Privacy Policy

Last Updated: October 12, 2025

Thank you for visiting Trakflip. This Privacy Policy describes the personal information handling policies of Trakflip (or "we" or "us" or "our") in connection with our website at Trakflip.com (the "Website") and its service offerings (together with the Website, the "Services"), including the following:

• 1) What personal information we collect;
• 2) How we use the data;
• 3) With whom we may share the personal information;
• 4) Legal basis for processing the data;
• 5) Storage and security of your data;
• 6) Your Privacy Rights, Choices and Disclosures;
• 7) Users outside the United States;
• 8) Links to other sites;
• 9) Privacy Policy updates; and
• 10) Contact Information.

1. Personal Information We Collect or Process

The Services capture some information about you automatically utilizing background local storage and session storage technologies, such as cookies and web beacons (also referred to as clear gifs, pixel tags, single-pixel gifs and web beacons) (collectively, "Cookies"). Tracking Technologies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of the Services (including certain third-party services and features offered as part of our website). Examples of information collected by cookies are your IP address, the browser you are using, the operating system you are using, the pages on the website that you visit and details of your transaction activity, such as the amount, date and time for each transaction. We may use third-party companies to help us tailor content on the Services to users or to serve interest-based ads or messages on our behalf. These companies may employ Tracking Technologies to measure advertising or messaging effectiveness (such as which web pages are visited, which messages are responded to, or what products are purchased and in what amount).

When you use our Services the server housing the pages may automatically generate a "session log." We use session logs to help us determine how people travel through our Services. In this way, we can structure our pages so that the information most frequently visited is easier to find. By tracking page visits, we can also determine if the information we're providing is being used. The data gathered may include the IP address from which you came, the website or software application that referred you, the pages you visited and the date and time of those visits.

Our Services may use spotlight ads/web beacons/GIF/pixel tags which are instrumentation tools that help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. Emails or electronic newsletters we send may use tools (e.g., pixel tags or web beacons) to gather email metrics and information to improve the reader's experience such as how many of the emails are opened, if they were printed or forwarded, the type of device (e.g., mobile or PC) from which they were opened, and the city, state, and county associated with the applicable IP address. In general, any electronic image viewed as part of a webpage, including an ad banner, can act as a web beacon.

We use the Meta pixel for the purpose of re-targeting our users.

Most browsers will tell you how to stop accepting new Cookies, how to be notified when you receive a new Cookie, and how to disable existing Cookies. Please note, however, that without Cookies you may not be able to take full advantage of all of our Services' features. In addition, disabling Cookies may cancel opt-outs that rely on Cookies, such as web analytics or targeted advertising opt-outs.

We operate social media pages on third party networks and have social media icons on our Services. Further, you may log into your Services account via social media credentials. When you visit or link to our social media pages, or log into the Services with social media credentials, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

We may use third-party companies to help us tailor Website content to users or to serve ads or messages on our behalf. These companies may employ Cookies and web beacons to measure advertising or messaging effectiveness (such as which web pages are visited, which messages are responded to, or what products are purchased and in what amount).

When using your mobile device to visit, access or use the Services, then additional categories of information that we collect may include:

• Your name associated with your mobile device
• Your geolocation
• Your mobile device ID information

We also collect information that you provide to us voluntarily.

We collect the information you provide to us when you sign up to receive newsletters, advisories, announcements or invitations, and when you contact us by email, chat or phone. We use this information to respond to your comments, requests or questions.

When you sign up for our waitlist, we collect your name, email address, and information about your streaming history.

We do not knowingly collect information from users of our Services under the age of 18 and/or their internet usage, and such persons are not authorized to use the Services. If we obtain actual knowledge that a user is under 18, we will take steps to remove that user's personal information from our databases. By using the Services, you represent that you are at least 18 years old and of legal age to enter into legal agreements, or if you are not, that you are at least 13 years old and have obtained your parent's or legal guardian's consent to accept the terms in this Privacy Policy. If you are a parent or guardian of a minor, you can refuse to permit us to collect personal information from your child and can request that we delete from our records the personal information we have collected. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other Services.

2. How We Use the Data

We use the personal information we collect as follows:

• To send you marketing communications.
• To present display advertisements on our Website, which may be tailored to your interests.
• To add you to our waitlist.
• For general business purposes, including managing your relationship with us, responding to enquiries and requests, and administrative purposes.
• To complete services requested by you.
• To manage and assure the integrity of our platform.
• Provide the publications and information you request.
• To communicate with you, including to provide status updates, transactional emails and other service communications, to provide you with notices about your account and to contact you through telephone, text, email or chat, as permitted by law.
• To communicate with you for research purposes, including to request your participation in surveys.
• To provide, maintain, and protect our Services.
• To monitor the performance of our Services and improve your user experience.
• To satisfy legal obligations and compliance requirements under laws and regulations applicable to us and our affiliates.
• To protect and defend the rights and property of our users, Trakflip and its affiliates, and third parties.
• To comply with legal obligations and regulations to which Trakflip and its affiliates are subject and cooperate with regulators, other appropriate agencies or authorities and law enforcement bodies, both within your jurisdiction and internationally.
• To develop, improve and test certain of our products and services.
• For other purposes that we tell you about when you register or provide data about yourself to us.
• For other legitimate business and lawful purposes.

You consent to receive updates about our waitlist and service.

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal information not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

3. With Whom We Share Personal Information

Trakflip relies on some third parties for delivery of the Services who perform services on our behalf, including without limitation our technology providers (e.g., AWS and Mailchimp) and professional advisors.

We may disclose any information we have about you (including your identity) if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Services, or to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, or the rights or property of visitors to or users of the Services. We reserve the right at all times to disclose any information that we deem necessary to comply with any applicable law, regulation, legal process or governmental request. We also may disclose your information when we determine that applicable law requires or permits such disclosure, including exchanging information with other companies and organizations for fraud protection purposes.

We may share your data with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party.

We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.

4. Grounds for Using Your Personal Information

We rely on the following legal grounds to process your personal information:

• Consent. Some uses of your personal information as described in this Privacy Policy are subject to your consent, such as marketing email communications from us and communications from other users of the Services.
• Performance of a contract. We may need to collect and use your personal information to onboard you as a user perform Services that you request.
• Legitimate Interests. We may use your personal information for our legitimate interests to provide our Services and to improve our Services and the content contained thereon. We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.
• Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.

5. Storage and Protection of Your Personal Information

We retain the personal information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. We will retain personal information required to comply with privacy requests, to manage active accounts, as required by law, in order to resolve disputes, or to enforce our agreements.

We will retain the personal information we process on behalf of our users as directed by them. We may also retain copies of your personal information for disaster recovery purposes, to prevent fraud or future abuse, or for our legitimate business purposes.

Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.

We take reasonable administrative, physical and technical precautions to protect your personal information and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, dual authentication, encryption and written commitments from third parties that may have access to your data that they will protect the data with reasonable safeguards.

No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control. Users assume the risk of security breaches and the consequences resulting from them. Please be careful in deciding what information you send to us or to other users and what content you upload to the platform.

6. Your Rights, Choices and Disclosures

(a) General

This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at info@trakflip.com or make changes to any user profile information connected to your account, as available.

Section (b) below describes the rights of those individuals located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union's General Data Protection Regulation (GDPR). Section (c) contains disclosures required under California law.

In certain instances we provide you the opportunity to "opt-out" of having your personal information used for certain purposes. For example, if you sign up for the Services but do not wish to receive any additional marketing material from us, you may so indicate your preferences in your profile (if available) or click on the "unsubscribe" link in the communication.

Users may update or change their personal information by editing their profile. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.

Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal information, such as the right to complain to your local data protection authority and the right to appeal our decision regarding a data access request.

(b) Your European Privacy Rights and Choices

While we do not specifically market our Services outside the United States, we will provide accommodations for the rights of those who reside in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union's General Data Protection Regulation (GDPR), whose privacy rights include the following:

• Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
• Right of access, correction, restriction of processing, erasure. You may contact us to request information about the personal information we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations.
• Right to withdraw your consent at any time. When we process your personal information based on your consent, you have the right to withdraw it at any time.
• Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal information based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.
• Right to data portability. You have the right to data portability of your own personal information by contacting us.
• Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal information that may negatively impact you.
• Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal information infringes your privacy rights according to the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.

(c) California Disclosures

California "Shine the Light" Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to hey@trakflip.com with "California Shine The Light Rights" in the subject line.

California Do Not Track Disclosure: We not respond to Do Not Track browser settings.

California Consumer Privacy Act Disclosures. Trakflip is not yet a "business" subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA).

7. Users Outside the United States

The Services are hosted in the United States and are intended for and directed to users in the United States. If you are a user accessing the Services from Canada, the European Union, Asia, or any other region with laws or regulations governing personal information collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Services, which are governed by U.S. law, this notice and our other policies that govern your use of the Services, you are transferring your personal information to the United States and you consent to that transfer. The Services are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

8. Links to Other Sites

Our Services may contain links to other websites for your convenience or information. These websites may be operated by companies unaffiliated with us, and we are not responsible for the content or privacy practices of those websites. Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.

9. Privacy Policy Changes

We may update this Privacy Policy from time to time to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal information to us. If we make material changes to this Privacy Policy, we will notify you via the Services, by email or by means of a notice on our home page. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.

10. Questions and Contact Information

Please contact us if you have any questions about our Privacy Policy. You may contact us by emailing us at hey@trakflip.com.