PRIVACY POLICY

1. Privacy Commitment

RALSTON respects the privacy of its Members and users of the Site and Services. This Privacy Policy describes the categories of personal information RALSTON collects, the purposes for which RALSTON uses that information, how RALSTON protects and retains that information, the circumstances under which RALSTON may disclose personal information, and the rights and choices that may be available to you under applicable privacy laws.

RALSTON’s privacy practices are as follows:

(a) RALSTON collects only the personal information reasonably necessary to provide, administer, secure, market, and improve the Site and Services;

(b) RALSTON does not sell personal information for monetary consideration;

(c) RALSTON may use cookies, pixels, tags, analytics tools, advertising technologies, and similar technologies, including Meta Pixel, to measure advertising performance, understand how users interact with the Site and Services, create advertising audiences, deliver interest-based or targeted advertising, and retarget users who have visited certain pages or interacted with RALSTON’s content, subject to applicable law and available opt-out rights;

(d) RALSTON may disclose limited personal information, identifiers, internet or electronic network activity information, and similar information to advertising, analytics, and technology partners, including Meta, for advertising measurement, audience creation, targeted advertising, cross-context behavioral advertising, retargeting, analytics, and related marketing purposes;

(e) RALSTON does not knowingly sell or share personal information of individuals under sixteen (16) years of age;

(f) RALSTON does not disclose personal information to third parties for their independent marketing or commercial purposes, except as described in this Privacy Policy or as otherwise permitted by applicable law;

(g) RALSTON uses personal information for marketing where RALSTON has a prior business relationship with the recipient, where the recipient has requested or consented to receive communications, where RALSTON uses advertising or retargeting technologies as described in this Privacy Policy, or where otherwise permitted by applicable law;

(h) RALSTON discloses personal information only as necessary to provide, administer, secure, market, analyze, and improve the Site and Services, to service providers, processors, contractors, advertising partners, analytics providers, or other third parties acting on RALSTON’s behalf or as otherwise described in this Privacy Policy, to protect legal rights and security, or as required by law; and

(i) RALSTON honors applicable privacy rights, including opt-out rights for sale, sharing, targeted advertising, or cross-context behavioral advertising, as required by applicable law.

For purposes of this Privacy Policy, “personal information” or “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identified or identifiable individual or household, as defined under applicable law.

2. Age Requirement; No Children’s Data

The Site and Services are intended only for individuals eighteen (18) years of age or older. Individuals under eighteen (18) years of age are not permitted to access or use the Site or Services or submit personal information to RALSTON.

RALSTON does not knowingly collect, use, sell, share, or disclose personal information from individuals under eighteen (18) years of age. If RALSTON learns that it has collected personal information from an individual under eighteen (18) years of age, RALSTON will delete that information unless retention is required or permitted by law.

By using the Site or Services, you represent that you are at least eighteen (18) years of age.

3. Scope of this Privacy Policy

This Privacy Policy applies to personal information RALSTON collects through or in connection with (a) the Site; (b) the Services; (c) subscription, enrollment, registration, and account processes; (d) RALSTON’s community platform, resources, live streams, calls, sessions, events, and related offerings; (e) payment, billing, renewal, cancellation, and refund processes; (f) communications with RALSTON, including email, support, administrative, billing, and membership communications; and (g) RALSTON’s limited marketing communications to persons with whom RALSTON has a prior business relationship or as otherwise permitted by law.

This Privacy Policy does not apply to websites, platforms, applications, or services owned or controlled by third parties. If you access a third-party website, platform, payment portal, community platform, video service, scheduling tool, or other third-party service through the Site or Services, that third party’s privacy policy and terms may apply to its processing of your information.

4. Categories of Personal Information RALSTON Collects

Depending on how you interact with RALSTON, the Site, and the Services, RALSTON may collect the following categories of personal information:

(a) Identifiers, such as your first and last name, business name, mailing address, billing address, email address, telephone number, username, account identifier, IP address, and similar contact or account identifiers.

(b) Customer records and account information, such as subscription records, membership tier, account status, billing status, payment method status, renewal status, cancellation status, refund history, and records of your interactions with RALSTON.

(c) Commercial information, such as Services purchased, subscribed to, considered, accessed, renewed, canceled, or refunded.

(d) Payment-related information, such as billing details, transaction information, payment status, and limited payment method information. RALSTON does not intend to store full credit card numbers, debit card numbers, bank account numbers, or payment security codes on its own systems. Payment information may be processed by third-party payment processors acting on RALSTON’s behalf.

(e) Internet, device, and electronic network activity information, such as IP address, device type, browser type, operating system, referring URL, pages viewed, access times, session activity, login activity, and similar technical information reasonably necessary to operate, secure, administer, and improve the Site and Services.

(f) Communications and user-submitted content, such as questions, comments, posts, messages, feedback, support requests, content submitted for review, and other information you choose to provide to RALSTON or post within the Services or community platform.

(g) Audio, video, or similar information, if you participate in recorded calls, sessions, live streams, events, or other recorded portions of the Services.

(h) Professional or business-related information, such as your business name, role, industry, professional interests, or business-related information you voluntarily provide in connection with the Services.

(i) Inferences or preferences, such as information reasonably derived from your interactions with the Site or Services to understand account needs, service usage, or member preferences, but only for RALSTON’s internal service administration and improvement purposes.

(j) Sensitive personal information, only if voluntarily provided by you or reasonably necessary to provide the Services, process payments, maintain account security, or comply with law. RALSTON does not request sensitive personal information unless necessary for a specific Service-related purpose and does not use sensitive personal information to infer characteristics about you.

RALSTON will not collect categories of personal information that are not reasonably necessary or proportionate to provide, administer, secure, improve, or market the Site and Services consistent with this Privacy Policy.

5. Categories of Sources

RALSTON may collect personal information from the following sources:

(a) Directly from you, including when you register, enroll, purchase, subscribe, log in, post content, submit questions, contact support, request information, cancel, renew, request a refund, or otherwise communicate with RALSTON.

(b) Automatically from your use of the Site and Services, including through server logs, cookies, security tools, analytics tools, and similar technologies used for Site operation, security, fraud prevention, account administration, and internal performance measurement.

(c) From service providers or processors acting on RALSTON’s behalf, including payment processors, community platform providers, hosting providers, email service providers, customer support tools, scheduling tools, video or live-stream platforms, and security providers.

(d) From your organization or authorized representatives, if your account, subscription, payment, or access is arranged through a business or other entity.

(e) From publicly available or lawfully obtained sources, but only where reasonably necessary for account administration, security, fraud prevention, legal compliance, or protection of RALSTON’s rights.

6. Purposes for Collection and Use

RALSTON collects and uses personal information only for the following purposes: (a) to provide, operate, administer, maintain, and improve the Site and Services; (b) to create, manage, authenticate, and secure accounts and memberships; (c) to process enrollments, subscriptions, payments, renewals, installments, cancellations, refunds, and billing matters; (d) to provide access to community platforms, resources, calls, live streams, sessions, recordings, downloads, and other Service features; (e) to communicate with you regarding your account, membership, subscription, access, billing, renewals, cancellations, support requests, policy updates, or administrative matters; (f) to provide customer service, technical support, account assistance, and responses to inquiries; (g) to maintain the safety, security, and integrity of the Site, Services, accounts, Content, community platform, and RALSTON’s systems; (h) to detect, prevent, investigate, or respond to fraud, unauthorized access, misuse of credentials, intellectual property violations, prohibited conduct, security incidents, payment issues, or violations of RALSTON’s Terms of Service; (i) to enforce RALSTON’s Terms of Service, payment rights, intellectual property rights, community rules, and legal rights; (j) to maintain business, accounting, tax, legal, and operational records; (k) to comply with applicable law, regulation, legal process, subpoena, court order, governmental request, tax obligation, accounting requirement, or other legal obligation; (l) to evaluate, maintain, and improve the performance, functionality, reliability, and quality of the Site and Services; (m) to send marketing, promotional, educational, or informational communications only to individuals with whom RALSTON has a prior business relationship, to Members, former Members, account holders, subscribers, or others who have requested or consented to receive such communications, and subject to any applicable opt-out rights; and (n) for any other purpose disclosed to you at or before the time of collection, provided that the purpose is compatible with the context in which the personal information was collected or is otherwise permitted by applicable law.

RALSTON will not use personal information for materially different, unrelated, or incompatible purposes without providing notice and obtaining consent where required by law.

7. No Sharing for Targeted Advertising, and No Third-Party Marketing Disclosure

RALSTON shares personal information for cross-context behavioral advertising or targeted advertising as set forth in Section 6.9 of this Privacy Policy; RALSTON may use and disclose limited personal information through cookies, pixels, tags, advertising technologies, analytics tools, and similar technologies, including the Meta Pixel, for advertising measurement, audience creation, targeted advertising, cross-context behavioral advertising, retargeting, attribution, analytics, and related marketing purposes. Depending on applicable law, these activities may constitute “sharing” of personal information, “targeted advertising,” or “cross-context behavioral advertising.”

RALSTON does not disclose personal information to third parties for their independent marketing, advertising, data-broker, profiling, or commercial purposes. RALSTON does not process personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. RALSTON does not knowingly sell or share personal information of individuals under sixteen (16) years of age. RALSTON will provide and honor any legally required opt-out rights relating to sharing of personal information, targeted advertising, cross-context behavioral advertising, or similar advertising activities, including recognized opt-out preference signals where required by applicable law. If RALSTON’s practices change in the future in a manner that would constitute a sale of personal information or profiling under applicable law beyond the practices described in this Privacy Policy, RALSTON will update this Privacy Policy, provide any notices required by law, and provide any required opt-out mechanism before engaging in such activity.

8. Disclosures of Personal Information

RALSTON may disclose personal information only in the following limited circumstances:

(a) Service providers and processors. RALSTON may disclose personal information to service providers, contractors, or processors acting on RALSTON’s behalf and only to the extent reasonably necessary for them to provide services to RALSTON, such as payment processing, website hosting, community platform operation, email delivery, customer support, scheduling, video or live-stream hosting, security, data storage, analytics for internal service improvement, and similar operational support.

(b) Legal compliance. RALSTON may disclose personal information if required to do so by law, regulation, legal process, subpoena, court order, governmental request, or similar legal obligation.

(c) Protection of rights, safety, and security. RALSTON may disclose personal information where RALSTON reasonably believes disclosure is necessary to protect the rights, property, safety, or security of RALSTON, Members, users, service providers, or others; to prevent fraud or misuse; to investigate security incidents; or to enforce RALSTON’s Terms of Service or legal rights.

(d) Professional advisors. RALSTON may disclose personal information to attorneys, accountants, auditors, insurers, and other professional advisors, but only as reasonably necessary for legal, accounting, audit, insurance, risk-management, or compliance purposes.

(e) Business transactions. If RALSTON is involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, personal information may be disclosed solely as reasonably necessary for that transaction and subject to appropriate confidentiality and use restrictions.

(f) With your direction or consent. RALSTON may disclose personal information where you direct RALSTON to do so or where you provide consent.

RALSTON discloses personal information to service providers, contractors, and processors only for limited and specified purposes related to the services they provide to RALSTON. Each such service provider, contractor, or processor is independently responsible for complying with all applicable privacy, data protection, and security laws governing its processing of personal information, including maintaining appropriate safeguards and refraining from selling, sharing, retaining, using, or disclosing personal information except as necessary to provide services to RALSTON or as otherwise permitted by applicable law.

9. Cookies and Similar Technologies

RALSTON may use cookies, pixels, tags, log files, analytics tools, advertising technologies, and similar technologies on the Site and in connection with the Services.

These technologies may be used for the following purposes:

(a) operating and maintaining the Site and Services;

(b) enabling logins, sessions, account access, and security features;

(c) remembering preferences;

(d) detecting and preventing fraud, misuse, credential sharing, unauthorized access, and security incidents;

(e) measuring internal Site and Service performance;

(f) understanding usage trends, traffic sources, page views, conversions, and interactions with the Site and Services;

(g) improving the functionality, reliability, quality, and effectiveness of the Site and Services;

(h) measuring the performance and effectiveness of RALSTON’s marketing and advertising campaigns;

(i) creating, customizing, and improving advertising audiences;

(j) delivering interest-based, targeted, or personalized advertising;

(k) retargeting or remarketing to individuals who have visited certain pages of the Site, interacted with RALSTON’s content, submitted forms, engaged with RALSTON’s social media accounts, or otherwise interacted with RALSTON online; and

(l) matching website activity with advertising platforms, including Meta platforms, for advertising measurement, attribution, audience creation, retargeting, and related marketing purposes.

RALSTON may use the Meta Pixel and similar technologies provided by Meta Platforms, Inc. or its affiliates. These technologies may allow RALSTON and Meta to collect or receive information from the Site and elsewhere on the internet, including identifiers, device information, browser information, IP address, pages visited, actions taken on the Site, referring URLs, and other internet or electronic network activity information. RALSTON and Meta may use this information to provide measurement services, deliver ads, measure ad performance, create or refine advertising audiences, and retarget users with RALSTON advertising on Meta platforms and other online locations.

Depending on your jurisdiction, RALSTON’s use of advertising pixels, cookies, and similar technologies may constitute “sharing” of personal information, “targeted advertising,” or “cross-context behavioral advertising” under applicable privacy laws. RALSTON will honor applicable opt-out rights as required by law.

You may be able to limit or opt out of certain cookies, pixels, targeted advertising, or cross-context behavioral advertising through browser settings, cookie preference tools made available on the Site, platform-level settings, device settings, industry opt-out tools, or privacy rights requests submitted to RALSTON as described in this Privacy Policy. Some features of the Site or Services may not function properly if cookies or similar technologies are disabled.

RALSTON does not knowingly use cookies, pixels, or similar technologies to sell or share personal information of individuals under sixteen (16) years of age.

10. Email and Direct Marketing Communications

This Section 6.10 governs email and direct marketing communications from RALSTON. RALSTON may use your personal information to send marketing, promotional, educational, or informational emails only if you are a current Member, former Member, subscriber, account holder, purchaser, or other person with whom RALSTON has a prior business relationship, or if you have requested or consented to receive such communications.

You may opt out of marketing or promotional emails at any time by using the “unsubscribe” link included in the email or by contacting RALSTON at the email address listed in this Privacy Policy. This email opt-out applies to marketing or promotional emails and direct marketing communications addressed in this Section 6.10.

Targeted advertising, cookies, pixels, tags, Meta Pixel, retargeting, cross-context behavioral advertising, advertising measurement, audience creation, and related privacy choices are addressed separately in Sections 6.7, 6.9, and 6.14 of this Privacy Policy. Opting out of marketing or promotional emails does not automatically opt you out of cookies, pixels, targeted advertising, cross-context behavioral advertising, retargeting, platform-level advertising, or similar advertising technology uses. Those choices may be exercised through privacy preference tools, cookie preference tools, opt-out mechanisms made available by RALSTON, platform-level settings, device settings, recognized opt-out preference signals where required by applicable law, privacy rights requests, or other methods described in this Privacy Policy.

Even if you opt out of marketing communications, RALSTON may still send transactional, administrative, legal, security, billing, renewal, cancellation, account, and Service-related communications.

11. Retention of Personal Information

RALSTON retains personal information only for as long as reasonably necessary and proportionate to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

The criteria RALSTON uses to determine retention periods include: (a) the length of your membership, subscription, account, or relationship with RALSTON; (b) the nature and sensitivity of the personal information; (c) the purposes for which the information was collected and used; (d) the need to provide, administer, secure, improve, or document the Site and Services; (e) legal, tax, accounting, audit, recordkeeping, and compliance obligations; (f) the need to resolve disputes, enforce agreements, collect amounts owed, process refunds or chargebacks, or defend legal claims; (g) security, fraud prevention, credential misuse, and platform integrity needs; and (h) whether retention is reasonably necessary for a lawful business purpose compatible with the context in which the information was collected.

RALSTON will not retain personal information for longer than reasonably necessary for the disclosed purposes unless retention is required or permitted by law.

12. De-Identified and Aggregated Information

RALSTON may create and use de-identified or aggregated information for internal business purposes, including to understand Service performance, usage trends, member engagement, and operational effectiveness.

RALSTON will not attempt to re-identify information that has been de-identified, except as permitted by law to test whether de-identification processes are effective. RALSTON will maintain and use de-identified information in de-identified form and will require any recipient of de-identified information to do the same.

13. Sensitive Personal Information

RALSTON does not request sensitive personal information unless it is reasonably necessary to provide the Services, process payments, maintain security, comply with law, or respond to a specific request from you. RALSTON does not use sensitive personal information to infer characteristics about you. RALSTON does not sell sensitive personal information. RALSTON does not disclose sensitive personal information for targeted advertising, cross-context behavioral advertising, profiling, or third-party marketing. RALSTON uses sensitive personal information, if any, only for purposes reasonably necessary to provide and maintain the Site and Services, protect security and integrity, process payments, comply with law, or as otherwise permitted by applicable law.

14. Privacy Rights and Choices

Depending on your state of residence and subject to applicable law, you may have some or all of the following rights:

(a) Right to Access / Know. You may request confirmation of whether RALSTON processes personal information about you and may request access to that information.

(b) Right to Data Portability. You may request a copy of certain personal information in a portable and, to the extent technically feasible, readily usable format.

(c) Right to Correction. You may request that RALSTON correct inaccurate personal information maintained about you.

(d) Right to Deletion. You may request that RALSTON delete personal information collected from or about you, subject to exceptions permitted by law.

(e) Right to Opt Out of Sale. You may opt out of the sale of personal information. RALSTON does not sell personal information.

(f) Right to Opt Out of Sharing / Targeted Advertising. Where applicable law provides such rights, you may have the right to opt out of the sale of personal information, the sharing of personal information, targeted advertising, or cross-context behavioral advertising. RALSTON may use cookies, pixels, tags, advertising technologies, analytics tools, and similar technologies, including the Meta Pixel, for advertising measurement, audience creation, targeted advertising, cross-context behavioral advertising, retargeting, and related marketing purposes, and depending on applicable law, these activities may constitute “sharing” of personal information, “targeted advertising,” or “cross-context behavioral advertising.” You may exercise any applicable opt-out rights by using any privacy preference, cookie preference, or mechanism made available by RALSTON, by contacting RALSTON as described in this Privacy Policy, or by using any other method required by applicable law, and RALSTON will honor recognized opt-out preference signals, where required by applicable law. Opting out of sharing, targeted advertising, or cross-context behavioral advertising does not mean you will stop seeing advertisements; it means that, where applicable, RALSTON will not use or disclose your personal information for targeted advertising or cross-context behavioral advertising after your opt-out has been processed, except as permitted by applicable law, and you may still receive contextual advertising, general advertising, transactional communications, administrative communications, or marketing communications where permitted by law and consistent with your communication preferences.

(g) Right to Opt Out of Profiling. You may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects where applicable. RALSTON does not process personal information for such profiling.

(h) Right to Limit Use or Disclosure of Sensitive Personal Information. You may request that RALSTON limit the use or disclosure of sensitive personal information where applicable. RALSTON uses sensitive personal information only for limited purposes permitted by law and does not use sensitive personal information to infer characteristics about you.

(i) Right to Non-Discrimination / Non-Retaliation. RALSTON will not discriminate or retaliate against you for exercising privacy rights.

(j) Right to Appeal. If applicable law provides an appeal right and RALSTON denies your privacy request, you may appeal the decision using the instructions provided in RALSTON’s response.

(k) Right to Use an Authorized Agent. Where permitted by law, you may authorize another person to submit a privacy request on your behalf, subject to verification and proof of authority.

15. How to Exercise Privacy Rights

To exercise privacy rights, contact RALSTON at:

Email: [email protected]

Alternative Email: [email protected]

Please include sufficient information for RALSTON to understand, evaluate, and respond to your request. RALSTON may request additional information reasonably necessary to verify your identity, authenticate your request, confirm your authority to act on behalf of another person, or locate responsive information. If you maintain an account with RALSTON, RALSTON may require you to submit or verify certain requests through your account. RALSTON will not require you to create a new account solely to submit a privacy request. RALSTON will respond to privacy requests within the time required by applicable law. If RALSTON needs additional time, RALSTON will notify you as required by law. RALSTON may deny a request, in whole or in part, where permitted by law, including where RALSTON cannot verify the request, the request conflicts with legal obligations, the information is exempt from deletion or disclosure, compliance would be impossible or involve disproportionate effort, or an exception under applicable law applies.

16. Appeals

If RALSTON denies your privacy request and applicable law gives you the right to appeal, you may submit an appeal by emailing RALSTON at [email protected] with the subject line “Privacy Appeal.” RALSTON will review the appeal and respond within the time required by applicable law. If the appeal is denied, RALSTON will provide any information required by applicable law regarding how you may contact the appropriate state attorney general or privacy regulator.

17. Verification of Requests

RALSTON may verify your identity before responding to a privacy request. Verification may include matching information you provide with information RALSTON maintains, confirming control of the email address associated with your account, requiring you to log into your account, or using other commercially reasonable verification methods. Personal information collected for verification purposes will be used only to verify and respond to the request and will not be used for unrelated purposes.

18. Authorized Agents

If you submit a request through an authorized agent, RALSTON may require proof that you authorized the agent to act on your behalf and may require you to verify your identity directly with RALSTON, unless prohibited by applicable law. RALSTON may deny a request from an authorized agent if RALSTON cannot verify the agent’s authority or your identity as permitted by law.

19. Security

RALSTON uses reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized or illegal access, destruction, use, modification, or disclosure. No website, platform, transmission, storage system, or security measure is completely secure. RALSTON cannot guarantee absolute security, but RALSTON will maintain safeguards appropriate to the nature of the personal information it processes. You are responsible for maintaining the confidentiality of your username, password, account credentials, and access links. You must promptly notify RALSTON if you believe your account, credentials, or access to the Services has been compromised.

20. Payment Information

Payment information may be collected and processed by RALSTON’s third-party payment processor. RALSTON does not intend to store full credit card numbers, debit card numbers, bank account numbers, or payment security codes on its own systems. Payment processors may process payment information according to their own privacy policies and legal obligations. RALSTON uses payment-related information to process transactions, subscriptions, renewals, installments, refunds, chargebacks, billing issues, tax records, accounting records, and related administrative matters.

21. Legal and Contractual Necessity

Certain personal information is necessary for RALSTON to provide the Site and Services, administer accounts, process payments, maintain security, comply with law, and perform its agreements with Members. If you decline to provide information that is necessary for those purposes, RALSTON may be unable to provide some or all of the Site or Services, process your subscription, maintain your account, respond to your requests, or complete transactions.

22. Changes to this Privacy Policy

RALSTON may revise, amend, or update this Privacy Policy from time to time. If RALSTON makes material changes to this Privacy Policy, RALSTON will provide notice as required by applicable law, which may include notice by email, notice through the Site, notice through the Services, or other legally sufficient means. The updated Privacy Policy will identify its effective date. Your continued use of the Site or Services after the effective date of the updated Privacy Policy constitutes acknowledgment of the updated Privacy Policy, except where applicable law requires a different form of notice or consent. RALSTON will not use personal information for materially different, unrelated, or incompatible purposes without providing notice and obtaining consent where required by applicable law.

23. Contact Information

If you have questions about this Privacy Policy or wish to exercise privacy rights, contact RALSTON at:

RALSTON

Email: [email protected]

Alternative Email: [email protected]