Lead Apparel, Inc. This Privacy Policy explains how Lead Apparel, Inc. ("Lead Apparel," "we," "us," or "our") collects, uses, discloses, and retains personal information when you interact with Lead Apparel, use the Launch platform, visit a Launch storefront, purchase merchandise, or otherwise use the services described below. Please read this Privacy Policy carefully. If you use Launch through your employer, client, membership organization, or another business customer, that organization may also have its own privacy notice and may determine how certain information is used within its storefront or program. 1 Scope of this Privacy Policy This Privacy Policy applies to personal information collected through leadapparel.com, the Launch platform and related dashboards, Launch storefronts, free trials, customer support, order and fulfillment activities, and related online or offline interactions (collectively, the "Services"). This Privacy Policy does not apply to third-party websites, applications, or services that maintain their own privacy notices. It also does not govern the independent privacy practices of a Lead Apparel customer, such as an employer that selects eligible users, determines purchasing permissions, or provides information to operate its company store. 2 Personal Information We Collect The personal information we collect depends on how you interact with the Services. 2.1 Account and contact information We may collect your name, business email address, telephone number, organization, job title, store name, account credentials, account role, authentication information, and communication preferences. 2.2 Customer and authorized-user information A business customer or its administrator may provide information about employees, members, clients, guests, or other authorized users. This information may include names, email addresses, organizational affiliations, eligibility tags, store permissions, and information used to administer Launch Codes, gift programs, purchasing allowances, or other customer-funded programs. 2.3 Store, branding, and program information We may collect company names, logos, artwork, brand files, product selections, decoration preferences, storefront settings, administrator instructions, launch dates, shipping configurations, and other information used to configure or operate a branded storefront. 2.4 Order, transaction, and fulfillment information When an order is placed, we may collect purchaser and recipient names, email addresses, telephone numbers, billing and shipping addresses, product and sizing selections, order history, Launch Code or gift-card usage, payment status, shipment details, delivery confirmations, and information relating to returns, replacements, or customer service. 2.5 Payment and financial information Payments may be processed by third-party providers such as Stripe and Plaid. Depending on the payment method, these providers may collect payment-card information, bank-account information, account-verification information, transaction details, and related financial information. Lead Apparel generally receives payment confirmations, limited payment-method details, transaction identifiers, and information needed for billing, reconciliation, refunds, and fraud prevention rather than complete card or bank credentials. 2.6 Communications and support information We collect information contained in emails, support requests, calls, surveys, feedback, project records, and other communications with Lead Apparel. We may maintain internal notes necessary to respond to requests, manage customer relationships, or resolve operational issues. 2.7 Device, usage, and analytics information When you use the Services, we and our service providers may automatically collect IP address, browser and device type, operating system, referring pages, pages viewed, links selected, approximate location derived from IP address, session timing, feature usage, diagnostic information, cookie identifiers, and similar internet or electronic activity information. We use analytics technologies, including Google Analytics 4 and Hotjar. Hotjar may record selected user sessions and interactions to help us understand and improve the Services. Sensitive form fields are configured to be masked or excluded from recordings. 3 Sources of Personal Information We may collect personal information: · directly from you when you create an account, communicate with us, configure a store, or place an order; · from the business customer or administrator that provides access to a Launch storefront or program; · from other users who purchase or ship merchandise for you; · automatically through cookies, pixels, log files, session-recording tools, and similar technologies; · from payment, identity-verification, commerce, shipping, and other service providers; and · from advertising, analytics, business-information, referral, and publicly available sources, where permitted by law. 4 How We Use Personal Information We may use personal information to: · provide, configure, maintain, and support the Services and branded storefronts; · create accounts, authenticate users, send one-time passwords, and manage roles and permissions; · administer free trials, selected plans, subscriptions, store openings, and account changes; · manage authorized-user eligibility, Launch Codes, gift cards, allowances, and customer-funded purchasing programs; · process orders, payments, invoices, refunds, production, decoration, fulfillment, shipping, delivery, returns, and replacements; · communicate about accounts, transactions, service changes, security, support, and administrative matters; · send marketing communications where permitted and manage communication preferences; · personalize and improve the Services, develop features, measure performance, and understand user behavior; · detect, investigate, and prevent fraud, misuse, security incidents, and violations of our agreements; · protect our rights, users, customers, personnel, property, and the integrity of the Services; and · comply with legal obligations, maintain business and tax records, resolve disputes, and enforce agreements. 5 Information Provided by Organizations Lead Apparel customers may provide personal information about employees, members, clients, or other authorized users to operate a Launch program. The customer determines matters such as who may access a storefront, what purchasing benefits are available, and how the program is administered. Where Lead Apparel processes this information on the customer's behalf, the customer is responsible for providing any required notices and having an appropriate legal basis or authorization to provide the information. If your information was provided by an organization and you have questions about that organization's decisions or instructions, please contact the organization first. We may refer a privacy request to that organization when it controls the relevant information or decision. 6 How We Disclose Personal Information We may disclose personal information to the following categories of recipients when reasonably necessary for the purposes described in this Privacy Policy: · business customers and storefront administrators, including reporting about program eligibility, orders, spending, and store activity; · hosting, cloud infrastructure, security, content-delivery, authentication, email, collaboration, customer-support, analytics, and platform-operations providers; · commerce, inventory-management, payment, ACH, accounting, invoicing, and fraud-prevention providers; · merchandise suppliers, decorators, manufacturers, packaging providers, warehouses, fulfillment partners, and shipping carriers; · advertising and measurement partners that help us evaluate campaigns or deliver relevant advertising; · professional advisers, auditors, insurers, financing sources, and other business advisers; · government authorities, courts, regulators, law enforcement, or other parties when disclosure is required or permitted by law; and · a buyer, investor, lender, or successor in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction. We may also disclose information at your direction, with your authorization, or as otherwise described when the information is collected. 7 Cookies Analytics and Advertising We and our providers use cookies, pixels, tags, local storage, and similar technologies to operate the Services, remember preferences, maintain sessions, measure performance, understand usage, prevent fraud, and support advertising and campaign measurement. These technologies may be provided by companies such as Google, Hotjar, LinkedIn, and Meta. They may collect or receive identifiers, device and browser information, pages viewed, interactions, referring information, approximate location derived from IP address, and information about whether an advertisement or communication resulted in a visit or transaction. You may manage cookies through the cookie-preference controls made available on the applicable Service and through your browser or device settings. The availability and effect of these controls may depend on the Service, browser, device, and region. Blocking certain technologies may affect the functionality of the Services. 8 Communications Lead Apparel uses service providers, including Shopify and SendGrid, to deliver transactional and service-related emails. SendGrid also supports delivery of Launch one-time-password emails. We use Klaviyo for marketing and promotional communications. You may unsubscribe from marketing emails using the link in the message or by contacting us. Even if you opt out of marketing communications, we may continue sending nonpromotional communications that are necessary to administer an account, authenticate access, complete a transaction, provide support, or communicate important service or legal information. 9 Sale Sharing and Targeted Advertising Lead Apparel does not sell personal information for money. However, certain disclosures through advertising cookies and pixels may be treated as a "sale," "sharing," or use for "targeted advertising" under some U.S. state privacy laws. These activities may involve identifiers, internet or electronic activity information, commercial information, approximate location, and inferences disclosed to advertising and analytics partners. Where applicable, you may opt out through our cookie-preference controls or by contacting us using the information below. We do not knowingly sell or share for cross-context behavioral advertising the personal information of individuals under 16 years of age. 10 Data Retention We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain customer and user accounts, preserve store configurations for potential reactivation, complete production and fulfillment, comply with accounting, tax, and legal obligations, resolve disputes, prevent fraud, and enforce agreements. Retention periods vary according to the nature and sensitivity of the information, the business purpose for which it was collected, contractual requirements, applicable limitation periods, and legal obligations. Store configuration information may be retained for a limited period after cancellation to support reactivation, while order, payment, tax, shipping, and legal records may be retained longer. When information is no longer required, we may delete, deidentify, or aggregate it, subject to lawful backup and archival practices. 11 Data Security We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of account credentials and for notifying us promptly if you suspect unauthorized account activity. 12 Your Privacy Rights and Choices Depending on where you live and subject to applicable exceptions, you may have the right to request access to personal information, correction of inaccurate information, deletion, a portable copy, or additional information about our collection and disclosure practices. You may also have the right to opt out of targeted advertising, certain profiling, or certain sales or sharing of personal information, and to appeal a decision regarding a privacy request. To submit a request, email launch@leadapparel.com with the subject line "Privacy Request" or write to us at the address below. Please describe your request and the relationship through which Lead Apparel received your information. We may need to verify your identity and authority before completing a request. An authorized agent may submit a request where permitted by law, but we may require proof of authorization and verification of the consumer's identity. We will not discriminate against you for exercising an applicable privacy right. Some information may be exempt from a request, and we may retain information where permitted or required by law. If we process information on behalf of a business customer, we may direct the request to that customer. 13 International Users Lead Apparel is based in the United States. If you access the Services from another country, your information may be transferred to, stored in, and processed in the United States and other locations where Lead Apparel or its providers operate. Those locations may have data-protection laws that differ from the laws where you live. Where required, we use appropriate measures for international transfers. 14 Children’s Privacy The Services are intended for business and organizational merchandise programs and are not directed to children under 13. We do not knowingly collect personal information directly from children under 13. If you believe a child has provided personal information to us, please contact us so that we can evaluate and address the matter. 15 Third Party Services and Links The Services may contain links to or integrations with third-party websites and services. Their privacy practices are governed by their own notices. We encourage you to review those notices before providing personal information directly to a third party. 16 Changes to this Privacy Policy We may update this Privacy Policy periodically to reflect changes in the Services, our practices, technology, or applicable law. We will post the updated Privacy Policy and update the date displayed above. If required by law, we will provide additional notice of material changes. 17 Contact Us For questions or requests concerning this Privacy Policy or our privacy practices, contact: Lead Apparel, Inc. 410 Shawmut Avenue La Grange, Illinois 60526 Email: launch@leadapparel.com