Global Privacy Statement for Peak Digital Marketing Solutions

This Worldwide Privacy Statement ("Global Statement") explains how Peak Digital Marketing Solutions, along with its affiliated organizations and subsidiaries (referred to as "Peak Digital Marketing Solutions," "our," "us," or "we"), handles personal data relating to individuals ("consumer," "you," or "your"). This includes details about the types of personal information we gather, our reasons for collecting it, whether we intend to sell or share such information, how long we plan to keep it, what privacy rights you have regarding your personal data, and the process for exercising those rights.

This Global Notice covers personal data gathered directly by us and via our network of affiliated organizations, subsidiaries, marketing operations, data handlers, third-party vendors, and throughout our corporate platforms, employment portal, promotional activities & giveaways, digital communications (encompassing emails, instant messaging, phone and video interactions, and SMS), gatherings, podcasts, e-commerce solutions, social networking platforms, online seminars, web properties and additional offerings (individually referred to as a "service," collectively as the "services").

1. Understanding Personal Information Personal Information refers to any details that can be used to identify you as an individual. This includes obvious identifiers like your name, address, or date of birth, as well as less direct information such as your location data, online identifiers, or specific physical, economic, cultural, or social characteristics. It encompasses both digital and non-digital data that, whether alone or combined with other information, can link back to you as a unique person. This definition extends to any information that makes you distinguishable from others or could be used to determine your identity, either directly or indirectly.

The phrases "personal information" and "personal data" (as legally defined under relevant data protection legislation) refer to any details that can identify a specific individual, or information that can be connected or potentially connected to an identifiable living person. The term "living person" specifically denotes a human being who is alive.

Individual data excludes information that is openly accessible to the public or has been "combined" or "pseudonymized" (and its corresponding term "anonymized" as specified in relevant privacy legislation). Combined and pseudonymized information is considered non-personal data. This indicates that we have eliminated any identifying details (such as names, email addresses, mailing addresses, and phone numbers), and the remaining information cannot be reasonably employed to determine your identity or connect you to the data in reference.

2. Information Gathering and Usage We gather information when you utilize our services. This includes personal details you provide directly, data collected automatically through your interaction with our platform, and information from third-party sources. We use the collected information to: - Deliver and enhance our services - Process your transactions - Communicate with you about our products and updates - Analyze user behavior and improve user experience - Detect and prevent fraudulent activities - Comply with legal requirements and regulations - Personalize content and recommendations - Manage your account and preferences - Resolve technical issues and provide support - Send relevant marketing communications (with your consent) The specific ways we use your information depend on which services you use and how you interact with our platform.

We gather only the essential personal data needed to fulfill our intended objectives, ensuring its relevance and adequacy. We employ privacy-enhancing technologies to minimize data collection, including techniques such as key coding, pseudonymization, de-identification, anonymization, and aggregated data management practices whenever practicable.

Lawful Grounds for Data Processing To process personal data, we require at least one of these legitimate bases: • Your explicit consent • Fulfillment of contractual obligations • Compliance with legal requirements • Protection of vital interests • Performance of tasks in the public interest • Pursuit of our legitimate business interests, provided they don't override your fundamental rights When processing relies on consent, you have the right to withdraw it at any time. However, this won't affect the lawfulness of processing carried out before withdrawal. For sensitive personal data, we need both a lawful basis from the above list and meet additional conditions under data protection laws. We regularly review our processing activities to ensure they rest on appropriate legal grounds and document our decisions.

We rely on the following lawful grounds when gathering and processing personal data:

• With Your Consent to collect and use your personal information for one or more purposes.
• In Performance of a Contract between you and Peak Digital Marketing Solutions, or for the implementation of pre-contractual measures taken at your request.
• To Comply with Legal Obligations , including: (i) to comply with applicable laws, rules, and regulations; (ii) to respond to and comply with court orders, subpoenas, and warrants, and criminal, civil, or regulatory investigations; (iii) to cooperate with government bodies and law enforcement requests; and (iv) to enforce our legal interests, such as by supporting the exercise, preparation, or defense of any legal claims.
• To Protect the Vital interests of an Individual , including where there are reasonable grounds to believe that our failure to act (by not disclosing certain personal information) could result in risk of death or serious bodily harm to you or others.
• In Pursuit of Legitimate Interests , including to conduct business activities related to the products and services that we provide to you and others, and to operate our business.

Types of Individuals

We gather personal data relating to the following groups of individuals:

• Patrons, Consumers, and Subscribers of our VIP influencer promotion solutions
• Minors, Their Parents and Those with Legal Custody (in cases where our services require parental authorization)
• Authors and Content Creators (for our digital platform and various publications)
• External Partners, Temporary Staff, and Student Workers
• Data Receivers (for parties who obtain personal details from our organization)
• Entertainers, Creatives, and Stage Professionals (stars and recording artists who work with us)
• Dealers, Merchants, and Business Associates (for users of our services)
• Staff Members, Past Personnel, and Eligible Dependents
• Employment Candidates
• Vendors, Contractors, and External Business Associates (for personnel supporting our operations)
• Event Presenters and Company Representatives (speaking at our live sessions and online gatherings)
• Guests and Attendees (at our venues and facilities)
• Online Users (accessing our digital platforms and internet-based services)

Information Sources

We gather personal data from these source categories:

• Information we collect directly from you depending on which services you request from us, how you engage with our services, and what specific personal information we need from you to provide these services.
• Information your organization provides to us that is necessary for you to use our services under a contractual agreement we have with your organization.
• Information we collect automatically depending on which services you request from us, how you engage with our services, and how you configured your device, browser, and email client.
• Information we receive from other parties including our advertising, measurement and analytics, and social media partners, data brokers, financial institutions, government and regulatory bodies, payment processors, public records, and service providers.

Types of Individual Data

We gather and process the following types of personal data. Please note that not every category or example mentioned applies to all individuals:

Types of Individual Data	Examples	Disclosed or Transferred to External Partners
Account Details	Personal identifiers, preferred contact methods, client reference number, electronic mail contact, SMS-capable phone address, physical mailing location, phone contact details, login credentials and security passcode	Yes
Biological Identifiers	Physical traits, conduct patterns, and organic features that carry personal identifiable data	No
Safeguarded Categories	Identity characteristics, including chronological age, nationality status, physical or mental impairment, gender identification and presentation, health circumstances, armed forces service background, ethnic heritage, racial background, spiritual or religious beliefs, and romantic or sexual preferences	No
Children's Information	Full name, date of birth - service access granted with parent/guardian approval	No
Business Data	Documentation of asset possession, consumer inclinations, acquired goods and services, transaction records, customer reviews, and desired item compilations	Yes
Contact Details	Personal information, preferred methods of communication, electronic mail contact, mobile phone messaging details, mailing location, and phone contact information - applicable to individuals without accounts	Yes
Qualifications and Experience	Login credentials and security tokens, employee username and passphrase, password recovery prompts and verification questions - for company staff members	No
Population Statistics	Demographics, date of birth, cultural background, sex, family earnings, relationship status, size of family, profession, primary language, racial or ethnic identity	No
Equipment Information	Hardware identifiers, equipment category, display dimensions, operational metrics, and network interface identifiers - for all devices connected to our platform	Yes
Digital Messaging and Telecommunications	Communication records including scheduling, email correspondence, instant messaging, voice and video communications, and SMS exchanges that occur during our interactions with you	No
Monetary Details	Credit card details and bank transfer data - based on your chosen payment option for your orders	No
Financial Crime & Investigative Intelligence	False documentation, law enforcement filings, and misappropriated identity details acquired from third parties - related to deceptive activities, larceny, and security incidents	No
Location Intelligence Data	Information that transforms your mailing address into geographic coordinates and map points, enabling navigation assistance and nearby service discovery	No
Approximate Location Information	Geographic location data, including latitude, longitude, and cartographic coordinates, determined by either your IP address or postal code, available at national, regional, or municipal levels	Yes
Official Identification Codes	Personal identification numbers, including social security, driver's license, state ID, and passport information - utilized exclusively for employment-related matters	No
Labels and Names	Personal identifiers, pseudonyms, digital signatures, email contacts, official ID numbers, IP addresses, mobile text messaging details, web-based identification markers, physical mailing locations, and phone contact information	Yes
Data Analysis & Behavioral Patterns	Conclusions and predictions derived from individual data and algorithmic analysis to establish personal preferences and identify areas of interest	Yes
Online Pursuits	Web browsing records, navigation patterns, engagement with our promotions and platforms, IP location identifiers, webpage visits, query records, and system logs	Yes
Digital Identity Markers	Device identifiers, analytics tracking codes, browser cookies, web beacons, monitoring scripts, and network IP addresses	Yes
Job Details	Personnel ID, recipient details, qualifications & permits, salary information, job evaluations, curriculum vitae, education documentation - utilized exclusively for work-related purposes	No
Confidential Individual Data	Personal biological markers, Protected demographic categories, Information about minors, Authentication details, Official identification numbers, Access codes, and Credit/debit card digits	No
Sensory Input	Sensory data including sound recordings, imagery, temperature measurements and comparable input types (such as still pictures, moving images and voice messages)	No
Customer Comments and Reviews	Feedback through questionnaires, interactions with our social platforms, star ratings and customer testimonials	Yes
Digital Platform Updates	Social media performance indicators, including content, engagement statistics, audience size, and user interactions for our influencer marketing solutions	Yes

Reasons for Data Processing

We collect and process personal data for the following purposes:

• To manage and deliver benefits for current and former staff members, along with their eligible dependents
• To keep you informed about our services and any new developments
• To maintain compliance with applicable legislation, regulatory requirements, and established standards while protecting our lawful rights and interests
• To establish and maintain your user profile and oversee our ongoing connection with you
• To create, market and distribute influencer-driven social media solutions and digital assets
• Making the most of promotional efforts and marketing tactics
• To meet our contractual commitments
• To enhance products and elevate client satisfaction
• For the administration and maintenance of our commercial activities and valid business objectives
• To customize promotional content and special deals for our VIP influencer marketing solutions
• To identify, safeguard against, monitor for, address, and bounce back from security incidents, fraudulent activities, and thievery
• To handle and complete purchases and sales
• To deliver assistance and care to clients
• To craft and strengthen social media presence and campaigns for our high-profile entertainment clientele
• To evaluate social media analytics and campaign effectiveness for marketing initiatives
• To confirm you are who you say you are and check your age

3. Information Regarding Minors

We do not target our digital services to individuals under the age of eighteen (18), and anyone accessing our online platforms confirms that they have reached eighteen (18) years of age prior to using them.

Our online services are not intentionally used to gather personal information from individuals under the age of thirteen (13), or as otherwise defined by relevant laws, whom we classify as children. Should we discover that a child has submitted personal information through our online services without proper consent from a parent or legal guardian, we will take immediate action to remove such information from our systems.

Parent/Guardian Authorization Guidelines We must obtain written permission from a parent or legal guardian before proceeding with any activities involving minors. This authorization requirement ensures proper oversight and protection of children under our care. Valid consent forms must include: - Child's full name and date of birth - Parent/guardian's complete contact information - Detailed description of authorized activities - Emergency medical treatment authorization - Parent/guardian signature and date - Witness signature when applicable Permission slips should be renewed annually or whenever significant changes occur in programming. All consent documentation must be securely stored and readily accessible to authorized personnel. Staff members are responsible for verifying proper authorization before allowing any minor to participate. Non-compliance with these procedures may result in disciplinary action.

For children to engage in our services, as allowed by current laws, parents or legal guardians must follow these procedures:

• Collection, Processing, and Retention: We will provide notice to the parent or legal guardian and obtain their written authorization for the service and verifiable parental consent before collecting and processing personal information about their child.
• Disclosure: We will provide a separate notice to the parent or legal guardian and obtain their written authorization before disclosing personal information about their child to our service providers and third parties.
• Sale: Under no circumstances do we knowingly sell personal information about children.

4. How We Share and Handle Your Information We may need to disclose your information to third parties in certain circumstances. This includes sharing data with our trusted service providers, partners, and affiliates who help us operate our business. We may also share information when required by law, to protect our rights, or to prevent fraud and abuse. Your personal information may be transferred as part of a business merger, sale, or acquisition. In such cases, we ensure your data continues to be protected under similar terms. We only share what's necessary and maintain strict controls over data access and usage. When we collaborate with third parties, we implement appropriate safeguards to protect your information and ensure compliance with applicable privacy laws and regulations. We will notify you about significant changes to how we share your information, unless otherwise required by law.

We collaborate with various individuals and organizations to run our operations, oversee and maintain our services, and carry out other functions outlined in this Worldwide Policy.

We provide or make available personal information to the following groups of data recipients:

• Within our Corporate Group of affiliate companies and subsidiaries to provide our celebrity marketing services and support our business operations
• With our Contractors and Service Providers who perform services on our behalf including cloud service providers, social media analytics tools, marketing platforms, payment processing services, and website hosting
• With our Third-Party Providers who provide cross-context behavioral advertising services for our celebrity marketing campaigns
• Corporate Transactions: We may share or disclose personal information in connection with any sale of company assets, merger, acquisition, or corporate reorganization
• Legal, Regulatory, and Law Enforcement Bodies: We may disclose information as required to comply with applicable laws, court orders, subpoenas, and regulatory investigations

Information Storage and Maintenance We will retain your personal information for as long as needed to fulfill the purposes outlined in this policy, or as required by applicable laws and regulations. When data is no longer necessary for these purposes, we will securely delete or anonymize it, unless legal obligations require further storage. The specific retention period varies depending on the type of information, its intended use, and relevant legal requirements.

We retain your personal data for the duration needed to deliver our services, maintain our business operations, and meet our obligations under relevant laws, regulations, and guidelines.

We reduce the collection of personal data by implementing privacy-focused technologies whenever feasible and appropriate.

Common storage durations encompass:

• For customers: We typically retain your personal information for up to six (6) years after your contractual relationship with us ends or your last account transaction occurred
• For employees: We typically retain your personal information for up to six (6) years after your employment relationship with us ends
• For unsuccessful applicants: We typically retain your personal information for up to four (4) years after we have communicated our hiring decision to you

6. Safeguarding of Data

We implement appropriate, reasonable, and business-standard security protocols, including administrative, technical, and physical safeguards, to protect our services and preserve their confidentiality, integrity, and accessibility. These measures are designed to defend your personal data against unintended or illegal destruction, loss, or modification, while preventing unauthorized access, usage, or exposure.

Our safety and protection protocols encompass:

• Security protocols and incident management procedures
• Securing data during transmission and storage
• Limiting personal data access to approved individuals
• Staff safety education
• Administering complete and partial backup procedures for our systems

Control Your Account Details, Purchases, and Preferences

Our online portal allows you to control different elements of your account:

• Account Information: Update your name, business name, mailing address, email address, and account password
• Subscription Services: Add, modify, pause or cancel your subscription services
• Orders & Tracking: View order history, track orders, and re-order
• Payment Methods: Add, modify or remove your payment information
• Addresses: Add, modify or remove your addresses
• Favorites: Add, modify or remove your favorites

For assistance managing your account, contact our customer service at +14157823456 .

8. Control your Communication Settings & Promotional Messages

From time to time, we share service updates and special promotional messages about our celebrity marketing offerings that could be valuable to you. These communications are sent based on your consent and our ongoing business partnership. You maintain full control over the types of messages you receive, your preferred delivery methods, and can withdraw your consent (or unsubscribe) whenever you wish.

If you require help managing your contact preferences, contact our customer service at +14157823456 .

Freedom from Automated Decisions You can choose not to be subject to decisions based solely on automated processing, including profiling, which may significantly affect you. This right exists unless the automated decision-making is: • Necessary for entering into or performing a contract with you • Authorized by applicable law • Based on your explicit consent Even when these exceptions apply, you have the right to: • Request human intervention • Express your point of view • Contest the decision if you disagree with it To exercise your right to opt out of automated decision-making, please contact us using the information provided in the "Contact Us" section.

Any system, software, or process that processes your personal data to reach or implement decisions with legal or comparable significant impact on you without human oversight qualifies as "automated decision-making technology." This includes technologies derived from artificial intelligence, machine learning, data analytics, and statistical modeling approaches.

We might employ automated systems to customize our celebrity endorsement services and enhance user experiences. If automated decision-making processes are used, you have the option to decline by following the opt-out procedures outlined in our Privacy Rights segment.

Managing Your Cookie and Interest-based Ad Preferences

Our online services use cookies, pixel tags, tracking scripts, and similar technologies to authenticate users, enable secure online purchasing, deliver our celebrity marketing services, and personalize content and offers. Our Cookie Notice provides instructions on how to opt-out from or remove our cookies from your device or browser.

You can also choose to disable personalized advertising by using these industry-provided options:

• Digital Advertising Alliance:
  • WebChoices to opt-out using your browser
  • YourAdChoices to opt-out using your email address or telephone number
• Network Advertising Initiative:
  • Consumer Opt-Out Choices

Declining Marketing Communications and Promotional Mail You may choose to stop receiving direct mailings and promotional emails from us. To be removed from our contact lists, simply notify us through any of the following methods: • Send an email requesting removal • Click the "unsubscribe" link in our marketing emails • Contact our customer service team • Update your communication preferences in your account settings Please note that even after opting out of marketing messages, you may still receive essential communications regarding your account or services.

Should you get an unexpected message from our team or wish to stop receiving specific promotional or marketing materials related to our celebrity marketing offerings, you can follow these procedures. We will process your request within ten (10) business days.

• For direct mail: Opt-out by contacting our customer service at +14157823456
• For email messages: Opt-out by clicking on the "Unsubscribe" link in the email message we sent or by contacting our customer service

Decline Text Message Services

For text messaging services, you can opt-out by replying STOP, END, CANCEL, UNSUBSCRIBE or QUIT to any text message you receive from Peak Digital Marketing Solutions. You may receive one final text message confirming your request. For help, reply HELP to any text message or contact us at +14157823456 .

13. Right to Decline Information Sale or Sharing

Digital Peak Marketing Solutions doesn't exchange your private data for monetary gain in the traditional way. Nevertheless, we utilize behavioral advertising across different platforms to show you targeted ads about our celebrity marketing offerings, which could technically qualify as "selling" or "sharing" personal data. To learn how to prevent this sharing or sale of your private information, please refer to our Privacy Rights section.

Peak Digital Marketing Solutions maintains strict privacy standards, ensuring that employee and applicant personal data is never sold or distributed to outside parties for behavioral advertising across different contexts.

14. Withdrawal through Global Opt-Out Tools

When your browser or device is correctly set up to send privacy preferences to our online services through "global opt-out tools" (including Global Privacy Control signals), our digital platforms will respect your choices and show "Opt-Out Request Honored" as a confirmation within our cookie consent notification and preference settings interface.

Privacy Protections & Your Personal Privacy Options

Privacy legislation may grant you specific rights regarding your personal data that we have gathered. The specific privacy rights you can exercise vary based on where you live, as well as the type, extent, circumstances, and intended use of your request.

You may be entitled to the following rights:

• Right to Access your personal information and be informed about what processing, sharing, or disclosure we have done
• Right to Correct inaccuracies to your personal information
• Right to Delete your personal information from our business systems
• Right to Data Portability to your personal information in a machine-readable format
• Right to Restrict Processing to your personal information under certain conditions
• Right to designate an Authorized Agent to act on your behalf regarding your personal information
• Right to Opt-out from targeted advertising, the sale or sharing of your personal information, and automated decision-making technology
• Right to Withdraw Consent to our collection, use, and disclosure of your personal information
• Right to Appeal Decisions we have made about your personal information and privacy rights
• Right to File Complaint with your applicable data protection authority

To make use of these rights, you may:

• Online: Use our Privacy Request Form
• Email: [email protected]
• Phone: +14157823456

Protection Against Discrimination for Exercising Your Privacy Rights We will not treat you unfairly or differently for exercising any of your privacy rights. You can freely make privacy-related choices without fear of retaliation, negative consequences, or discriminatory treatment. This includes maintaining the same level of service, quality, and pricing regardless of your privacy decisions.

We at Peak Digital Marketing Solutions pledge not to discriminate or take retaliatory action against individuals who exercise their privacy rights as outlined in this Global Notice and protected by applicable data protection legislation. This includes our commitment to maintain consistent pricing, service quality, and access to our products and services, regardless of whether you choose to exercise your privacy rights.

Privacy and Data Protection Impact & Risk Evaluations

We conduct risk and impact evaluations of our operational systems and procedures whenever necessary, considering the type, extent, framework, and objectives of our data handling operations, in accordance with relevant data protection regulations.

Unauthorized Access to Private Data

In the event of a possible security breach affecting your personal data, we will conduct an immediate investigation. Should we determine that your personal information was compromised in a manner that constitutes a breach under current data protection legislation, we will inform you by sending a breach notification to the email address associated with your account, or through other means as required by law.

19. Cross-Border Data Movement We may need to process your information in countries outside your home location. This happens when our service providers, business partners, or affiliated companies operate internationally. When we transfer data across borders, we implement appropriate safeguards to protect your information according to applicable data protection laws. These safeguards typically include contractual obligations with our data recipients, ensuring they maintain adequate security measures and process your information only as permitted. By using our services or providing your information, you acknowledge that your data may be transferred to and processed in countries that might have different data protection standards than your own. Rest assured, we maintain strict protocols to protect your information during such transfers.

Peak Digital Marketing Solutions operates exclusively within the United States and has no physical presence or offices in other nations.

In utilizing our services, your personal data is processed, accessed, and maintained on servers and hardware situated in the United States and various other nations where our service partners operate. As a result, your personal information may be transferred to the United States and other jurisdictions that might not maintain data protection standards comparable to those of your home country.

For personal data transfers, we use authorized data transfer mechanisms, which include:

• Adequacy Decisions: European Commission adequacy decisions and UK adequacy decisions
• By Contract: EU standard contractual clauses ("EU SCCs"), the UK International Data Transfer Addendum to the EU SCCs ("UK Addendum"), or equivalent model clauses
• With Your Consent: Where you have provided consent to the proposed transfer after being informed of possible risks

Geographic Privacy Supplements and Regional Addenda

Additional privacy terms and rights specific to certain countries or regions are covered in these supplemental privacy notifications:

• Privacy Notice for California Residents Under the CCPA
• Data Protection and Privacy Statement In compliance with data protection regulations, we inform you about how we process your personal information. This notice outlines our practices for collecting, storing, and safeguarding your data in accordance with GDPR requirements. Your privacy matters to us. We commit to handling your personal data responsibly, transparently, and securely, ensuring it's used only for legitimate business purposes and with your consent where required. We protect your information through appropriate technical and organizational measures, limiting access to authorized personnel who need it for specific business functions. Your data is retained only as long as necessary and in line with legal obligations. You have rights regarding your personal data, including access, correction, deletion, and data portability. To exercise these rights or learn more about our data handling practices, please contact our Data Protection Officer. This notice may be updated periodically to reflect changes in our practices or regulatory requirements. We encourage you to review it regularly to stay informed about how we protect your privacy.

21. Supplementary Conditions Referenced or Omitted by Citation

• For clients, customers, users, and web visitors, you must read this Global Notice together with our General Terms & Conditions
• This Global Notice excludes external links that redirect from our services to websites or online resources not under Peak Digital Marketing Solutions' control

Concerns About Your Privacy If you have inquiries, complaints, or concerns about your personal information, data collection practices, or the handling of your privacy, please don't hesitate to contact us. Our privacy team is here to help address any issues and provide clarity on our privacy practices. You can reach out to us about privacy matters through: - Email - Our website's contact form - Written correspondence to our main office - Phone support We take privacy concerns seriously and will work diligently to resolve any issues you bring to our attention.

We are committed to resolving your questions, issues, and complaints about this Global Notice and related privacy management practices by emailing [email protected] or calling +14157823456 .

Should you feel dissatisfied with our complaint resolution, you may elevate your concerns to our management team. If you remain unhappy with the outcome, you have the right to file a complaint with the relevant data protection authority in your jurisdiction.

23. Control Room Details

The entity responsible for managing personal data gathered under this Worldwide Privacy Notice is:

Contact Information for Privacy and Data Protection Representatives

Get in touch with our Data Protection & Privacy Representative:

Changes to Our Global Privacy Statement

We reserve the right to update, revise, or alter this Global Notice periodically. Any such modifications will become effective as of the "Last Updated" date displayed at the beginning of this Global Notice.

Any material change to this Global Notice will be effective upon posting the revised Global Notice to our services at https://www.kletterwald-feldberg.com/legal/global-privacy-notice.html or by emailing a copy of these changes to the email address on file for your account or by any other means consistent with applicable law. It is your responsibility to check this Global Notice for changes prior to each use of our services.

Effective Date: June 24, 2025
Last Review Date: June 24, 2025
Next Scheduled Review: December 2025