Privacy Policy of Srado Ventures, LLC and Its Affiliates

1. Introduction and Scope

This Privacy Policy (“Policy”) is promulgated by Srado Ventures, LLC, a Florida limited liability company (“Srado Ventures,” “Company,” “we,” “us,” or “our”), and is intended to govern and apply to the data collection, usage, storage, sharing, and security practices of all current and future websites, mobile applications, digital services, subsidiaries, affiliates, brands, or business divisions owned, controlled, or operated by Srado Ventures, LLC (collectively, the “Srado Entities”).

This Policy sets forth the lawful basis and commercial rationale under which the Srado Entities may collect and process Personal Information and Sensitive Personal Information of visitors, users, customers, business partners, vendors, and any other individual whose information is obtained or accessed through any digital or physical platform managed by the Srado Entities (hereinafter referred to as “you” or “Data Subject”).

By accessing any Srado Entity website, submitting Personal Information, or engaging with any Srado product or service, you acknowledge and agree to the terms set forth in this Policy.

2. Definitions

For purposes of this Policy, the following definitions shall apply:

• “Personal Information” shall mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person, as defined by applicable laws, including but not limited to name, address, email address, phone number, IP address, account identifiers, browsing history, and geolocation data.
• “Sensitive Personal Information” shall include data such as social security numbers, biometric data, health-related data, financial account credentials, racial or ethnic origin, religious beliefs, precise geolocation, or other data deemed sensitive under law.
• “Process” or “Processing” shall mean any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, storage, modification, retrieval, use, disclosure, transmission, dissemination, erasure, or destruction.
• “Data Subject” refers to any individual whose Personal Information is Processed by Srado Ventures or any Srado Entity.
• “Applicable Law” includes, without limitation, the California Consumer Privacy Act (“CCPA”), California Privacy Rights Act (“CPRA”), the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”), Children’s Online Privacy Protection Act (“COPPA”), Gramm-Leach-Bliley Act (“GLBA”), and any U.S. federal, state, or international data protection laws that may govern or apply to Srado’s activities.

3. Categories of Information Collected

Srado Ventures and the Srado Entities may collect and process the following categories of information, directly or indirectly, through manual, automated, or third-party means, subject to the provisions of this Policy:

A. Identifiers and Contact Information

Including but not limited to:

• Full name, postal address, email address, telephone number, user ID, account credentials, IP address, and device identifiers.

B. Commercial and Transactional Information

Including:

• Records of products or services purchased, obtained, or considered, order histories, preferences, or other purchasing tendencies.

C. Internet or Other Electronic Network Activity Information

Including:

• Browsing history, search history, clickstream data, session logs, operating system, browser type, access timestamps, referring/exit pages, and usage behavior collected through cookies or similar technologies.

D. Geolocation Data

Collected through user device settings, IP resolution, or third-party analytics to the extent necessary for service delivery or legal compliance.

E. Financial and Payment Information

Srado Ventures may facilitate payment transactions through third-party payment processors such as Stripe, PayPal, Square, or similar services. Srado Ventures does not directly collect or store your credit card numbers, bank account details, or security codes. These third-party processors may independently collect and process such data in accordance with their privacy policies and applicable laws.

F. Biometric, Health, or Sensitive Information

While Srado Ventures does not currently collect biometric or health data, future ventures may incorporate features or applications (including those powered by artificial intelligence, predictive analytics, or decision-making algorithms) that process Sensitive Personal Information, including but not limited to medical history, fitness data, mental wellness inputs, or biometric identifiers. Any such collection shall be subject to heightened safeguards and compliance with applicable data protection laws.

G. Inferred and Derived Information

We may derive information or user profiles based on data analytics, user behavior, and AI-based tools, including predicted preferences, risk levels, or behavioral trends.

4. Purposes for Data Collection and Legal Basis for Processing

Srado Ventures and the Srado Entities collect and Process Personal Information for the following lawful and business-critical purposes, and shall retain such data only for as long as necessary to fulfill the stated purposes or comply with applicable legal obligations:

A. Service Provision and Operations

To provide, maintain, personalize, and improve the websites, applications, and services offered by Srado Entities, including but not limited to user account creation, service fulfillment, order processing, technical support, content delivery, and authentication.

B. Transaction Facilitation

To enable the secure and compliant facilitation of payments through third-party payment processors, including but not limited to Stripe, PayPal, Square, or other financial intermediaries. Srado Ventures does not store payment credentials or financial account numbers.

C. Marketing, Targeting, and Retargeting

To analyze user preferences and deliver customized advertising content through digital platforms. Srado Ventures may utilize:

• Google Analytics and Google Ads for site performance, attribution, and behavioral targeting;
• Meta Platforms (Facebook/Instagram), LinkedIn, Twitter/X, TikTok, and other digital media platforms for ad placement and retargeting;
• Cookies, pixel tags, beacons, and similar tracking technologies for performance measurement, remarketing, and lookalike audience generation.

Users may opt-out of certain behavioral targeting through the Network Advertising Initiative (www.networkadvertising.org/choices) or similar self-regulatory programs. The Company does not currently respond to browser-based “Do Not Track” signals and disclaims any obligation to do so.

D. Research, Analytics, and Product Development

To conduct internal research, trend analysis, feature testing, and optimization of products, services, and website performance. Data may be anonymized or pseudonymized for such analytical purposes.

E. Automated Decision-Making and Profiling

Srado Ventures may utilize automated data processing technologies, including AI-driven engines, algorithms, and heuristics, to facilitate:

• Dynamic pricing models;
• Predictive booking or product suggestions;
• Eligibility determinations;
• Risk scoring or fraud detection;
• Personalization of content or offerings.

Where required by law, individuals shall be informed of the use of such automated decision-making and may request human review, where feasible.

F. Legal and Regulatory Compliance

To comply with legal obligations under applicable federal, state, or international laws, including but not limited to recordkeeping, fraud prevention, law enforcement requests, tax reporting, and data subject rights fulfillment.

G. Security and Fraud Detection

To monitor, detect, and prevent security breaches, identity theft, unauthorized access, and other illegal or harmful activity, and to enforce the Terms of Use of any Srado Entity.

5. Disclosure of Personal Information to Third Parties

Srado Ventures and the Srado Entities may disclose Personal Information to third parties only in the following circumstances and subject to appropriate confidentiality, security, and lawful basis protections:

A. Service Providers and Contractors

We may share data with third-party vendors, service providers, contractors, and agents who perform functions on our behalf, such as:

• Website hosting and infrastructure (e.g., AWS, Cloudflare);
• Analytics providers (e.g., Google Analytics);
• Advertising networks (e.g., Google Ads, Meta, TikTok);
• CRM and communication tools (e.g., Mailchimp, HubSpot);
• Payment processors (e.g., Stripe, PayPal, Square).

Such entities are authorized to process Personal Information only to the extent necessary to perform their contractual functions, and are prohibited from using such data for their own purposes.

B. Affiliates and Corporate Family

Personal Information may be shared within the Srado corporate family, including subsidiaries, joint ventures, and future affiliates, for operational, administrative, or marketing purposes, subject to the terms of this Policy.

C. Business Transfers

In the event of a merger, acquisition, divestiture, restructuring, reorganization, bankruptcy, asset sale, or other transfer of control involving Srado Ventures or any Srado Entity, Personal Information may be disclosed, sold, or otherwise transferred to the successor entity, subject to continued compliance with this Privacy Policy or one materially similar in protection.

D. Legal Compliance and Government Requests

We may disclose Personal Information as required by law, regulation, subpoena, legal process, or enforceable government request, or where we believe such disclosure is necessary to protect rights, property, or personal safety.

E. AI and Automated Decisions

While Srado Ventures may use AI technologies to deliver or enhance services, we affirm that:

• No automated decision-making is used to render binding legal conclusions, financial denials, or health assessments;
• AI outputs are reviewed for fairness, nondiscrimination, and transparency, to the extent required by applicable law;
• Users retain the right to request human intervention regarding any materially impactful automated processing, where required.

6. Data Retention, Security, and Individual Rights

A. Data Retention

Srado Ventures and the Srado Entities shall retain Personal Information only for as long as is necessary to fulfill the purposes outlined in this Policy, including:

• Compliance with legal obligations (e.g., tax, regulatory, dispute resolution);
• Enforcement of contractual rights;
• Analysis of service performance and improvement.

Upon the expiration of the applicable retention period, or upon verified user request, Srado shall delete or anonymize Personal Information in accordance with applicable laws and industry best practices, subject to any legal preservation obligations.

B. Data Security

We implement and maintain reasonable and appropriate administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of Personal Information. These may include:

• SSL/TLS encryption for data in transit;
• Role-based access control;
• Intrusion detection and response tools;
• Employee confidentiality obligations and training.

However, no method of transmission or storage is 100% secure, and Srado Ventures disclaims all warranties, express or implied, regarding the complete security of Personal Information. In the event of a data breach, affected individuals may be notified in accordance with applicable breach notification laws.

C. User Rights and Choices

Subject to jurisdictional requirements and verification procedures, you may exercise the following rights by contacting [email protected]:

1. Right to Access – To request a copy of the Personal Information collected and/or shared about you.
2. Right to Correct – To request correction of inaccurate or incomplete data.
3. Right to Delete – To request the erasure of your Personal Information, subject to lawful exceptions.
4. Right to Opt-Out of Sale or Sharing – You may request to opt-out of any future sale or sharing of your Personal Information, should Srado choose to engage in such activities. Currently, Srado Ventures does not sell Personal Information as defined under the CCPA/CPRA.
5. Right to Limit Use of Sensitive Information – If and when we collect Sensitive Personal Information, you may request its use be limited to essential service functions.
6. Right to Non-Discrimination – We will not deny goods or services, charge different prices, or provide a different level of service to you for exercising your privacy rights.

All rights requests must include sufficient information to verify your identity and a clear description of the request. We may refuse or limit responses where permitted by law.

D. Automatic Deletion and Inactivity Protocols

To enhance data hygiene and mitigate unnecessary retention, Srado Ventures may implement protocols to anonymize, archive, or delete Personal Information after a defined period of three (3) years of user inactivity, where such deletion is operationally feasible and not legally restricted. Notification of impending deletion may be provided where required.

E. Limitations of Liability for User Conduct and Third-Party Platforms

You, the Data Subject, are solely responsible for:

• The accuracy, legality, and completeness of any information you provide;
• Ensuring such information does not infringe upon the rights of others or violate applicable laws.

Srado Ventures shall not be liable for any damages arising from:

• User-submitted data that is false, misleading, or unlawfully obtained;
• Security breaches, data misuse, or unauthorized disclosures occurring on or through third-party platforms, processors, or integrations (e.g., Stripe, Meta, Google, AWS), even if accessed via Srado Entities.

We expressly disclaim liability for any loss or damage resulting from reliance on inaccurate or outdated Personal Information, or from user failure to update such information.

7. Children’s Privacy, International Data Transfers, and Policy Amendments

A. Children’s Privacy (COPPA Compliance)

Srado Ventures and the Srado Entities do not knowingly collect or solicit Personal Information from individuals under the age of thirteen (13). If we become aware that we have inadvertently collected such information without verified parental consent, we will promptly delete it.

No portion of our services is directed to or intended for children under 13. If you are a parent or legal guardian and believe your child has provided Personal Information to us, please contact us at [email protected].

B. International Data Transfers

Although Srado Ventures does not target international users, our platforms may be accessed by individuals located outside the United States. By interacting with any Srado service, you acknowledge and agree that your data may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.

Where required, we shall take appropriate measures to ensure lawful cross-border data transfers, including reliance on Standard Contractual Clauses, adequacy decisions, or consent.

C. Policy Amendments and Versioning

Srado Ventures reserves the right to amend this Privacy Policy at any time in response to legal, operational, or technological developments. Material changes will be posted on our website(s), and the “Last Updated” date at the top of the Policy shall be revised accordingly.

Continued use of our services following such changes shall constitute your acknowledgment and acceptance of the revised terms.

8. Dispute Resolution, Governing Law, and Contact

A. Binding Arbitration and Waiver of Class Actions

To the fullest extent permitted by law, any and all disputes, controversies, or claims arising out of or relating to this Privacy Policy, the Srado Entities’ services, or your relationship with Srado Ventures (whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory), shall be resolved exclusively through final and binding arbitration, administered by the American Arbitration Association (AAA) under its applicable rules.

This agreement to arbitrate includes, without limitation, any disputes concerning the collection, use, storage, or disclosure of Personal Information.

B. Exclusion for Small Claims

Nothing herein shall preclude either party from seeking relief in a small claims court of competent jurisdiction for disputes that qualify under applicable monetary thresholds.

C. Class Action and Jury Trial Waiver

You and Srado Ventures expressly agree that:

• No class, consolidated, or representative actions shall be brought;
• Each party may bring claims only in an individual capacity, and not as a plaintiff or class member in any purported class or collective proceeding;
• Jury trials are expressly waived.

D. Governing Law and Jurisdiction

This Policy and any dispute arising therefrom shall be governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict of law principles. Any court proceedings (where permitted) shall be brought exclusively in the state or federal courts located in Palm Beach County, Florida, and each party irrevocably submits to the personal jurisdiction thereof.

E. Contact Information

For any inquiries, rights requests, complaints, or notices regarding this Privacy Policy or data practices, please contact:

Legal Department

Srado Ventures, LLC
Email: [email protected]
Subject Line: Privacy Policy Inquiry