PRIVACY POLICY Pure Financial Academy Effective Date: 5/25/25

1. General Information and Jurisdiction

Pure Financial LLC ("Company" or "we" or "us" or "our") respects the privacy of its users ("user" or "you") that use our website located at purefinancialacademy.com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the "Website"). The following Company privacy policy ("Privacy Policy") is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

2. Controller Information and Contact Details

Data Controller: Pure Financial LLC
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Data Protection Officer: This email address is being protected from spambots. You need JavaScript enabled to view it.
Address: 6595 Roswell Rd. Ste G2515 Atlanta, GA 30328

3. Information We Collect and Legal Basis for Processing

3.1 Non-Personally-Identifying Information Collection "Non-Personally-Identifying Information" is information that, without the aid of additional information, cannot be directly associated with a specific person. "Personally-Identifying Information," by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user's Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for Company to determine from an IP address a user's Internet service provider and the geographic location of the visitor's point of connectivity as well as other statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users' experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

3.2 Legal Basis for Processing (GDPR Article 6) We process your personal information based on the following legal grounds:

• Contract Performance (Article 6(1)(b) GDPR): Providing educational services, processing payments, customer support, account management
• Legitimate Interests (Article 6(1)(f) GDPR): Website analytics, fraud prevention, license management, marketing to existing customers, security measures
• Consent (Article 6(1)(a) GDPR): Third-party marketing communications, non-essential cookies, newsletter subscriptions
• Legal Obligations (Article 6(1)(c) GDPR): Tax reporting, consumer protection compliance, legal record keeping

3.3 Purposes of Processing We process personal data for the following purposes: (1) delivering products and services you have requested; (2) managing your account and providing customer support; (3) communicating with you about products or services from us, our affiliates or third parties; (4) developing and displaying content and advertising tailored to your interests; (5) resolving disputes, collecting fees and troubleshooting; (6) measuring consumer interest in our services; (7) informing you of updates to our products or services; (8) customizing your experience; (9) detecting and protecting against error, fraud and other criminal activity; (10) enforcing our Terms of Use; and (11) as otherwise described to you at the point of collection. We may examine your Personally-Identifying Information across multiple users to identify problems or resolve disputes, and in particular we may examine your information to identify users using multiple User IDs or aliases. We may compare and review your Personally-Identifying Information for errors, omissions and accuracy.

4. Cookies, Web Beacons and Tracking Technologies

4.1 Web Cookies A "Web Cookie" is a string of information which assigns you a unique identification that a website stores on a user's computer, and that the user's browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users' experiences and to help Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used. COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

4.2 Web Beacons A "Web Beacon" is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users' Personally-Identifying Information. They are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

4.3 Analytics Services We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google's Ads Settings (www.google.com/settings/ads).

5. Data Sharing and Third Party Information

5.1 Aggregated and Non-Personally Identifying Information We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis.

5.2 Third-Party Service Providers We may share your Personally-Identifying Information, which may include your name and contact information (including email address and telephone number) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website's functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.

5.3 Third-Party Presenters We may share your Personally-Identifying Information, which may include your name and contact information (including email address and telephone number) with our authorized presenters that perform an in-person or virtual presentation hosted or sponsored by us. These authorized presenters may contact you for the purpose of promoting their products and/or services.

5.4 Contractor and Vendor Restrictions Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Company, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally-Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. Third-Party Presenters are not obligated to comply with this Privacy Policy with respect to Personally-Identifying Information provided to them as a result of an in-person or virtual presentation.

6. International Data Transfers

6.1 Transfer Mechanisms Your data may be transferred to the United States and other countries outside your jurisdiction. We ensure adequate protection through:

• EU-US Data Privacy Framework adequacy decision (adopted July 10, 2023) for transfers to participating U.S. companies
• Standard Contractual Clauses (SCCs) where applicable
• Appropriate technical and organizational safeguards for all international transfers

6.2 Safeguards All international transfers include appropriate security measures to protect your data during transit and storage.

7. Social Media Integration

We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook's "Like" or "Share" button, Twitter's "tweet" button, LinkedIn's "Share" button, that particular social network's plugin will be activated and your browser will directly connect to that provider's servers. If you do not use these buttons, none of your data will be sent to the respective social network's plugin provider. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control. Content such as forum discussions, reviews, blog posts, comments or articles from our site may be shared on social media outlets when a social plug-in is clicked. We encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

8. Specific Data Uses

8.1 License Management We save the licenses you've purchased or leased, the purchase date, the expiration date, the licensed product name, your license key, your computer's hardware ID and the number of computers you are allowed to use our products and services on. This information is used to allow you access to use our products and services and to limit piracy of such products and services.

8.2 Statistics and Communications Tracking We use cookies and collect IP addresses, geolocation, browser and operating system to store open and click statistics on our emails so we may improve our communication and see which types of newsletters and information is the most appreciated by our community.

9. Data Disclosure Circumstances

Company will disclose Personally-Identifying Information under the following circumstances:

9.1 By Law or to Protect Rights When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

9.2 Marketing Communications Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by clicking the unsubscribe link in the email communications or by contacting us using the contact information below.

9.3 Business Transfers and Bankruptcy Company reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Company's assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

10. Data Retention Periods

We retain personal information for the following periods:

• Account data: Retained while your account is active plus 7 years for legal compliance
• Payment data: Retained for 7 years for tax and legal purposes
• Marketing data: Retained until you withdraw consent
• Analytics data: Retained for 26 months (Google Analytics default)
• Support communications: Retained for 3 years
• License management data: Retained for duration of license plus 3 years

Data is securely deleted when retention periods expire or upon valid erasure requests, subject to legal obligations.

11. Your Rights Under Data Protection Laws

11.1 GDPR Rights (EU Residents) Under the General Data Protection Regulation, you have the following rights:

• Access (Article 15): Request a copy of your personal data and information about processing
• Rectification (Article 16): Correct inaccurate or incomplete personal data
• Erasure (Article 17): Request deletion of your personal data in certain circumstances
• Restriction (Article 18): Limit our processing of your personal data in specific situations
• Data Portability (Article 20): Receive your data in a structured, machine-readable format
• Object (Article 21): Object to processing based on legitimate interests or direct marketing
• Withdraw Consent: Withdraw consent for consent-based processing at any time

11.2 Right to Lodge a Complaint You have the right to lodge a complaint with a supervisory authority if you believe we have violated your data protection rights.

11.3 Exercising Your Rights Submit requests to This email address is being protected from spambots. You need JavaScript enabled to view it. with "Data Subject Request" in the subject line, including your full name, email address, and specific request. We respond within one month (extendable to three months for complex requests). We may request additional information to verify your identity before processing requests.

12. Account Management and Data Changes

You may at any time review or change your Personally-Identifying Information by going to your user profile (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally-Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.

13. Children's Privacy Protection

13.1 COPPA Compliance We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted.

13.2 GDPR Children's Protection For EU residents, we do not knowingly collect data from children under 16 (or the digital age of consent in your country) without parental consent.

13.3 Parental Rights If you are the parent or legal guardian of a child who has become a member of the Website or has otherwise transferred Personally-Identifying Information to the Website, please contact Company using our contact information below to have that child's account terminated and information deleted.

14. State Privacy Rights

14.1 California Privacy Rights California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

14.2 Do-Not-Track Policy Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.

15. Security and Data Protection

We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures. We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

16. Automated Decision-Making and Profiling

We may use automated systems for fraud detection and prevention, personalized course recommendations, and marketing segmentation. You have the right to object to automated decision-making that significantly affects you and request human review of such decisions.

17. Policy Updates and Changes

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company's Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

18. Governing Law and Contact Information

This Privacy Policy is governed by the laws of the State of Wyoming.

Privacy Officer: This email address is being protected from spambots. You need JavaScript enabled to view it.
General Support: This email address is being protected from spambots. You need JavaScript enabled to view it.