Privacy Policy

1. INTRODUCTION AND SCOPE

1.1 Overview.

This Privacy Policy describes how The PopupStaff, LLC (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you access or use the website located at www.ThePopupStaff.com and any related applications, features, tools, and services (collectively, the “Platform”).

1.2 Who This Policy Applies To.

This Privacy Policy applies to all individuals who access or use the Platform, including without limitation:

(a) individuals who create accounts and profiles as workers or service providers (“Talent”);
(b) individuals or businesses who post opportunities or engage Talent (“Clients”); and
(c) visitors who browse the Platform without creating an account.

1.3 Relationship to Terms of Service.

This Privacy Policy forms part of and is incorporated by reference into the Company’s Terms of Service. Capitalized terms not defined in this Privacy Policy have the meanings set forth in the Terms of Service.

1.4 Information Covered.

This Privacy Policy applies to “personal information” or “personal data,” meaning information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

1.5 Geographic Scope.

The Platform is operated from the United States. By accessing or using the Platform, you acknowledge that your information may be collected, stored, and processed in the United States and other jurisdictions where the Company or its service providers operate, which may have data protection laws that differ from those of your place of residence.

1.6 Effective Date.

This Privacy Policy is effective as of the “Last Updated” date posted at the top of this Privacy Policy and applies to all information collected on or after that date.

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide.

We collect personal information that you voluntarily provide to us when you create an Account, complete a profile, post or respond to opportunities, communicate with other Users, subscribe to a paid plan, or otherwise interact with the Platform. This information may include, without limitation:

(a) Account Information: name, email address, telephone number, username, password, and other registration details;
(b) Profile Information (Talent): photographs, skills, work experience, availability, geographic location, resume information, certifications, and other information you choose to include in your profile;
(c) Profile Information (Clients): business name, business address, contact person, job titles, job descriptions, and related business details;
(d) Communications: messages exchanged through the Platform, support inquiries, and other communications with us or other Users;
(e) Subscription and Billing Information: payment method details and billing information, which are processed by third-party payment processors and not stored directly by the Company, except for limited transaction identifiers and subscription status; and
(f) Other Information: any additional information you choose to provide through forms, surveys, or other features of the Platform.

2.2 Information Collected Automatically.

When you access or use the Platform, we may automatically collect certain information about your device and usage, including without limitation:
(a) IP address and general location information;
(b) device identifiers, browser type, operating system, and language settings;
(c) pages viewed, features used, time and date of visits, referring and exit URLs, and other usage data; and
(d) log files and diagnostic information.

2.3 Cookies and Similar Technologies.

We and our service providers may use cookies, web beacons, pixels, and similar tracking technologies to collect information about your interactions with the Platform, to rememberyour preferences, to authenticate users, to analyze usage, and to improve our Services. Additional information regarding cookies and your choices is described in Section 5 of this Privacy Policy.

2.4 Information from Third Parties.

We may receive information about you from third-party service providers and partners, including without limitation:

(a) payment processors, in connection with subscription billing and fraud prevention;
(b)analytics providers, in connection with usage and performance analysis;
(c) marketing and advertising partners, in connection with promotional campaigns; and
(d) social media platforms or other third-party integrations, if you choose to connect them to your Account.

2.5 Combination of Information.

We may combine information collected from you directly, information collected automatically, and information received from third parties for the purposes described in this Privacy Policy.

3. HOW WE USE INFORMATION

We use the information we collect for the following business and commercial purposes:

3.1 To Provide and Operate the Platform.

To create and manage Accounts, authenticate Users, display profiles and job postings, facilitate communications between Talent and Clients, and otherwise operate and maintain the Platform.

3.2 To Match Talent and Clients.

To enable search, discovery, and matching of Talent and Clients based on skills, experience, location, availability, and other profile information.

3.3 To Process Subscriptions and Payments.

To administer Subscription Plans, process billing and payments through third-party payment processors, prevent fraud, and manage account status and access to paid features.

3.4 To Communicate with You.

To send administrative messages, service announcements, technical notices, security alerts, and support responses, and, where permitted by law, to send marketing and promotional communications.

3.5 To Improve and Develop the Platform.

To analyze usage trends, monitor and improve performance, develop new features, conduct research and analytics, and enhance user experience.

3.6 To Enforce Our Terms and Protect Rights.

To enforce our Terms of Service, detect and prevent fraud or misuse, investigate potential violations, and protect the rights, property, and safety of the Company, our Users, and third parties.

3.7 To Comply with Legal Obligations.

To comply with applicable laws, regulations, legal processes, and governmental requests, and to establish, exercise, or defend legal claims.

3.8 For Marketing and Advertising.

Subject to your preferences and applicable law, to personalize content, deliver targeted advertising, measure the effectiveness of marketing campaigns, and promote the Platform and related services.

3.9 Aggregated and De-Identified Data.

To create and use aggregated or de-identified information for analytics, research, and business purposes, in which case such information will not be reasonably capable of identifying you.

4. HOW WE SHARE INFORMATION

4.1 With Other Users.

We may share your information with other Users as necessary to facilitate the operation of the Platform, including:

(a) Profile Information: Talent profiles (such as name, photo, skills, experience, and location) may be visible to Clients, and Client profile information may be visible to Talent;
(b) Communications: Messages and other communications you send through the Platform will be shared with the intended recipient; and
(c) Booking-RelatedInformation: Information necessary for Talent and Clients to communicate and arrange Bookings, subject to each User’s privacy settings and the functionality of the Platform.

4.2 With Service Providers.

We may share information with third-party vendors, consultants, and service providers who perform services on our behalf, including without limitation:

(a) website and data hosting;
(b)payment processing and billing;
(c) email, messaging, and customer support services;
(d) analytics and performance monitoring;
(e) security, fraud prevention, and compliance services.These service providers are authorized to use personal information only as necessary to perform services for us and are contractually obligated to protect such information.

4.3 For Legal and Compliance Purposes.

We may disclose information if we believe in good faith that such disclosure is necessary to:

(a) comply with applicable law, regulation, legal process, or governmental request;
(b) enforce our Terms of Service or other agreements;
(c) investigate, prevent, or take action regarding potential violations, fraud, or security issues; or
(d) protect the rights, property, or safety of the Company, our Users, or others.

4.4 Business Transfers.

In the event of a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, your information may be disclosed to and transferred as part of such transaction, subject to customary confidentiality protections.

4.5 With Your Consent.

We may share your information with third parties when you direct us to do so or otherwise provide your consent.

4.6 Aggregated or De-Identified Information.

We may share aggregated or de-identified information that cannot reasonably be used to identify you for business, analytical, research, or marketing purposes.

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 Cookies and Similar Technologies.

We and our service providers use cookies, web beacons, pixels, SDKs, and similar tracking technologies (“Cookies”) to collect information about your interactions with the Platform, to operate and improve the Services, and to provide a more personalized experience.

5.2 Types of Cookies We Use.

We may use the following categories of Cookies:

(a) Essential Cookies: Necessary for the operation of the Platform, including account authentication, security, and fraud prevention.
(b) Functional Cookies: Used to remember your preferences and settings and to enhance functionality.
(c) Analytics Cookies: Used to understand how Users interact with the Platform, measure performance, and improve features (e.g., through services such as Google Analytics or similar tools).
(d) Advertising and Marketing Cookies: Used to deliver and measure the effectiveness of advertisements and marketing campaigns and, where applicable, to personalize content.

5.3 Third-Party Tracking.

Third-party service providers, such as analytics and advertising partners, may place Cookies on your device and collect information about your online activities over time and across different websites and services, subject to their own privacy policies.

5.4 Your Choices.

You can control or disable Cookies through your browser or device settings. Please note that if you disable certain Cookies, some features of the Platform may not function properly or may be unavailable.

5.5 Do Not Track Signals.

Some browsers offer a “Do Not Track” (“DNT”) signal. At this time, there is no universally accepted standard for responding to DNT signals, and the Platform does not respond to such signals.

6. DATA RETENTION

6.1 Retention Periods.

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide and operate the Platform, maintain your Account, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our rights.

6.2 Account Information.

Information associated with your Account will generally be retained for the duration of your active use of the Platform. If you close your Account or request deletion, we will take reasonable steps to delete or anonymize your personal information, subject to the retention requirements described below.

6.3 Legal and Business Requirements.

We may retain certain information for longer periods where required or permitted by law, including for tax, accounting, regulatory, fraud prevention, security, and litigation purposes, or to comply with legal process or governmental requests.

6.4 Backups and Residual Copies.

Even after deletion of your Account or personal information, copies of such information may remain in our backup systems or archives for a limited period of time, in accordance with our data retention policies and applicable law, after which such information will be securely deleted or anonymized.

7. DATA SECURITY

7.1 Security Measures.

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures may include access controls, encryption, secure hosting environments, and monitoring of our systems for vulnerabilities and threats.

7.2 No Absolute Security.

Despite our efforts, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, we cannot and do not guarantee the absolute security of your personal information, and you use the Platform and provide information at your own risk.

7.3 User Responsibilities.

You are responsible for maintaining the confidentiality of your Account credentials and for any activity that occurs under your Account. You should use strong passwords, keep your login information secure, and notify us immediately of any suspected unauthorized access to or use of your Account.

7.4 Security Breach Notification.

In the event of a data breach involving your personal information, we will provide notice as required by applicable law and take commercially reasonable steps to investigate, mitigate, and remediate the incident.

8. YOUR CHOICES AND CONTROLS

8.1 Account Information.

You may access, review, update, or correct certain personal information in your Account at any time by logging into your Account settings. You are responsible for ensuring that your information is accurate and up to date.

8.2 Communication Preferences.

You may manage your preferences for receiving marketing or promotional communications from us by following the unsubscribe instructions included in such communications or by adjusting your Account settings. Please note that you may continue to receive transactional or service-related communications, such as account notices and billing information, even if you opt out of marketing messages.

8.3 Cookies and Tracking Controls.

You can control the use of Cookies and similar technologies through your browser or device settings, as described in Section 5. Disabling certain Cookies may affect the functionality of the Platform.

8.4 Access, Deletion, and Portability Requests.

Subject to applicable law, you may request access to, correction of, deletion of, or a copy of your personal information by contacting us using the information provided in Section 14. We will respond to such requests in accordance with applicable legal requirements.

8.5 Withdrawal of Consent.

Where we rely on your consent to process personal information, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal, and may limit your ability to use certain features of the Platform.

9. STATE PRIVACY RIGHTS

9.1 California Privacy Rights (CCPA/CPRA).

If you are a resident of California, you have certain rights under the California Consumer Privacy Act and the California Privacy Rights Act (“CCPA/CPRA”), including the right to:

(a) Know what categories of personal information we collect, the sources of such information, the purposes for which we use it, and the categories of third parties with whom we share it;
(b) Access the specific pieces of personal information we have collected about you;
(c) Delete personal information we have collected from you, subject to certain exceptions;
(d) Correct inaccurate personal information;
(e) Opt Out of the “sale” or “sharing”of personal information, if applicable (we do not sell personal information in the traditional sense, but we may share information for advertising or analytics purposes as defined by law);
(f) Limit the Use of Sensitive Personal Information, if applicable; and
(g) Non-Discrimination, meaning you will not receive discriminatory treatment for exercising your privacy rights.You may exercise these rights by submitting a verifiable consumer request using the contact information provided in Section 14. We may need to verify your identity before processing your request.

9.2 Other U.S. State Privacy Laws.

Residents of certain other U.S. states, including Virginia, Colorado, Connecticut, and Utah, may have similar rights under applicable state privacy laws, which may include the right to:

(a) access and confirm whether we process your personal information;
(b) correct inaccuracies in your personal information;
(c) delete personal information;
(d) obtain a copy of your personal information in a portable format;
(e) opt out of targeted advertising, the sale of personal information, or certain profiling activities; and
(f) appeal our decision regarding a privacy rights request. Requests to exercise these rights may be submitted using the contact information in Section 14, and we will respond in accordance with applicable law.

9.3 Authorized Agents.

Where permitted by law, you may designate an authorized agent to submit privacy rights requests on your behalf. We may require proof of the agent’s authorization and verification of your identity before processing such requests.

10. INTERNATIONAL USERS

10.1 Cross-Border Data Transfers.

The Platform is operated from the United States. If you access or use the Platform from outside the United States, your personal information may be transferred to, stored in, and processed in the United States and other jurisdictions where the Company or its service providers maintain facilities.

10.2 Different Data ProtectionLaws.

The data protection and privacy laws of the United States and other jurisdictions may differ from those in your country of residence and may not provide the same level of protection. By using the Platform and providing your personal information, you consent to the transfer of your information to and from the United States and to the processing of your information in accordance with this Privacy Policy.

10.3 Legal Bases for Processing.

Where required by applicable law, we rely on one or more of the following legal bases to process personal information:

(a) performance of a contract (to provide the Platform and Services);
(b) compliance with legal obligations;
(c) our legitimate business interests (such as operating, improving, and securing the Platform); and
(d) your consent, where applicable.

10.4 Safeguards.

Where required by applicable law for international data transfers, we will implement appropriate safeguards, such as contractual protections or other lawful transfer mechanisms, to help ensure an adequate level of protection for your personal information.

11. CHILDREN’S PRIVACY

11.1 Age Restriction.

The Platform is not intended foruse by individuals under the age of eighteen (18). We do not knowingly collect, use, or disclose personal information from children under 18.

11.2 No Knowing Collection.

If we become aware that we have inadvertently collected persona linformation from a person under the age of 18, we will take commercially reasonable steps to delete such information from our records as soon as practicable.

11.3 Parental Requests.

If a parent or legal guardian believes that a child under the age of 18 has provided personal information to us, they may contact us using the information in Section 14 to request review or deletion of such information.

11.4 COPPA Compliance.

To the extent applicable, we comply with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and do not knowingly collect personal information from children under the age of 13.

12. THIRD-PARTY LINKS AND SERVICES

12.1 Links to Third-Party Websites.

The Platform may contain links to third-party websites, applications, or services that are not owned or controlled by the Company, including links to external job tools, social media platforms, payment processors, or other service providers.

12.2 No Responsibility for Third-Party Practices.

This Privacy Policy applies only to information collected by the Company through the Platform. We are not responsible for the privacy practices, data collection, use, disclosure, or security policies of any third-party websites or services, even if they are accessible through the Platform.

12.3 Independent Policies.

When you access a third-party website or service, you do so at your own risk and are subject to that third party’s terms of use and privacy policy. We encourage you to review the privacy policies of any third-party sites or services before providing them with your personal information.

12.4 No Endorsement.

The inclusion of any third-party link or integration on the Platform does not imply endorsement, approval, or affiliation by the Company with such third party or its practices.

13. CHANGES TO THIS PRIVACY POLICY

13.1 Updates and Modifications.

We may update or modify this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations. When we make changes, we will revise the “Last Updated” date at the top of this Privacy Policy and post the updated version on the Platform.

13.2 Material Changes.

If we make material changes to this Privacy Policy, we will provide notice as required by applicable law, which may include posting a prominent notice on the Platform, sending you an email, or providing an in-Platform notification.

13.3 Continued Use.

Your continued access to or use of the Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of and agreement to the revised Privacy Policy. If you do not agree to any changes, your sole remedy is to discontinue use of the Platform and, if applicable, close your Account.

14. CONTACT INFORMATION AND PRIVACY REQUESTS

14.1 How to Contact Us.

If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise your rights under applicable privacy laws, you may contact us at:

The Popup Staff, LLC
Email:contact@thepopupstaff.com


14.2 Submitting Privacy Rights Requests.

To submit a request to access, correct, delete, orobtain a copy of your personal information, or to exercise any other rights available to you under applicable law, please contact us using the information above and clearly describe your request. We may need to verify your identity before processing your request, and we will respond within the time frames required by law.

14.3 Authorized Agents.

Where permitted by applicable law, you may designate an authorized agent to submit a privacy rights request on your behalf. We may require proof of the agent’s authority and verification of your identity before acting on such a request.

15. “DO NOT SELL OR SHARE”; TARGETED ADVERTISING; SENSITIVE PERSONAL INFORMATION

15.1 No Sale of Personal Information.

We do not sell personal information for monetary consideration. However, under certain U.S. state privacy laws, including the California Consumer Privacy Rights Act (“CPRA”), the sharing of personal information for cross-context behavioral advertising or analytics may beconsidered a “sale” or “sharing.”

15.2 Sharing for Advertising and Analytics.

We may share certain identifiers, device information, and usage data with analytics and advertising partners to measure performance, deliver relevant content, and improve the Platform. Such sharing may constitute “sharing” under CPRA and similar laws.

15.3 Right to Opt Out of Sale or Sharing.

Where required by law, you have the right to optout of the “sale” or “sharing” of your personal information for targeted advertising purposes. You may exercise this right by:

(a) submitting a request using the contact information in Section 14; or
(b) using any “Do Not Sell or Share My Personal Information” link or mechanism made available on the Platform.

15.4 Sensitive Personal Information.

We may collect limited categories of “sensitive personal information,” such as account login credentials and, where you choose to provide it, precise location information and photographs. We use such information only for purposes necessary to provide the Platform, secure Accounts, prevent fraud, and comply with legal obligations.

15.5 Limitation on Use of Sensitive Information.

We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law, and where required, you may have the right to limit the use and disclosure of such information by submitting a request in accordance with Section 14.

15.6 Non-Discrimination.

We will not discriminate against you for exercising any of your privacy rights, including by denying services, charging different prices, or providing a different level or quality of service, except as permitted by law.

16. AUTOMATED DECISION-MAKING AND PROFILING

16.1 Matching and Ranking Tools.

The Platform may use automated tools and algorithms to organize, rank, recommend, or display Talent profiles, job opportunities, and search results based on criteria such as skills, experience, location, availability, activity level, and subscription tier.

16.2 No Solely Automated Legal Decisions.

We do not use automated decision-making, including profiling, that produces legal or similarly significant effects concerning you without meaningful human involvement, such as decisions that would determine your eligibility for employment, credit, insurance, or housing.

16.3 Purpose of Automation.

Any automated processing is used solely to:

(a) improve search and matching relevance;
(b) personalize user experience;
(c) operate and secure the Platform; and
(d) detect and prevent fraud or abuse.

16.4 User Rights.

Where required by applicable law, you may have the right to request information about the logic involved in automated processing and to object to or request human review of certain automated decisions by contacting us as set forth in Section 14.

17. BIOMETRIC INFORMATION AND PHOTOGRAPHS

17.1 Photographs and Images.

Talent may choose to upload profile photographs or other images to the Platform. Such images are used solely for identification, profile display, and marketplace matching purposes.

17.2 No Biometric Processing.

The Company does not collect, extract, store, analyze, or use biometric identifiers or biometric information (such as facial recognition templates, facial geometry scans, fingerprints, or voiceprints), and does not use any facial recognition or biometric analysis technologies in connection with photographs or other images uploaded to the Platform.

17.3 No AI Training Use.

User photographs and other personal content are not used to train artificial intelligence or machine learning models for facial recognition or biometric identification purposes without your express consent.

17.4 Compliance with Biometric Laws.

To the extent any biometric data were ever collected in the future, the Company would do so only in compliance with applicable biometric privacy laws, including, where applicable, the Illinois Biometric Information Privacy Act (BIPA) and similar state statutes, and would provide all required notices and obtain any required consents.

18. LAW ENFORCEMENT REQUESTS AND LEGAL PROCESS

18.1 Disclosure for Legal Compliance.

We may disclose personal information if we believe in good faith that such disclosure is necessary to comply with applicable law, regulation, legal process, court order, subpoena, warrant, or governmental request, or to protect the rights, property, or safety of the Company, our Users, or others.

18.2 Review of Requests.

We review all law enforcement and governmental requests for personal information to ensure they are legally valid and properly scoped, and we object to or seek to narrow requests that we believe are unlawful, overbroad, or not required by applicable law.

18.3 User Notice.

Where permitted by law and consistent with legal obligations, we will attempt to notify affected Users of any request for their personal information before disclosing it, so that they may seek to challenge the request or otherwise protect their rights. We may delay or withhold notice if we determine that doing so is prohibited by law or would pose a risk to an ongoing investigation or to public safety.

18.4 Preservation of Information.

We may preserve personal information when required by law or when reasonably necessary to comply with legal obligations, enforce our agreements, resolve disputes, or protect our legal rights, even if such information would otherwise be deleted inaccordance with our data retention practices.

19. DATA MINIMIZATION; PURPOSE LIMITATION; RECORD KEEPING

19.1 Data Minimization.

We collect and process only the categories of personal information that are reasonably necessary and proportionate to achieve the purposes described in this Privacy Policy, including to operate the Platform, facilitate connections between Talent and Clients, administer subscriptions, communicate with Users, and comply with legal obligations.

19.2 Purpose Limitation.

We use personal information only for the specific and legitimate purposes described in this Privacy Policy or as otherwise permitted by applicable law. We do not use personal information for materially different, unrelated, or incompatible purposes without providing notice and, where required, obtaining your consent.

19.3 Retention and Internal Access Controls.

Access to personal information is limited to personnel and service providers who require such access for legitimate business purposes consistent with this Privacy Policy, and such access is subject to confidentiality and security obligations.

19.4 Record keeping and Compliance.

We maintain records of privacy rights requests and our responses as required by applicable law, including the California Consumer Privacy Act and similar state privacy statutes. Such records may include the date of the request, the type of request, the manner of verification, and the response provided, and will be retained for the period required by law.

19.5 Appeals of Privacy Decisions.

Where required by applicable state privacy laws, Users may have the right to appeal our decision regarding a privacy rights request. Information regarding how to submit an appeal will be provided in our response to the initial request or upon request through the contact information set forth in Section 14.

20. DISPUTE RESOLUTION; ARBITRATION

20.1 Incorporation of Terms of Service.

Any dispute, claim, or controversy arising out of or relating to this Privacy Policy, the collection, use, disclosure, or protection of personal information, or the Company’s privacy practices (each, a “PrivacyDispute”) shall be subject to the dispute resolution, arbitration, class action waiver, and jury trial waiver provisions set forth in Section 20 of the Company’s Terms of Service, which are hereby incorporated into this Privacy Policy by reference.

20.2 Exclusive Remedy.

To the fullest extent permitted by law, arbitration as set forth in the Terms of Service shall be the exclusive forum for resolving any Privacy Dispute, except to the extent a claim may be brought in small claims court or where a party seeks injunctive or equitable relief for intellectual property or data security matters as permitted under the Terms of Service.

20.3 No Class or Representative Actions.

All Privacy Disputes shall be brought in the parties’ individual capacities only, and not as a plaintiff or class member in any purported class, collective, representative, orprivate attorney general proceeding, as more fully set forth in the Terms of Service.

20.4 Governing Law.

The governing law and venue provisions set forth in the Terms of Service shall apply to any Privacy Dispute to the extent not inconsistent with applicable privacy law.

21. BUSINESS-TO-BUSINESS AND PROFESSIONAL CONTACT INFORMATION

21.1 Business Contact Data.

To the extent permitted by applicable law, certain personal information we collect may relate to individuals acting in a business or professional capacity on behalf of a Client or other organization, such as name, business email address, business telephone number, job title, and company affiliation (“Business Contact Information”).

21.2 Use of Business Contact Information.

We use Business Contact Information solely for business-to-business purposes, including to:

(a) create and manage Client Accounts;
(b) communicate regarding job postings, Bookings, and Platform services;
(c) provide customer support and account administration;
(d) process subscriptions and billing; and
(e) comply with legal and regulatory obligations.

21.3 State Law B2B Exemptions.

To the extent applicable, certain state privacy laws, including the California Consumer Privacy Rights Act (“CPRA”), may provide limited or modified rights with respect to Business Contact Information. Where such exemptions apply, we will process Business Contact Information in accordance with those statutory provisions and any applicable implementing regulations.

21.4 No Use for Unrelated Marketing Without Consent.

We do not use Business Contact Information for unrelated third-party marketing purposes without consent, and we do not sell such information.

22. CONSENT DESIGN; NO DARK PATTERNS

22.1 Fair and Transparent Choice.

We design our privacy notices, consent mechanisms, and user interfaces to provide clear, meaningful, and easily understandable choices regarding the collection and use of personal information. We do not use deceptive, coercive, or manipulative design practices (“dark patterns”) to obtain consent or to discourage the exercise of privacy rights.

22.2 No Forced Consent.

Where consent is required by applicable law, we do not condition the provision of core Platform services on your consent to the processing of personal information that is not reasonably necessary to provide such services, except as permitted by law.

22.3 No Retaliation or Degradation of Service.

We do not deny, limit, or degrade the quality of the Platform, charge different prices, or provide a different level of service solely because you exercise your privacy rights or choose not to consent to optional data processing activities, except as permitted by applicable law.

22.4 Clear Withdrawal Mechanisms.

Where we rely on your consent to process personal information, we provide reasonable and accessible mechanisms for you to withdraw such consent at any time, and we honor such withdrawals in accordance with applicable law.

23. FINANCIAL INFORMATION AND PAYMENT DATA

23.1 Third-Party Payment Processing.

The Company does not directly collect, store, or process full credit card numbers, bank account numbers, or other complete financial account information. All subscription and billing payments are processed by third-party payment processors that are certified as compliant with the Payment Card Industry Data Security Standard (“PCI-DSS”).

23.2 Limited Transaction Data.

The Company may receive and store limited information related to payment transactions, such as the name of the cardholder, billing ZIP code, payment method type, transaction dates, subscription status, and unique payment tokens or identifiers, but not full card numbers or sensitive authentication data.

23.3 Security and Tokenization.

Payment processors use industry-standard encryption and tokenization technologies to protect financial information. The Company accesses only non-sensitive tokens and meta data necessary to manage subscriptions, process refunds (if any), prevent fraud, and maintain accounting records.

23.4 No Off-Platform Payment Responsibility.

The Company does not collect, transmit, hold, or control any payments exchanged between Talent and Clients in connection with Bookings or services performed. All such payments are handled directly between those parties outside of the Platform and are not subject to this Privacy Policy.