with a legal

obligation to which the Company is subject.

Legitimate interests: Processing personal data is necessary for the purposes of legitimate

business or commercial interests pursued by the Company.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and

whether the personal data is a statutory or contractual requirement, or a requirement necessary to enter a

contract.

*A legitimate interest is when we have a business or commercial reason to use your information, so long

as this is not overridden by your own rights and interests.

VI. Cookies and Other Tracking Technologies.

A cookie is a small data text file, which is stored on the hard drive of your device. Each cookie is unique to

your web browser. It will contain some anonymous information such as a unique identifier, a website’s

domain name, and some digits and numbers. Cookies cannot be used to run programs or deliver viruses

to your Device. At no time will our cookies collect your personal information.

When you visit our Site, we may store certain types of “session” or “persistent” cookies on your device to

authorize access to our private content and to facilitate and customize your use of our Site. A session

cookie is be active during the time you are viewing a website. A persistent cookie remembers information,

settings, preferences, or sign-on credentials that the user has previously saved.

The following types of cookies are used on our Site:

Essential cookies

Essential cookies allow us to offer you the best possible experience when accessing and

navigating through our Site and using its features. For example, these cookies let us recognize

that you have created an account and have logged into that account.

Functionality cookies

Functionality cookies let us operate the Site in accordance with the choices you make. For

example, we will recognize your username and remember the choices that you made to your

account during future visits.

Analytical cookies

These cookies enable us and third-party service providers to collect aggregated data for

statistical purposes on how our visitors use our Site. These cookies do not contain or collect

personal information and are merely used to help us improve your user experience of the Site.

Targeting cookies

These cookies collect information about your browsing habits in order to provide advertising

which is more relevant to you and your interests – for example, they remember the websites you

have visited and share that information with other parties such as publishers, ad exchanges and

ad technology service providers.

Once you leave our Site, our persistent cookies remain on your hard drive, although some expire after 6

months or 1 year. This helps create a convenient and faster Site experience.

In addition, we may use cookies to: (1) allow you to use the Site without having to re-enter your username

and password (if applicable); (2) enhance or personalize your Site usage and shopping experience; (3)

monitor Site usage; (4) manage the Site; and (5) improve the Site and our products and services.

We also may use cookies to provide you with interest-based ads tailored to your Device. For more

information on our advertising, see below: “Interest-Based Advertising.”

If you choose, you can set your browser to reject cookies or manually delete individual cookies or all of

them on your computer by following your browser’s help file directions. (See www.allaboutcookies.org to

learn how to disable cookies on your browser or otherwise opt out of cookies.) However, if your browser is

set to reject cookies or you manually delete cookies, you may have some trouble accessing and using

some of the pages and features that are currently on our Site, or that we may put on our Site in the future.

Note that browser-management tools for cookies are outside of our control, and we cannot guarantee

their effectiveness. We may combine the information we collect through cookies, web beacons, or other

technology tools with other information we have collected from you or information from other sources.

Some content or applications, including advertisements, on the website and platform are served by third

party advertisers, ad networks and servers, content providers, and application providers. These third

parties may use cookies to collect information about you when you visit our Site and use our services.

The information they collect may be associated with your personal information or they may collect

information, including personal information, about your online activities over time and across different

websites and other online services. They may use this information to provide you with interest-based

advertising or other targeted content. We do not control these third parties' tracking technologies or how

they may be used. If you have any questions about an advertisement or other targeted content, you

should contact the responsible provider directly.

We also use web beacons and pixels on our website and in emails. For example, we may place a pixel in

marketing emails that notify us when you click on a link in the email. We use these technologies to

operate and improve our Site and marketing efforts.

VII.Interest-Based Advertising.

We may use third-party advertising companies that use tracking technologies to serve our advertisements

across the Internet. These companies may collect information about your visits to the Site and other

websites and your interaction with our advertising and other communications. These advertising

companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be

personalized, meaning that they are intended to be relevant to you based on information collected about

your visits to the Site and elsewhere over time. Other companies may also use such technology to

advertise on our Site or third party websites. You have the choice to tell us not to collect and use this

information, and in some jurisdictions, we will only engage in interest-based advertising if you opt in.

For more information about interest-based advertising and targeting cookies and your choices to accept

or opt out, please see the following websites:

• Network Advertising Alliance (US) at: https://optout.networkadvertising.org/?c=1

• Digital Advertising Alliance Consumer Choice (US) at: https://optout.aboutads.info/?c=2&lang=EN

You also can request to opt out of interest-based advertising by using the contact information in “Contact

Us” below.

VIII.Analytics

We deploy technologies to track the performance of our Site as well as specific performance data through

demographic data about the user and Device that visits the Site, and metrics like time on the website, scroll

depth, click-through rates, impressions, and conversion rates. Specifically, we use Google Analytics to help us

understand how our users use the website. You can read more about how Google uses your Personal

Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics

here: https://tools.google.com/dlpage/gaoptout

We may also use non-personal or aggregated information for statistical analysis, research, and other purposes.

IX. Promotional Communications.

We may use your personal information to send you updates (by email, text message, telephone or post)

about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see

above “Basis for Processing Personal Data”). This means we do not usually need your consent to send

you promotional communications. However, where consent is needed, we will ask for this consent

separately and clearly.

We will always treat your personal information with the utmost respect.

You have the right to opt out of receiving promotional communications at any time by contacting us by

using the contact information detailed in “Contact Us” below.

X. Your Choices.

We or our partners may send you informational emails about offers of services or services. At any time,

you can ‘unsubscribe’ yourself from our email list simply by clicking the ‘unsubscribe’ button. Additionally,

you can ‘unsubscribe’ yourself from our SMS/text messages by replying ‘stop’. If you do not wish to

receive communications from us about special offers and promotions, you can opt-out of receiving these

communications by following the instructions contained in the messages you receive. You also can opt

out by sending us a request by using the contact information in “Contact Us” below.

Even if you opt-out of receiving these messages, we reserve the right to send you certain

communications relating to the services we provide, and we may send you service announcements and

administrative messages. We do not offer you the opportunity to opt-out of receiving those

communications.

XI. Retention of Personal Information.

We will retain your personal information for as long as needed in order to perform the purposes for which

such personal information was collected. Thereafter, we will keep your personal information for as long as

is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;

• To show that we treated you fairly; or

• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this

policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

XII.Security.

We maintain reasonable and appropriate measures designed to maintain the information we collect in a

secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and

secure the information we collect from visitors to the Site. Even though we follow commercially

reasonable procedures to try to protect your information in our possession, no security system is perfect,

and we cannot promise, and you should not expect, that your information will be secure in all

circumstances.

XIII.Children.

The Site is not directed to children (anyone under 13 years of age), nor do we knowingly solicit or collect

any personal information from children without verifiable parental consent. If we discover that we have

received any personal information from a child, we will investigate promptly and then delete such information from our system if warranted. If you are a parent or legal guardian of a child and you become

aware that your child has provided us with personal information, please contact us promptly using the

contact information detailed in the “Contact Us” section below. Parents and legal guardians always have

the right to inspect any information that we may have inadvertently collected from their child and have the

right to have us delete it.

XIV.Third Party Websites.

The Site may contain links to third-party websites, such as social media sites, i.e., Facebook and X

(formerly Twitter), which may have privacy policies that differ from our own. We are not responsible for the

activities and practices that take place on these third-party websites. Accordingly, we recommend that you

review the privacy policies posted on any external site before disclosing any personal information. Please

contact those websites directly if you have any questions about their privacy policies.

XV.Changes to This Privacy Policy.

We may change this Privacy Policy from time to time, including as required to keep current with rules and

regulations, new technologies and security standards. When we do, we will post the change(s) on our

Site. If we change the policy in a material and retroactive manner, we will attempt to provide appropriate

notice to you.

XVI.Where Your Personal Information is Held.

Personal information may be held at our offices and those of our third-party service providers,

representatives and agents as described above (see “Disclosure of Information”).

Some of these third parties may be based outside the U.S.A. or European Economic Area. For more

information, including on how we safeguard your personal information when this occurs, see “Transferring

Your Personal Information between the U.S. and the EEA” below.

XVII.Transferring Your Personal Information between the US and

the EEA and UK.

To deliver services to you, it is sometimes necessary for us to share your personal information between the

United States and the European Economic Area (EEA) and UK.

As an example, your information, including personal data, is processed at the Company's operating offices and

in any other places where the parties involved in the processing are located. It means that this information may

be transferred to — and maintained on — computers located outside of your state, province, country or other

governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you submit any personal information to us, you expressly consent to this Privacy Policy, including our ability to

transfer your personal information between jurisdictions.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in

accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a

country unless there are adequate controls in place including the security of your data and other personal

information.

If you would like further information, please contact us or our Data Protection Officer (see “Contact Us” below).

If we need, or are required, to contact you concerning any event that involves your information, we may do so

by email, telephone, or mail.

XVIII.Access, Correction, & Deletion.

We respect your right to access and correct your personal information. You may exercise your rights,

subject to applicable laws, to request that we delete or restrict access to your personal data. We may

need to retain it for legally permitted purposes, and this will be explained to you if necessary.

If you need assistance correcting or updating your personal information or would like to request that we

delete your personal information, please contact us using the contact information detailed in the “Contact

Us” section below.

XIX.U.S. State Privacy Laws.

a. California Consumer Privacy Act

The California Consumer Privacy Act (as amended by the California Privacy Rights Act) (together, the CCPA)

gives California consumers enhanced rights with respect to their personal information that is collected by businesses. If you are a California consumer, California law provides you with the following additional rights

with respect to your Personal Information:

• The right to know what personal information we have collected, used, disclosed and sold about you.

You may submit a request to know by using the contact information detailed in this section. You also

may designate an authorized agent to make a request for access on your behalf.

• The right to request that we delete any personal information we have collected about you. You may

submit a request for deletion by using the contact information detailed in this section. You also may

designate an authorized agent to make a request for deletion on your behalf.

California consumers may also have the right not to be subject to automated decision-making, including

profiling, where it would have a legal or similarly significant effect on them; and the right to data portability

regarding the data they provided to us. California consumers can use an authorized agent to submit a request

on their behalf. We may request proof that the consumer gave the agent signed permission to submit the

request.

If you exercise any of these rights and submit a request to us, please email us at: please send us a request by

using the contact information in “Contact Us” below. Your exercise of these rights will have no adverse effect

on the price and quality of our goods or services.

We will confirm receipt of your request within 10 business days. We must provide the requested information or

delete or correct your Personal Information within 45 days of receipt of your request, but we can use up to an

additional 45 days if we let you know that additional time is needed.

Before responding, we must verify that the person making the request is the person about whom we have

collected their personal information. We may ask you to provide certain, limited Personal Information, such as

your name and email address to verify and match your identity with our records and systems. If you have an

account with us, we may ask that you verify your identity through our account authentication process. This is

also to protect against fraud. We will not retain this personal information or use it for any other purpose.

Also please be advised that we need to search our records and systems only for the preceding 12 months.

There may be cases where we do not have any personal information about you or we are not able to verify

your identity for matching purposes. Deleting your personal information may result in the inability to access

certain areas of the Site or services.

b. Do Not Sell or Share Personal Information.

If you’re a California consumer, you may have a right to opt-out from the “sale” or “sharing” of your Personal

Information with third parties who are not our service providers (as those terms are defined CCPA).Our use of

Personal Information to serve you interest-based advertising may constitute the “sale” or “sharing” of personal

information for cross-contextual behavioral advertising under the CCPA. Where legally required, we will honor

California consumers’ requests to opt out of this sharing of their personal information for this purpose.

To exercise this right, please send us a request by submitting your information on our “Contact Us” page

(www.stackeleven.com/contact). In your message, please indicate in the message box “California Do Not Sell/

Share Request”.

c. California “Shine The Light” Law

California Civil Code § 1798.983 permits our customers who are California residents to request certain

information about our disclosure of their personal information to third parties for direct marketing purposes

during the preceding calendar year. This request is free and may be made once a year. To do so, please

contact us by using the contact information in “Contact Us” below and stating your specific request and

your name, address, e-mail address and phone number. Please allow a minimum of 30 days for a

response. This will not prohibit disclosure of information for non-marketing purposes.

d. Connecticut Data Privacy Rights.

If you are a Connecticut resident, (Public Act No. 22-15) An Act Concerning Personal Data Privacy and

Online Monitoring provides you additional rights with respect to your personal information. The Act grants

Connecticut consumers the right to: (i) access, correct, delete and obtain a copy of personal data that we

collect, and (ii) opt out of the processing of personal data for the purposes of (i) targeted advertising, (ii)

certain sales of personal data, or (iii) profiling. If you would like to exercise any of the rights described

above, please send us a request by using the contact information in “Contact Us” below. In your

message, please indicate in the subject line “Connecticut Privacy Request” and providing us with your

name and the email address and the specific privacy request.d. Utah Consumer Privacy Rights.

If you are a Utah resident, the Utah Consumer Privacy Act (UCPA) (S.B. 227) gives consumers a number

of rights related to their personal data, including the right to: (i) access and delete personal data, (B) opt

out of the collection and use of personal data for certain purposes, and (ii) obtain a copy of their personal

data. If you would like to exercise any of the rights described above, please send us a request by using

the contact information in “Contact Us” below. In your message, please indicate in the subject line “Utah

Privacy Request” and providing us with your name and the email address and the specific privacy

request.

e. Virginia Consumer Data Privacy Rights.

If you are a Virginia resident, the Virginia Consumer Data Protection Act (“VCDPA”) (Va. Code § 59.1-575)

allows for consumers to request that the company collecting their personal data: (i) confirm if the

company is actually processing their personal data, (ii) correct inaccuracies in the consumer’s personal

data that is collected by the company, (iii) delete personal data provided by or obtained about the

consumer, (iv) obtain copies of the personal data collected by the company, and (v) opt out of the

processing of personal data for purposes of targeted advertising, the sale of personal data, or further

profiling. If you would like to exercise any of the rights described above, please send us a request by

using the contact information in “Contact Us” below. In your message, please indicate in the subject line

“Virginia Privacy Request” and providing us with your name and the email address and the specific

privacy request.

f. Nevada Do Not Sell Opt Out

If you are a Nevada resident, the Nevada Privacy Law (SB 220) enables you to ask us to add you to our

opt-out list for possible future sales of certain information we have collected or will collect about you. A

sale under Nevada law is the exchange of personal information for monetary consideration by the

business to a third-party for the third-party to license or sell the personal information to other third parties.

If you would like to exercise any of the rights described above, please send us a request by using the

contact information in “Contact Us” below. In your message, please indicate in the message box “Nevada

Do Not Sell Request” and providing us with your name and the email address.

g. Other US States

Several other states have enacted consumer privacy laws similar to the CCPA. Like the CCPA, these

other state consumer privacy laws may provide certain privacy rights to their residents. To the extent

applicable, we will honor privacy rights requests under these other US state consumer privacy laws.

Please email us at: info@hercampus.com with proof of your state residency.

XIX. Your Rights.

We want you to be in control of how your personal information is used by us. Please note that our ability

to access or control your personal data will be limited, as required or permitted by applicable law.

Depending on your jurisdiction, you may have the right to be informed of, and request access to, the

personal data we process about you; update and correct inaccuracies in that information; have the

information restricted or deleted; object or withdraw your consent to certain uses of data; and lodge a

complaint with your local data protection authority. You may also have the right not to be subject to

automated decision-making, including profiling, where it would have a legal or similarly significant effect

on you; and the right to data portability with regard to the data you provided to us. We will not discriminate

against you for the exercise of these rights.

If you would like to exercise any of the rights described above, please send us a request by using the

contact information in “Contact Us” below. In your message, please indicate the right you would like to

exercise and your jurisdiction. We may ask you for additional information to confirm your identity and for

security purposes, before disclosing the personal information requested from you. We reserve the right to

charge a fee where it is permitted by law, for instance if your request is manifestly unfounded or

excessive. We may not always be able to fully address your request, for example if it would impact the

duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different

way.

XX. How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this Privacy Policy, please contact us using

the contact information detailed in the “Contact Us” section below.

Please be reminded that you may only make a CCPA-related data access or data portability disclosure

request once within any 12-month period.

If you choose to contact us directly by phone, email, or in writing, you will need to provide us with:• Enough information to identify you (e.g., your full name, address and customer or

matter reference number);

• Proof of your identity and address (e.g., a copy of your driving license or passport);

and

• A description of what right you want to exercise and the information to which your

request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the

person making the request is the person about whom we collected information or is someone authorized

to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be

used solely for the purposes of verification.

XXI. Right to Lodge Complaints.

We are transparent about the ways in which we collect and use personal information and welcome your

questions and concerns. We hope that we or our Data Protection Officer can resolve any query or

concern you raise about our use of your information.

If you have any concern or complaint about the way we handle your personal information, please contact

us using the contact information detailed in the “Contact Us” section below. To the extent you believe we

have not addressed your concerns or otherwise chosen to do so, you have the right to lodge a complaint

with a supervisory authority in the country where you reside.

If you are a United States resident, you may contact the U.S. Federal Trade Commission regarding your

concerns. For more information, please see: https://www.ftc.gov/media/71268

XXII. Contact Us.

If you have questions or concerns about this Privacy Policy or how we collect and use the information of

our customers, you can contact us by sending a letter to us at the appropriate address below:

Heleus Holdings LLC

ATTN: Privacy Protection Officer

2101 Gaither Rd #125, Rockville, MD 20850

info@stackeleven.com