Privacy Policy

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

We use the information we collect to provide, maintain, and improve our services, communicate with you about our services, and respond to your inquiries. We also use this information for marketing, analytics, and to comply with legal obligations.

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.

SMS Opt-In Data — Exclusion from Sharing: All of the above categories exclude text messaging originator opt-in data and consent. All text messaging originator opt-in data and consent will not be shared with any third parties or affiliates for marketing or promotional purposes. This information is collected solely to facilitate the SMS programs described in this Privacy Policy and our Terms of Service, and will only be used for the specific purpose for which it was provided.

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.

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 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.
• Functionality cookies — Functionality cookies let us operate the Site in accordance with the choices you make.
• 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.
• Targeting cookies — These cookies collect information about your browsing habits in order to provide advertising which is more relevant to you and your interests.

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.

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. 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.

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.

You have the choice to tell us not to collect and use this information. For more information about interest-based advertising and your choices, please see:

• Network Advertising Alliance (US): https://optout.networkadvertising.org
• Digital Advertising Alliance Consumer Choice (US): https://optout.aboutads.info

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 at: google.com/policies/privacy. You can also opt-out of Google Analytics at: 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, 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 by these channels. This means we do not usually need your consent to send you promotional communications by email, telephone or post. However, where consent is needed, we will ask for this consent separately and clearly.

SMS & Text Message Communications — Explicit Consent Required: Notwithstanding the above, SMS and text message communications require your explicit prior consent. We will not send you SMS marketing messages without your express written opt-in. Your consent to receive SMS messages is voluntary and is not a condition of purchasing any goods or receiving any services from us. You can withdraw your consent at any time by replying STOP to any SMS message you receive from us. Message frequency varies. Message and data rates may apply.

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

XIV. Third Party Websites

The Site may contain links to third-party websites, such as social media sites, 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.

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.

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.

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.

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.
• The right to request that we delete any personal information we have collected about you.
• The right not to be subject to automated decision-making, including profiling, where it would have a legal or similarly significant effect.
• The right to data portability regarding the data you provided to us.

If you exercise any of these rights, 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.

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 under the 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 page. 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 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.

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 targeted advertising, certain sales of personal data, or profiling. If you would like to exercise any of these rights, please send us a request by using the contact information in "Contact Us" below. In your message, please indicate "Connecticut Privacy Request".

e. 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, (ii) opt out of the collection and use of personal data for certain purposes, and (iii) obtain a copy of their personal data. If you would like to exercise any of these rights, please send us a request by using the contact information in "Contact Us" below. In your message, please indicate "Utah Privacy Request".

f. 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, (iii) delete personal data, (iv) obtain copies, and (v) opt out of processing for purposes of targeted advertising, sale of personal data, or profiling. If you would like to exercise any of these rights, please send us a request by using the contact information in "Contact Us" below. In your message, please indicate "Virginia Privacy Request".

g. 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 this right, please send us a request by using the contact information in "Contact Us" below. In your message, please indicate "Nevada Do Not Sell Request".

h. 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 contact us using the information in "Contact Us" below with proof of your state residency.

XX. Your Rights

We want you to be in control of how your personal information is used by us. 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. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested from you.

XXI. 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.

If you choose to contact us directly, 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.

XXII. Right to Lodge Complaints

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

If you are a United States resident, you may contact the U.S. Federal Trade Commission regarding your concerns. For more information, please see: ftc.gov.

XXIII. 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:

[email protected]