STRATLEND WEALTH ACADEMY LP

PRIVACY POLICY

Last Updated: October 2025

INTRODUCTION

StratLend Wealth Academy LP ("Academy," "Company," "we," "us," or "our"), located at 14784 Winnwood Rd, Dallas, TX 75254, with General Partner Colter Doty, is committed to protecting your privacy and ensuring you have a positive experience on our website and through our services.

This Privacy Policy ("Policy") explains how we collect, use, disclose, protect, and otherwise handle your personal information when you access, browse, or use stratlend-demo.com, our related websites, platforms, mobile applications, services, courses, coaching programs, and any other services we provide (collectively, the "Service").

Please read this Privacy Policy carefully. By accessing or using the Service, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with our privacy practices, please do not use the Service.

This Privacy Policy should be read in conjunction with our Terms and Conditions. If there is any conflict between this Privacy Policy and the Terms and Conditions, the more protective provision for your personal information shall apply.

1. DEFINITIONS

1.1 "Personal Information" or "Personal Data" means any information that identifies, relates to, describes, or could be linked with a particular individual, including but not limited to:

- Name, email address, and contact information

- Phone number and mailing address

- Demographic information (age, gender, location)

- Username and password

- Payment and billing information

- Educational background and professional history

- Financial information and transaction history

- Communications and correspondence

- Device identifiers and usage data

1.2 "Sensitive Personal Information" means special categories of Personal Information that require heightened protection, such as health information, financial account numbers, government identification numbers, or other data as defined by applicable privacy laws.

1.3 "Processing" means any operation performed on Personal Information, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, transmission, erasure, or destruction.

1.4 "Data Subject" means the individual to whom Personal Information relates.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

The Academy collects Personal Information that you voluntarily provide, including:

a) Registration Information: When you create an account or register for the Service, we collect your name, email address, phone number, mailing address, date of birth, username, password, and other information as requested.

b) Purchase and Payment Information: When you purchase programs, courses, coaching services, or materials, we collect payment information such as credit card numbers, billing address, transaction history, and payment method details. Payment processing is handled by third-party payment processors who comply with PCI-DSS standards.

c) Profile Information: Information you voluntarily provide in your profile, including professional background, experience level, goals, and other biographical information.

d) Course and Program Participation: Information about your enrollment, participation, progress, completion status, performance, test results, assignments, and any communications with instructors or coaches.

e) Communications: Content of any emails, messages, comments, feedback, or other communications you send to the Academy, including customer service inquiries and support requests.

f) Survey and Feedback Information: Information you provide in response to surveys, questionnaires, or feedback requests.

g) Testimonials and Reviews: If you provide a testimonial, case study, or review, we collect the information contained therein.

h) Event Registration: If you register for webinars, events, or live sessions, we collect event-specific information you provide.

2.2 Information Collected Automatically

The Academy automatically collects certain information about your use of the Service, including:

a) Device Information: Information about the devices you use to access the Service, including device type, operating system, unique device identifiers, mobile network information, and device settings.

b) Usage Data: Information about how you interact with the Service, including pages visited, courses accessed, content viewed, time spent on pages, clicks, searches, downloads, and engagement metrics.

c) IP Address and Location Data: Your Internet Protocol (IP) address and approximate geographic location based on IP address. We may use this information to comply with legal requirements, prevent fraud, and improve service delivery.

d) Cookies and Similar Technologies: The Academy uses cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activities, preferences, and interactions with the Service.

e) Log Files: Our web servers automatically log information such as your IP address, browser type, referring/exit pages, operating system, date and time stamps, and clickstream data.

f) Analytics Data: Information collected through web analytics services (such as Google Analytics) that help us understand how users interact with the Service.

g) Performance Data: Information about the performance and functionality of the Service as experienced by you, including error reports and diagnostics.

2.3 Information from Third Parties

The Academy may receive Personal Information about you from third-party sources, including:

a) Service Providers: Third-party vendors, partners, or service providers may provide information about you in connection with services they provide to the Academy.

b) Referrals: If another user refers you to the Academy, we may collect information from that referral.

c) Social Media: If you connect your social media accounts to the Service, we may collect information from your social media profile.

d) Data Brokers and Public Sources: We may obtain information from publicly available sources or data aggregators to verify information or enhance our records.

e) Partners and Affiliates: Business partners, affiliate networks, and co-marketing partners may share information about you with the Academy.

2.4 Children's Information

The Service is not intended for individuals under 18 years of age. We do not knowingly collect Personal Information from children under 13. If we become aware that we have collected Personal Information from a child under 13, we will promptly delete such information and terminate the child's account.

3. HOW WE USE YOUR INFORMATION

3.1 Primary Uses

The Academy uses Personal Information for the following primary purposes:

a) Service Delivery: To provide, maintain, enhance, and personalize the Service, including course materials, coaching, support, and communications.

b) Account Management: To create, manage, and maintain your account, including processing enrollment, managing access credentials, and handling account-related inquiries.

c) Payment Processing: To process payments, billing, refunds, and financial transactions related to your use of the Service.

d) Communication: To send you transactional communications, such as account confirmations, course updates, service announcements, password resets, and administrative notices.

e) Customer Support: To respond to your inquiries, provide technical support, troubleshoot issues, and resolve disputes.

f) Personalization: To customize the Service based on your preferences, interests, past activity, and engagement patterns to improve your user experience.

g) Marketing and Promotions: To send you promotional materials, special offers, discounts, newsletters, and other marketing communications (with your consent or as otherwise permitted).

h) Analytics and Improvement: To analyze how the Service is used, identify trends, assess effectiveness, monitor performance, and improve the Service's functionality, content, and user experience.

i) Security and Fraud Prevention: To detect, prevent, and investigate fraud, unauthorized access, security breaches, and other illegal or unauthorized activity.

j) Legal Compliance: To comply with applicable laws, regulations, legal processes, subpoenas, court orders, and government requests.

k) Rights Protection: To protect the Academy's legal rights, property, and safety, as well as the rights, property, and safety of users and the public.

l) Testimonials and Case Studies: To use your information in testimonials, case studies, success stories, and marketing materials (with your consent).

3.2 Secondary and Related Uses

a) Educational Research: To conduct research on educational effectiveness, student outcomes, and learning patterns (in de-identified or aggregated form).

b) Product Development: To develop new programs, courses, services, and features based on user feedback and usage patterns.

c) Business Analytics: To analyze business performance, market trends, and user demographics to inform business strategy.

d) Affiliate Programs: To administer affiliate programs, referral programs, and partnership arrangements.

e) Third-Party Service Providers: We may share your information with vendors and service providers who process it on our behalf for the purposes listed above.

4. LEGAL BASIS FOR PROCESSING (FOR EEA AND GDPR COMPLIANCE)

For individuals located in the European Economic Area (EEA) or subject to the General Data Protection Regulation (GDPR), our processing of your Personal Information is based on one or more of the following legal bases:

a) Contract: Processing is necessary to perform our contract with you or to take steps at your request prior to entering into a contract.

b) Legitimate Interests: Processing is necessary for our legitimate interests, such as improving the Service, fraud prevention, marketing, or business analytics, and such interests are not overridden by your rights.

c) Consent: You have explicitly consented to the processing of your Personal Information for a specific purpose.

d) Legal Obligation: Processing is necessary to comply with applicable law, legal process, or regulatory requirements.

e) Vital Interests: Processing is necessary to protect your vital interests or the vital interests of others.

f) Public Task: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 Cookies

The Academy uses cookies (small text files stored on your device) to enhance your experience, remember your preferences, and collect usage data. Types of cookies used include:

a) Essential Cookies: Required for the Service to function properly, including session management and security.

b) Performance Cookies: Collect information about how you use the Service to improve performance and functionality.

c) Functional Cookies: Remember your preferences and choices to personalize your experience.

d) Marketing Cookies: Track your activity across websites to display targeted advertisements.

5.2 Cookie Control

Most web browsers allow you to control cookies through browser settings. You can typically choose to:

- Accept all cookies

- Accept only certain types of cookies

- Reject cookies

- Delete cookies

Please note that rejecting or disabling cookies may affect your ability to use certain features of the Service. The Academy is not responsible for consequences resulting from your cookie preferences.

5.3 Other Tracking Technologies

The Academy uses web beacons (transparent images), pixels, and similar technologies to:

- Track user engagement

- Monitor conversion rates

- Personalize advertising

- Measure email campaign effectiveness

- Gather analytics

5.4 Do-Not-Track Signals

Some browsers include a "Do-Not-Track" feature. The Academy does not currently respond to Do-Not-Track signals as there is no industry-wide standard for their implementation.

6. INFORMATION SHARING AND DISCLOSURE

6.1 Service Providers and Vendors

The Academy shares Personal Information with third-party service providers and vendors who assist in operating the Service and conducting our business, including:

- Payment processors and financial institutions

- Cloud hosting and storage providers

- Email service providers and marketing platforms

- Analytics providers

- Customer relationship management (CRM) systems

- Communication platforms

- Technical support providers

These service providers are contractually obligated to use your information solely for the purposes of providing services to the Academy and to maintain the confidentiality and security of your information.

6.2 Business Partners and Affiliates

With your consent or as permitted by law, we may share information with business partners, affiliate networks, and co-marketing partners for joint marketing efforts, promotions, or product offerings.

6.3 Legal Requirements and Law Enforcement

The Academy may disclose Personal Information when required by law, legal process, court order, or government request, or when we believe in good faith that such disclosure is necessary to:

- Comply with applicable laws and regulations

- Enforce our Terms and Conditions and other agreements

- Protect the safety, rights, or property of the Academy, users, or the public

- Detect, prevent, or address fraud, security issues, or technical problems

- Respond to claims of illegal activity

6.4 Business Transactions

In the event the Academy is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction, Personal Information may be transferred as part of that transaction. We will provide notice before your Personal Information becomes subject to a different privacy policy.

6.5 De-Identified and Aggregated Information

The Academy may share de-identified, anonymized, or aggregated information that does not identify you personally with third parties for research, marketing, analytics, and other purposes without restriction or notification.

6.6 Restrictions on Sharing

The Academy does not sell, rent, or lease Personal Information to third parties for their independent marketing or commercial purposes. However, your information may be disclosed to service providers, partners, and others as described in this Privacy Policy.

6.7 Your Consent

By using the Service, you consent to the sharing of your Personal Information as described in this Privacy Policy. If you do not consent to such sharing, please do not use the Service or contact us to discuss options.

7. DATA RETENTION

7.1 Retention Periods

The Academy retains Personal Information for as long as necessary to provide the Service, fulfill the purposes for which it was collected, and comply with legal obligations. Specific retention periods vary based on the type of information and purposes:

a) Account Information: Retained for the duration of your account and for a reasonable period afterward (typically 1-2 years) to comply with legal and tax requirements.

b) Payment Information: Retained as required by payment processors and applicable financial regulations (typically 3-7 years).

c) Course and Program Information: Retained for the duration of your participation and for a reasonable period afterward for record-keeping and support purposes.

d) Communications: Retained for as long as necessary to respond and provide service, typically 1-2 years.

e) Marketing Information: Retained as long as you remain subscribed to communications or as required by law.

f) Analytics and Usage Data: Aggregated or de-identified data may be retained indefinitely; identifiable usage data is typically retained for 1-2 years.

7.2 Deletion Requests

You may request deletion of your Personal Information by contacting the Academy. We will comply with deletion requests subject to legal and contractual obligations to retain certain information.

7.3 Account Closure

Upon closure of your account, we will delete your Personal Information as described above, except where retention is required by law or for legitimate business purposes.

8. SECURITY AND DATA PROTECTION

8.1 Security Measures

The Academy implements comprehensive technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, disclosure, alteration, and destruction, including:

a) Encryption: Sensitive information, including payment data, is encrypted in transit using SSL/TLS protocols and at rest using industry-standard encryption methods.

b) Access Controls: Access to Personal Information is restricted to authorized personnel with legitimate need-to-know basis.

c) Authentication: Multi-factor authentication and strong password requirements are implemented.

d) Firewalls and Intrusion Detection: Firewalls, intrusion detection systems, and monitoring tools protect the Academy's systems.

e) Regular Security Audits: Regular security assessments, vulnerability scans, and penetration testing are conducted.

f) Employee Training: Academy employees receive regular training on data protection, privacy practices, and security protocols.

g) Incident Response: The Academy maintains procedures to detect, respond to, and mitigate security incidents.

h) Third-Party Security: Third-party service providers are required to maintain appropriate security measures.

8.2 Limitations of Security

While the Academy implements comprehensive security measures, no method of transmission over the Internet or electronic storage is 100% secure. The Academy cannot guarantee absolute security of your Personal Information. You acknowledge that your use of the Service involves inherent security risks, and the Academy is not liable for unauthorized disclosure or breaches resulting from factors beyond its reasonable control.

8.3 Breach Notification

In the event of a data breach involving Personal Information, the Academy will notify affected individuals as required by applicable law. Notification will be provided promptly and will include information about the nature of the breach and steps individuals should take to protect themselves.

9. YOUR PRIVACY RIGHTS AND CHOICES

9.1 Access and Portability

You have the right to request access to Personal Information the Academy holds about you and to receive a copy in a portable format. To exercise this right, contact the Academy with your request.

9.2 Correction and Updates

You have the right to request correction or update of inaccurate or incomplete Personal Information. You can update certain information through your account settings, or contact the Academy for assistance.

9.3 Deletion and Erasure

You have the right to request deletion of your Personal Information, subject to limitations for legal compliance, contractual obligations, and legitimate business purposes. Contact the Academy to submit a deletion request.

9.4 Opt-Out of Marketing Communications

You may opt out of receiving promotional or marketing communications by:

- Clicking the "Unsubscribe" link in any promotional email

- Adjusting your communication preferences in your account settings

- Contacting the Academy directly

9.5 Cookie and Tracking Opt-Out

You can control cookies and tracking through your browser settings, opt-out tools, and do-not-track mechanisms. Some third-party services offer opt-out options on their websites.

9.6 Withdrawal of Consent

If you provided consent for processing your Personal Information, you may withdraw such consent at any time by contacting the Academy. Withdrawal of consent will not affect the lawfulness of processing prior to withdrawal.

9.7 Restrictions on Processing

In certain circumstances, you may request that the Academy restrict processing of your Personal Information while we verify accuracy or consider your objection.

9.8 Objection to Processing

You may object to processing of your Personal Information on legitimate interest grounds.

9.9 California Consumer Privacy Act (CCPA) Rights

If you are a California resident, you have specific rights under the CCPA, including:

- Right to know what Personal Information is collected and how it is used

- Right to access your Personal Information

- Right to delete your Personal Information (subject to exceptions)

- Right to opt-out of the sale of your Personal Information

- Right to non-discrimination for exercising CCPA rights

To exercise CCPA rights, submit a verifiable consumer request to the Academy via the contact information below.

9.10 GDPR Rights (EEA Residents)

If you are an EEA resident, you have rights under the GDPR, including access, rectification, erasure, data portability, and complaint rights. To exercise GDPR rights, contact the Academy.

10. THIRD-PARTY LINKS AND SERVICES

10.1 External Links

The Service may contain links to third-party websites, applications, and services not operated by the Academy. The Academy is not responsible for the privacy practices, content, or security of third-party services.

10.2 Third-Party Policies

Your use of third-party websites and services is subject to their terms, conditions, and privacy policies. The Academy strongly recommends reviewing third-party privacy policies before providing Personal Information.

10.3 Social Media Integration

If you connect your social media accounts to the Academy's Service, we may collect information from your profile in accordance with the social media platform's authorization and the permissions you grant.

10.4 No Endorsement

The Academy's inclusion of third-party links does not imply endorsement or recommendation of such third parties or their services.

11. INTERNATIONAL DATA TRANSFERS

11.1 Data Transfer Basis

Personal Information collected by the Academy is stored and processed in the United States. If you are located outside the United States, your information will be transferred to, stored in, and processed in the United States.

11.2 Transfer Mechanisms

For EEA residents, data transfers are conducted in compliance with GDPR requirements, using mechanisms such as:

- Standard Contractual Clauses (SCCs)

- Binding Corporate Rules (where applicable)

- Adequacy Decisions

11.3 Consent to Transfer

By using the Service, you consent to the transfer of your Personal Information to the United States and to processing in accordance with this Privacy Policy and applicable laws.

12. CHILDREN'S PRIVACY

12.1 Age Requirements

The Service is intended for users 18 years of age and older. The Academy does not knowingly collect Personal Information from children under 18.

12.2 Parental Consent

If a child under 18 uses the Service without parental consent or permission, the parent or guardian should contact the Academy immediately to request removal of the child's information.

12.3 COPPA Compliance

Although not required to comply with the Children's Online Privacy Protection Act (COPPA) as the Service is intended for adults, the Academy strives to protect children's privacy by not knowingly collecting information from those under 13.

13. POLICY UPDATES AND CHANGES

13.1 Changes to Privacy Policy

The Academy may update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors.

13.2 Notification of Changes

Material changes to this Privacy Policy will be communicated to users via:

- Email notification

- Prominent notice on the Service

- Updated "Last Updated" date on this page

13.3 Continued Use

Your continued use of the Service following notification of changes constitutes your acceptance of the revised Privacy Policy. If you do not agree to changes, you may discontinue use of the Service.

13.4 Effective Date

This Privacy Policy is effective as of the "Last Updated" date shown at the top of this document.

14. CALIFORNIA PRIVACY RIGHTS

14.1 California Residents

California residents have specific rights under California law, including the California Consumer Privacy Act (CCPA) and the California Online Privacy Protection Act (CALOPA).

14.2 Information Disclosure

Under California law, you may request information about the categories of Personal Information we collect, the purposes for collection, and the sources of information. To make this request, contact us at the information provided below.

14.3 Direct Marketing Opt-Out

California residents may opt out of direct marketing by contacting the Academy. We will honor opt-out requests within 30 days.

14.4 Do-Not-Track Disclosure

California law requires disclosure that the Academy does not currently respond to Do-Not-Track signals in web browsers.

15. EUROPEAN PRIVACY RIGHTS

15.1 GDPR Compliance

The Academy complies with the General Data Protection Regulation (GDPR) as it applies to EEA residents' Personal Information.

15.2 Data Controller

For GDPR purposes, StratLend Wealth Academy LP is the data controller of your Personal Information.

15.3 Legal Basis and Rights

As described in Section 4, we process your information based on specific legal bases. You have the rights described in Section 9 and this section.

15.4 Data Protection Authority

If you believe your rights have been violated, you have the right to lodge a complaint with your national data protection authority.

16. CONTACT INFORMATION

16.1 Privacy Inquiries

For questions about this Privacy Policy, privacy practices, or to exercise privacy rights, please contact:

StratLend Wealth Academy LP

14784 Winnwood Rd

Dallas, TX 75254

General Partner: Colter Doty

16.2 Data Protection Officer

If required by applicable law, contact information for the Data Protection Officer is available upon request.

16.3 Response Time

The Academy will respond to privacy inquiries and requests within 30 days or as otherwise required by applicable law.

17. COMPLAINT PROCEDURES

17.1 Informal Resolution

If you have concerns about our privacy practices, we encourage you to contact the Academy first to discuss and resolve the matter informally.

17.2 Formal Complaints

You have the right to file a formal complaint with applicable regulatory authorities, including your national data protection authority (for EEA residents) or the relevant state attorney general (for U.S. residents).

ACKNOWLEDGMENT

By accessing and using stratlend-demo.com and the Academy's services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with our privacy practices, please do not use the Service.

Your privacy is important to us. We remain committed to transparent, fair, and lawful data practices and welcome your feedback and inquiries.

Last Updated: October 2025

Effective Date: October 21, 2025