CREW GLOBAL PRIVACY POLICY

Privacy Policy for Crew Studio Ventures LLC

Version: 1.0

Effective Date: June 1, 2026

Company: Crew Studio Ventures LLC

Address: 30 N Gould St, Ste N, Sheridan, Wyoming 82801, United States

Contact Form: https://meet-crew.com/contact

Privacy Contact: privacy@meet-crew.com

Support Contact: support@meet-crew.com

Compliance Contact: compliance@meet-crew.com

This Privacy Policy explains how Crew Studio Ventures LLC (“Crew,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects personal information when you access or use the Crew mobile application, web application, websites, dashboards, APIs, platform features, lead and customer inquiry tools, campaign tools, payout request tools, operator tools, community tools, and related services.

This Privacy Policy applies to:

• Creators;
• Independent Agents;
• Independent Operators;
• Verified Independent Operators;
• Business Customers;
• Brand users;
• workspace users;
• platform visitors;
• support contacts;
• potential customers or interested persons submitting inquiries;
• recipients of communications;
• other individuals whose personal information is processed through the Platform.

This Privacy Policy should be read together with Crew’s Terms of Service, Deal Terms, Lead Privacy Notices, Data Processing Addenda, Joint Controller Terms, Subprocessor List, Cookie Notice, and any other applicable supplemental privacy notices.

1. IMPORTANT SUMMARY

Crew is a software platform for business and professional users. Crew provides tools for lead generation, customer inquiry distribution, performance campaigns, B2B marketing and sales operations, brand opportunities, campaign documentation, Platform Balance display, payout requests, Independent Operator tools, and related workflows.

Depending on the feature and context, Crew may act as:

• an independent controller;
• a processor or service provider;
• a joint controller;
• a platform provider;
• a technology provider;
• a data host;
• a documentation provider.

The relevant role depends on the actual processing activity, applicable law, and the relationship between Crew, Users, Business Customers, Independent Operators, Hyperplace, affiliated companies, service providers, and other recipients.

Crew may use automated and human-assisted systems to support matching, validation, routing, fraud prevention, quality review, payout review, and operational workflows. Crew uses human review where appropriate, especially for disputes, fraud signals, compliance questions, payout review, rejection review, and unclear or high-risk cases.

Crew generally retains operational account, lead, and inquiry data for up to 12 months where feasible, unless a longer retention period is legally required or reasonably necessary for consent documentation, accounting, tax, fraud prevention, compliance, dispute resolution, legal defense, or other legitimate purposes described in this Privacy Policy.

2. DEFINITIONS

For purposes of this Privacy Policy:

2.1 “Platform”

“Platform” means the Crew app, web app, websites, APIs, dashboards, tools, databases, workflows, communication features, inquiry tools, campaign tools, operator tools, payout request tools, and related services.

2.2 “User”

“User” means any person who accesses or uses the Platform.

2.3 “Creator”

“Creator” means a User who uses content, audience, community, online presence, offline presence, referrals, or other professional activity to participate in Deals, Brand opportunities, affiliate-like opportunities, customer inquiry generation, or campaign activities.

2.4 “Independent Agent”

“Independent Agent” means a User who independently generates, submits, documents, manages, validates, or supports customer inquiries, leads, campaign responses, or business opportunities through the Platform.

2.5 “Independent Operator” or “IO”

“Independent Operator” or “IO” means an independent business user who creates, invites, organizes, supports, or manages their own team, workspace, community, campaign group, session, or business structure using the Platform.

2.6 “Verified Independent Operator”

“Verified Independent Operator” means an Independent Operator approved by Crew for enhanced tools, permissions, workspace features, operator spend features, community growth features, or other advanced Platform functionality.

2.7 “Business Customer”

“Business Customer” means any business, company, Brand, partner, agency, energy company, installer, roofing company, sales organization, investment syndicate, service provider, or other professional customer that uses the Platform or receives customer inquiries, leads, campaign responses, data, services, or access through Crew.

2.8 “Customer Inquiry” or “Inquiry”

“Customer Inquiry” or “Inquiry” means information submitted by or on behalf of a potential customer, prospect, interested party, lead, homeowner, property owner, company, or other person or entity expressing potential interest in a product, service, consultation, offer, campaign, or Business Customer .

2.9 “Lead”

“Lead” means a Customer Inquiry or customer-related opportunity that may be submitted, documented, validated, matched, distributed, exported, or made available through the Platform.

2.10 “Personal Information”

“Personal Information” means information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked to an individual.

2.11 “Lead Privacy Notice”

“Lead Privacy Notice” means a notice shown to a potential customer or interested person before or during the submission, signature, OTP verification, consent confirmation, or finalization of a Customer Inquiry. It may describe the relevant recipients, recipient categories, processing purposes, contact channels, consent text, privacy text version, and related information.

3. INFORMATION WE COLLECT

Crew may collect the following categories of information.

3.1 Account Information

We may collect:

• name;
• email address;
• phone number;
• username;
• password or authentication credentials;
• profile photo;
• date of birth or age confirmation;
• address;
• country;
• language preference;
• account role;
• workspace membership;
• team membership;
• account settings;
• account status;
• acceptance records;
• login history.

3.2 Business and Professional Information

We may collect:

• business name;
• company role;
• business address;
• tax information;
• VAT or tax ID, where applicable;
• business registration information;
• professional category;
• role as Creator, Independent Agent, IO, Business Customer, or Brand user;
• social media profiles;
• website links;
• professional profile;
• campaign preferences;
• Deal participation history;
• performance metrics;
• quality metrics;
• rejection rates;
• payout history;
• Business Customer relationship data.

3.3 Verification and Compliance Information

Where required, we may collect:

• identity verification data;
• business verification data;
• tax forms;
• bank account verification data;
• fraud prevention data;
• compliance review notes;
• sanctions screening results;
• risk flags;
• documentation uploads;
• Deal acceptance records;
• consent logs;
• audit records.

3.4 Payment, Payout, and Platform Balance Information

We may collect and process:

• bank account information;
• payout method information;
• payout request information;
• approved Platform Balance;
• pending Platform Balance;
• payout history;
• transaction references;
• tax reporting information;
• payment provider identifiers;
• failed payment information;
• fee information;
• bank transfer records.

Crew does not treat Platform Balance as a bank account, stored value account, e-money account, deposit account, payment account, wallet, or financial product.

3.5 Customer Inquiry and Lead Data

Where a Customer Inquiry is submitted or processed through the Platform, we may collect:

name;

phone number;

email address;

address or location;

property information;

product interest;

service interest;

household or business information;

project information;

availability;

preferred contact method;

answers to qualification questions;

consent status;

OTP verification status;

signature status;

timestamp;

IP address;

user-agent;

device information;

Lead Privacy Notice version;

consent text version;

displayed consent text;

displayed privacy text;

signature or OTP reference;

recipient list or recipient category;

matching status;

lead status;

validation status;

rejection status;

Business Customer delivery status; CRM/API export status. Depending on the Deal or product category, additional information may be collected where necessary and legally permitted.

3.6 Energy/Solar-Related Inquiry Data

For restricted Energy or Solar-related inquiries, we may process information such as:

• ownership status;
• property type;
• roof type;
• roof condition;
• electricity consumption;
• location;
• technical feasibility indicators;
• regional availability;
• installer availability;
• customer interest confirmation;
• eligibility indicators;
• project timing;
• related qualification information.

3.7 Deal and Campaign Information

We may collect:

• Deal ID;
• Deal Terms version;
• accepted Deal Terms;
• campaign participation;
• submitted inquiries;
• submitted proof;
• documentation;
• payout trigger;
• validation status;
• rejection reason;
• Business Customer feedback;
• campaign performance data;
• allowed channel data;
• content usage data;
• disclosure confirmation;
• Brand or Business Customer approval records.

3.8 Content and Communications

We may collect:

• messages;
• support requests;
• comments;
• uploaded files;
• images;
• videos;
• screenshots;
• documents;
• forms;
• reports;
• content submissions;
• Brand materials;
• proof materials;
• community posts;
• workspace communications;
• complaint records;
• moderation records.

3.9 Device, Technical, and Usage Information

We may collect:

• IP address;
• device type;
• device identifiers;
• browser type;
• operating system;
• app version;
• language settings;
• time zone;
• log data;
• crash reports;
• feature usage;
• session data;
• authentication logs;
• API logs;
• CRM export logs;
• security logs;
• cookie or similar technology information.

3.10 Location Information

GPS or precise location tracking is not enabled by default. Where optional location features, check-ins, territory planning, or location documentation are enabled, we may process location-related information with appropriate notice and consent where required. Approximate location may be inferred from IP address, account information, inquiry information, or user-provided data.

3.11 Operator Spend Card Information

For selected Verified Independent Operators, we may process:

spend approval requests;

session name;

city/country;

start and end date;

purpose;

Deal or campaign reference;

expected participants;

requested budget;

approved budget;

merchant category;

transaction data;

receipt uploads;

booking confirmations;

provider information;

card usage logs;

misuse flags; reimbursement or recovery records. Crew does not use Operator Spend Card data to create personal repayment obligations for Creators or Independent Agents.

3.12 Cookies, Pixels, SDKs, and Tracking Technologies

Crew may collect information through cookies, SDKs, pixels, local storage, device identifiers, tags, scripts, and similar technologies.

This may include:

• session information;
• device and browser information;
• attribution data;
• advertising identifiers;
• campaign source data;
• conversion events;
• analytics events;
• product usage events;
• referral information;
• user preferences;
• authentication data;
• security data.

Where required by law, Crew will obtain consent or provide choices for non-essential cookies, advertising pixels, analytics SDKs, or similar technologies.

3.13 Information From Third Parties

We may receive information from:

• Business Customers;
• Hyperplace;
• Brands;
• Independent Operators;
• payment providers;
• card providers;
• identity verification providers;
• CRM systems;
• API integrations;
• analytics providers;
• hosting providers;
• support providers;
• app stores;
• advertising platforms;
• enrichment providers;
• public sources;
• other Users;
• customer recipients;
• law enforcement or authorities, where applicable.

4. HOW WE USE INFORMATION

Crew may use personal information for the following purposes.

4.1 Platform Operation

We use information to:

• create and manage accounts;
• authenticate Users;
• provide Platform features;
• manage roles and permissions;
• operate workspaces;
• provide dashboards;
• process Deal acceptance;
• provide documentation tools;
• provide inquiry tools;
• provide API, CSV, and CRM export features;
• provide Platform Balance display;
• process payout requests;
• provide support;
• maintain security.

4.2 Lead and Inquiry Processing

We use information to:

• collect Customer Inquiries;
• display and document Lead Privacy Notices;
• document consent;
• document OTP verification or signature confirmation;
• store consent text versions and displayed text;
• validate Inquiries;
• match Inquiries with Business Customers;
• route Inquiries;
• distribute Inquiries;
• export Inquiries through API, CSV, or CRM;
• make Inquiries available to Hyperplace or other Business Customers;
• verify validity;
• handle rejection windows;
• resolve disputes;
• document compliance;
• prevent fraud.

4.3 Matching and Distribution

We may use Inquiry data, Deal data, Business Customer data, region, product interest, capacity, availability, performance data, quality data, and Platform rules to match or distribute Inquiries. Matching may determine whether an Inquiry is exclusive, shared, routed, prioritized, or made available to one or more Business Customers.

Matching is primarily based on objective and business-relevant criteria, such as:

• the product or service requested by the potential customer;
• the information provided by the potential customer;
• the region, location, or service area;
• availability and capacity of Business Customers or partners;
• partner-defined acceptance criteria;
• product suitability;
• technical or operational feasibility;
• Deal Terms;
• consent and recipient disclosure records;
• lead status, validation status, and quality indicators;
• duplicate detection and fraud prevention signals.

For example, where a potential customer submits an inquiry, Crew may compare the customer’s information with the criteria provided by available Business Customers or partners. The system may filter potential recipients by region, availability, product category, eligibility, and other relevant requirements. Crew uses human review, manual checks, support review, compliance review, or Business Customer review where appropriate, especially in cases involving disputes, rejection decisions, fraud signals, unusual records, compliance questions, payout review, or unclear matching results.

4.4 Payouts and Platform Balance

We use information to:

• calculate pending or approved Platform Balance;
• determine payout eligibility;
• process payout requests;
• verify tax and bank information;
• comply with accounting requirements;
• prevent payout fraud;
• resolve disputes;
• document approvals and rejections.

4.5 Business Customer Services

We use information to:

• provide Business Customer dashboards;
• manage campaigns;
• deliver Inquiries;
• enable API/CSV/CRM exports;
• provide reporting;
• process billing;
• manage rejection windows;
• support compliance;
• manage Business Customer relationships.

4.6 Independent Operator Features

We use information to:

• verify Independent Operators;
• manage operator permissions;
• provide workspace and team tools;
• approve Operator Spend Card access;
• process spend approvals;
• review receipts;
• detect misuse;
• provide Community Growth Pool or operator bonus features;
• support community or session-related documentation.

4.7 Communications

We use information to:

• send service messages;
• respond to support requests;
• provide account notifications;
• provide Deal notifications;
• provide payout notifications;
• provide security alerts;
• provide compliance notices;
• contact Users about disputes, complaints, or incidents.

Marketing communications are sent only where permitted by law and may be subject to separate opt-in or unsubscribe rights.

4.8 Security, Fraud Prevention, and Compliance

We use information to:

• prevent fraud;
• detect fake Inquiries;
• detect duplicate submissions;
• prevent unauthorized access;
• detect account misuse;
• investigate suspicious activity;
• monitor compliance;
• enforce Terms;
• comply with law;
• respond to legal requests;
• protect Users, Business Customers, customers, and Crew.

4.9 Product Improvement and Analytics

We may use information to:

improve Platform features;

develop new features;

analyze usage;

measure campaign performance;

improve matching logic;

improve validation processes;

improve fraud prevention;

debug technical issues; improve user experience. Where possible, we use aggregated, anonymized, or pseudonymized information.

4.10 Advertising, Attribution, and Growth

Where permitted by law and subject to applicable consent requirements, Crew may use information to:

measure advertising performance;

attribute conversions;

analyze campaign sources;

optimize campaigns;

create or manage audiences;

measure referral programs;

understand growth channels; improve marketing efficiency. Non-essential advertising, tracking, analytics, or attribution technologies may be subject to cookie consent, opt-in, opt-out, or similar choices where required.

4.11 Legal and Administrative Purposes

We use information to:

• comply with tax, accounting, corporate, and legal obligations;
• establish, exercise, or defend legal claims;
• respond to regulators, courts, or authorities;
• maintain business records;
• manage corporate transactions;
• enforce contracts.

5. LEGAL BASES FOR PROCESSING

For individuals in the EU, EEA, UK, or Switzerland, our legal bases may include the following.

5.1 Contract Performance

We process information where necessary to provide the Platform, accounts, Deals, Platform Balance, payout requests, Business Customer services, and related features.

5.2 Legitimate Interests

We process information based on legitimate interests, including:

• operating the Platform;
• preventing fraud;
• securing accounts;
• improving services;
• managing business relationships;
• processing Inquiries;
• matching Inquiries;
• documenting consent;
• handling disputes;
• enforcing Terms;
• supporting Business Customers;
• supporting Users;
• maintaining legal records;
• analyzing product usage;
• protecting the Platform and its users.

We balance these interests against the rights and freedoms of affected individuals.

5.3 Consent

We may rely on consent for:

• certain marketing communications;
• certain customer contact permissions;
• certain OTP or signature confirmations;
• optional location features;
• optional cookies, pixels, SDKs, analytics, or advertising technologies where required;
• specific data sharing or recipient disclosure;
• specific Deal or Inquiry submissions.

Consent can be withdrawn where legally available, but withdrawal does not affect prior lawful processing.

5.4 Legal Obligation

We process information to comply with tax, accounting, regulatory, sanctions, data protection, consumer protection, corporate, and legal obligations.

5.5 Vital Interests or Public Interest

In rare cases, we may process information to protect vital interests or comply with public interest obligations where legally applicable.

6. HOW WE SHARE INFORMATION

Crew may share information as described below.

6.1 Business Customers and Inquiry Recipients

We may share Customer Inquiry data with Business Customers, Hyperplace, partners, installers, service providers, or other recipients where permitted by Deal Terms, consent records, Lead Privacy Notices, recipient disclosures, or applicable law. For certain Level 1 and Level 2 Users, Hyperplace may act as the standard Lead or Inquiry recipient and may further route Inquiries to one or more suitable companies, depending on product category, region, availability, matching, and consent records.

6.2 Independent Operators and Workspaces

Where you join a workspace, team, session, community, or Independent Operator structure, certain profile, activity, Deal, documentation, performance, or team-related information may be visible to the relevant Independent Operator or workspace administrators.

6.3 Business Customer Dashboards, API, CSV, and CRM Exports

Business Customers may receive data through dashboards, API, CSV, CRM integrations, webhooks, manual exports, or other approved delivery methods. Business Customers are responsible for their own use, storage, protection, deletion, legal basis, customer contact, and onward transfer of exported data.

6.4 Service Providers, Subprocessors, and Technology Partners

We may share information with service providers, subprocessors, technology providers, and business tools that help us operate, secure, improve, automate, analyze, and support the Platform. These providers may process personal information on behalf of Crew or in connection with services used by Crew, depending on the relevant feature, processing activity, jurisdiction, contractual setup, and data protection role. Crew may use providers in the following categories.

6.4.1 Hosting, Cloud Infrastructure, Databases, and Deployment

Crew may use hosting, cloud infrastructure, database, storage, backend, deployment, and server

providers, including:

• Amazon Web Services (AWS);
• Google Cloud and Google Services;
• Vercel;
• Supabase.

These providers may process account data, technical data, log data, customer inquiry data, lead data, workspace data, platform data, API data, files, database records, authentication data, and related operational data.

6.4.2 Automation, Data Pipelines, AI Infrastructure, and Workflow Tools

Crew may use automation, workflow, AI infrastructure, orchestration, model, enrichment, and data

processing tools, including:

• n8n;
• LangChain;
• OpenAI;
• Anthropic;
• Langdock;
• Pecan AI;
• Cohere AI;
• Segment.io.

These providers may process data necessary to automate workflows, support AI-assisted features, generate summaries, classify records, assist with matching, analyze operational data, support product functionality, improve workflows, and provide internal or customer-facing Platform features. Crew does not intend to make legally significant decisions about individuals solely by automated means without appropriate human review where required by law.

6.4.3 Analytics, Product Intelligence, Business Intelligence, and Reporting

Crew may use analytics, reporting, product intelligence, and business intelligence tools, including:

• Amplitude;
• Google Analytics;
• Umami Analytics;
• Tableau;
• Adobe;
• Segment.io.

These providers may process usage data, event data, device data, session data, product interaction data, campaign performance data, aggregated statistics, reporting data, and related analytics information. Where required by law, Crew will obtain consent or provide choices for non-essential analytics, cookies, SDKs, pixels, or similar technologies.

6.4.4 Communication, Telephony, Messaging, Email, and Customer Engagement

Crew may use communication, telephony, messaging, outreach, CRM, email, and customer

engagement tools, including:

• Twilio;
• Outreach.io;
• Apollo.io;
• Aircall;
• ActiveCampaign;
• Attio.

These providers may process contact data, communication data, call metadata, message data, email data, CRM data, lead status data, campaign data, support data, and related customer or user communication records.

6.4.5 Advertising, Marketing, Attribution, and Growth Tools

Crew may use advertising, attribution, marketing, campaign, and growth tools, including:

• Meta Ads;
• Google Ads;
• Taboola Ads;
• TikTok Ads;
• Cello.so;
• Ocean.io;
• Apollo.io;
• ActiveCampaign;
• Google Analytics;
• Segment.io.

These providers may process campaign data, audience data, conversion data, attribution data, lead source data, advertising identifiers, cookie or pixel data, and related marketing performance information, subject to applicable consent and legal requirements.

6.4.6 Payment, Billing, Payout, and Financial Operations

Crew may use payment, billing, payout, and financial service providers, including:

• Stripe;
• banking, card, payout, and payment providers used by Crew from time to time.

These providers may process payout data, payment method data, transaction data, billing records, tax- related data, bank account information, payment identifiers, fraud prevention data, and financial compliance information.

6.4.7 Sales, CRM, Enrichment, and Business Data Providers

Crew may use sales, CRM, enrichment, and business data providers, including:

• Apollo.io;
• Ocean.io;
• Outreach.io;
• Attio;
• QUO.

These providers may process business contact data, company data, lead data, sales activity data, CRM records, enrichment data, outreach records, and related business development information.

6.4.8 Updates to Provider List

Crew may update the list of subprocessors, service providers, and technology partners from time to time as the Platform evolves. Where required by law or contract, Crew will provide notice of material changes or maintain a separate Subprocessor List.

6.5 Hyperplace and Affiliated Companies

We may share information with Hyperplace or other affiliated companies where they act as Business Customers, Lead recipients, campaign participants, service providers, or affiliated business partners. Such sharing will be governed by applicable Deal Terms, Lead Privacy Notices, Privacy Notices, Data Processing Terms, Joint Controller Terms, or other agreements where required.

6.6 Legal and Compliance

We may share information where we believe necessary to:

• comply with law;
• respond to legal requests;
• cooperate with authorities;
• enforce Terms;
• prevent fraud;
• protect rights, safety, and security;
• investigate misconduct;
• defend legal claims.

6.7 Corporate Transactions

We may share information in connection with a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar corporate transaction.

6.8 With Your Direction

We may share information when you instruct us to do so, accept Deal Terms, submit an Inquiry, connect a CRM, invite a User, join a workspace, request payout, or otherwise use Platform features that involve sharing.

7. INTERNATIONAL DATA TRANSFERS AND TRANSFER SAFEGUARDS

Crew Studio Ventures LLC is based in the United States. Crew may process, access, store, or transfer personal information in the United States, the European Union, the United Kingdom, Switzerland, and other countries where Crew, its affiliates, service providers, subprocessors, business partners, or technology providers operate. Where personal information from the EU, EEA, UK, or Switzerland is transferred to a country that has not been recognized as providing an adequate level of data protection, Crew will use appropriate

safeguards where required by law. These safeguards may include:

EU Standard Contractual Clauses;

the UK International Data Transfer Addendum or UK International Data Transfer Agreement;

Swiss data transfer terms where applicable;

Data Processing Addenda;

transfer risk assessments;

contractual restrictions on access and use;

encryption in transit and, where appropriate, at rest;

access controls and authentication;

logging and monitoring;

data minimization;

pseudonymization or aggregation where appropriate;

EU or regional hosting options where technically and commercially feasible; vendor due diligence and subprocessor review. EU-related customer inquiry and lead data may be hosted on European infrastructure where applicable and technically feasible. However, the location of a server does not by itself determine whether international transfer rules apply, because remote access, support, subprocessors, affiliates, and provider infrastructure may still involve international transfers. Crew may make additional information about transfer safeguards available upon request where required by applicable law or contract.

8. DATA RETENTION

Crew retains personal information for as long as necessary for the purposes described in this Privacy Policy.

8.1 General Retention Principle

Operational account data, lead data, and inquiry data are generally retained for up to 12 months where feasible, unless a longer retention period is legally required or reasonably necessary for legal, accounting, tax, payout, consent, fraud prevention, compliance, dispute resolution, audit, data protection, or legal defense purposes.

8.2 Account Data

Operational account data is generally deleted or anonymized within 12 months after account deletion, unless longer retention is legally required or reasonably necessary.

8.3 Lead and Inquiry Data

Lead and Inquiry data is generally retained for up to 12 months for operational purposes, unless a longer period is legally required or reasonably necessary for consent documentation, payout review, Business Customer disputes, rejection review, fraud prevention, compliance review, regulatory obligations, audit, data protection, or legal defense.

8.4 Consent Records and Lead Privacy Notice Logs

Consent, OTP, signature, recipient disclosure, Lead Privacy Notice, accepted text, displayed text, Deal acceptance, and audit records may be retained as long as required or reasonably necessary to demonstrate compliance, respond to disputes, support legal claims, or defend against legal claims. Where feasible, such records may be pseudonymized, minimized, archived, or separated from active operational systems.

8.5 Payout and Accounting Records

Payout, tax, billing, accounting, and financial records may be retained for the legally required retention period.

8.6 Security and Fraud Records

Security logs, fraud prevention records, abuse records, and enforcement records may be retained as long as necessary to protect the Platform, Users, Business Customers, customers, and legal rights.

8.7 Operator Spend Card Records

Operator Spend Card records may be retained as long as necessary for accounting, fraud prevention, audit, dispute resolution, compliance, or legal defense purposes.

8.8 Support Records

Support records may be retained as long as necessary for support, dispute resolution, compliance, internal quality review, or legal defense purposes.

8.9 Deletion and Anonymization

When information is no longer needed, Crew will delete, anonymize, aggregate, or securely archive it according to applicable law and internal retention rules.

9. YOUR RIGHTS

Depending on your location, you may have rights regarding your personal information.

These rights may include:

• access;
• correction;
• deletion;
• restriction;
• objection;
• data portability;
• withdrawal of consent;
• opt-out of certain processing;
• appeal of certain decisions;
• complaint to a supervisory authority.

To exercise privacy rights, contact privacy@meet-crew.com or use https://meet-crew.com/contact. We may need to verify your identity before fulfilling a request. Some data may be retained where legally required or reasonably necessary for legal, accounting, tax, fraud prevention, compliance, dispute, or legal defense purposes.

10. EU/EEA, UK, AND SWITZERLAND RIGHTS

If you are located in the EU, EEA, UK, or Switzerland, you may have additional rights under applicable data protection law.

You may have the right to:

• request access to your personal data;
• request correction;
• request deletion;
• request restriction;
• object to processing based on legitimate interests;
• request data portability;
• withdraw consent;
• lodge a complaint with a supervisory authority.

Where Crew acts as a processor for another controller, we may forward your request to the relevant controller or ask you to contact that controller directly.

11. U.S. STATE PRIVACY RIGHTS

If you are located in a U.S. state with privacy laws that apply to Crew, you may have additional rights,

such as:

right to know/access;

right to delete;

right to correct;

right to opt out of certain sharing or targeted advertising;

right to data portability; right not to be discriminated against for exercising privacy rights. Crew will provide additional notices where legally required. Crew does not knowingly sell personal information of minors.

12. COOKIES AND SIMILAR TECHNOLOGIES

Crew may use cookies, SDKs, pixels, local storage, device identifiers, tags, scripts, and similar

technologies to:

operate the Platform;

authenticate Users;

remember preferences;

analyze usage;

improve performance;

prevent fraud;

secure accounts;

support campaigns;

measure functionality;

attribute conversions; improve advertising and growth activities. Where required, Crew will provide cookie choices or obtain consent. Non-essential analytics, advertising, attribution, retargeting, or marketing technologies may be subject to additional choices, opt-in, opt-out, or consent requirements depending on your location and applicable law.

13. SECURITY

Crew uses technical and organizational measures designed to protect personal information, including access controls, authentication, encryption where appropriate, logging, monitoring, provider security controls, and internal policies. No system is completely secure. Users are responsible for securing their accounts, devices, passwords, API keys, CRM integrations, exports, and local copies of data.

14. CHILDREN

The Platform is not intended for individuals under 18. Crew does not knowingly allow individuals under 18 to create accounts or use the Platform. If we learn that a person under 18 has provided personal information, we may delete the information and terminate the account.

15. MARKETING COMMUNICATIONS

Crew may send service-related communications necessary for account, Platform, Deal, security, payout, or compliance purposes. Crew may send marketing communications where permitted by law. You may opt out of marketing communications by following unsubscribe instructions or contacting us. Opting out of marketing does not stop service-related communications.

16. CUSTOMER CONTACT AND COMMUNICATION CONSENT

Where Customer Inquiries involve phone, email, SMS, WhatsApp, or other contact channels, Crew, Hyperplace, Business Customers, or recipients may rely on the applicable consent record, Deal Terms, Lead Privacy Notice, privacy notice, or other lawful basis. Business Customers and recipients are responsible for complying with applicable communication, anti-spam, telemarketing, consumer protection, and data protection laws when contacting customers. Crew may document customer contact permissions through OTP verification, signature confirmation, consent checkbox, timestamp, IP address, user-agent, consent text version, displayed text, recipient list, recipient category, or other consent and audit records.

17. AUTOMATED PROCESSING, MATCHING, AND HUMAN REVIEW

Crew may use automated or semi-automated systems to:

• match Inquiries;
• prioritize recipients;
• detect duplicates;
• validate required fields;
• identify fraud risk;
• calculate Platform Balance;
• support Business Customer routing;
• support quality scoring;
• recommend Deals;
• detect compliance issues.

Crew may use automated and human-assisted systems to support matching, routing, validation, prioritization, and distribution of Customer Inquiries.

Matching is primarily based on objective and business-relevant criteria, such as:

• the product or service requested by the potential customer;
• the information provided by the potential customer;
• the region, location, or service area;
• availability and capacity of Business Customers or partners;
• partner-defined acceptance criteria;
• product suitability;
• technical or operational feasibility;
• Deal Terms;
• consent and recipient disclosure records;
• lead status, validation status, and quality indicators;
• duplicate detection and fraud prevention signals.

For example, where a potential customer submits an inquiry, Crew may compare the customer’s information with the criteria provided by available Business Customers or partners. The system may filter potential recipients by region, availability, product category, eligibility, and other relevant requirements. Crew uses human review, manual checks, support review, compliance review, or Business Customer review where appropriate, especially in cases involving disputes, rejection decisions, fraud signals, unusual records, compliance questions, payout review, or unclear matching results. Where required by law, Crew will provide additional information or rights related to automated decision-making. Crew does not intend to make decisions that produce legal or similarly significant effects concerning individuals solely by automated means without appropriate safeguards where required by law.

18. APP STORE AND PLATFORM FEATURES

The Platform may be distributed through Apple App Store, Google Play, or other app stores. App store providers may process information under their own terms and privacy policies. Crew may provide in-app account deletion, reporting, support, moderation, and other features where required by app store rules or applicable law.

19. REPORTING, MODERATION, AND COMPLAINTS

Crew may provide tools or contact channels for reporting misuse, illegal content, fraud, data concerns, prohibited Deals, harassment, misleading claims, intellectual property concerns, account abuse, or other safety and compliance issues. Reports may be submitted through the Platform, through available reporting features, through https://meet-crew.com/contact, or by contacting compliance@meet-crew.com. Crew may collect and process information related to reports, moderation decisions, complaints, appeals, enforcement actions, reviewer notes, timestamps, account records, affected content, affected Deals, affected Inquiries, and related evidence. Crew may review, restrict, remove, suspend, disable, or limit accounts, Content, Deals, Inquiries, exports, roles, payouts, Platform Balance, or Platform features where Crew believes this is necessary to protect Users, Business Customers, customers, legal compliance, app store compliance, data protection, brand safety, platform integrity, or third-party rights. Where required by law or offered by Crew, affected Users may submit a complaint or appeal regarding certain moderation, suspension, restriction, or removal decisions.

20. CHANGES TO THIS PRIVACY POLICY

Crew may update this Privacy Policy from time to time. We may notify you through the Platform, email, website posting, app notification, or other reasonable means. The updated Privacy Policy becomes effective on the date stated in the updated version.

21. CONTACT US

For privacy questions, requests, complaints, or concerns, contact:

Crew Studio Ventures LLC 30 N Gould St, Ste N Sheridan, Wyoming 82801 United States

Privacy Contact: privacy@meet-crew.com

Support Contact: support@meet-crew.com

Compliance Contact: compliance@meet-crew.com

Contact Form: https://meet-crew.com/contact

SCHEDULE 1 — DATA ROLE FRAMEWORK

This Schedule provides general guidance. The actual data protection role depends on the specific processing activity.

1. CREW AS CONTROLLER

Crew may act as controller for:

• account management;
• Platform security;
• fraud prevention;
• verification;
• support;
• payout records;
• Platform Balance;
• Operator Spend Card administration;
• Deal acceptance logs;
• consent and Lead Privacy Notice logs;
• compliance records;
• analytics;
• account deletion;
• legal claims;
• business administration.

2. CREW AS PROCESSOR

Crew may act as processor where a User, Independent Operator, or Business Customer uses Crew primarily as a software tool to store, manage, or process data under that party’s instructions.

Examples may include:

• CRM-like storage for a User;
• workspace data hosted for an Independent Operator;
• Business Customer campaign data processed under instructions;
• certain API/CRM integration scenarios.

3. CREW AS JOINT CONTROLLER

Crew may act as joint controller where Crew and another party jointly determine purposes and means of processing.

Examples may include certain:

• campaign matching scenarios;
• shared Inquiry distribution scenarios;
• joint lead processing with Hyperplace or Business Customers;
• recipient matching workflows;
• consent and distribution logic.

4. RECIPIENTS AS SEPARATE CONTROLLERS

Business Customers receiving Customer Inquiries may act as separate controllers for their own use of the data, including contacting customers, managing sales processes, and storing data in their own CRM.

5. REQUIRED AGREEMENTS

Where required, Crew may enter into:

• Data Processing Addendum;
• Joint Controller Addendum;
• Standard Contractual Clauses;
• UK Addendum;
• Swiss transfer terms;
• Subprocessor terms;
• Business Customer privacy terms;
• other required agreements.

SCHEDULE 2 — CATEGORIES OF RECIPIENTS

Personal information may be shared with:

• Business Customers;
• Hyperplace;
• Brands;
• Independent Operators;
• workspace administrators;
• payment providers;
• banking providers;
• card providers;
• hosting providers;
• cloud providers;
• database providers;
• analytics providers;
• advertising platforms;
• attribution providers;
• AI providers;
• automation providers;
• email providers;
• telephony providers;
• messaging providers;
• CRM providers;
• API integration providers;
• enrichment providers;
• support providers;
• legal and compliance advisors;
• tax and accounting providers;
• authorities where required;
• other recipients authorized by the User or applicable terms.

SCHEDULE 3 — GENERAL RETENTION SUMMARY

SCHEDULE 4 — SUBPROCESSORS, SERVICE PROVIDERS, AND TECHNOLOGY PARTNERS

Crew may use third-party service providers, subprocessors, technology partners, and business tools to operate, secure, improve, automate, analyze, and support the Platform.

The following list may change over time. The specific providers used for a particular User, Customer Inquiry, Deal, Business Customer, country, or feature may depend on the relevant functionality, configuration, region, and processing activity.

1. Hosting, Cloud Infrastructure, Databases, and Deployment

• Amazon Web Services (AWS);
• Google Cloud / Google Services;
• Vercel;
• Supabase.

2. Automation, AI, Workflow, and Data Infrastructure

• n8n;
• LangChain;
• OpenAI;
• Anthropic;
• Langdock;
• Pecan AI;
• Cohere AI;
• Segment.io.

3. Analytics, Product Intelligence, and Business Intelligence

• Amplitude;
• Google Analytics;
• Umami Analytics;
• Tableau;
• Adobe;
• Segment.io.

4. Communication, Telephony, Messaging, Email, and Customer Engagement

• Twilio;
• Outreach.io;
• Apollo.io;
• Aircall;
• ActiveCampaign;
• Attio.

5. Advertising, Marketing, Attribution, and Growth

• Meta Ads;
• Google Ads;
• Taboola Ads;
• TikTok Ads;
• Cello.so;
• Ocean.io;
• Apollo.io;
• ActiveCampaign;
• Google Analytics;
• Segment.io.

6. Payment, Billing, Payout, and Financial Operations

• Stripe;
• banking, card, payout, and payment providers used by Crew from time to time.

7. Sales, CRM, Enrichment, and Business Data

• Apollo.io;
• Ocean.io;
• Outreach.io;
• Attio;
• QUO.

Crew may update this list from time to time. Where required by law or contract, Crew will provide notice of material changes or maintain a separate Subprocessor List.

SCHEDULE 5 — CONTACT AND RIGHTS REQUESTS

To exercise privacy rights, submit:

• name;
• email;
• account identifier, if applicable;
• country;
• request type;
• description of request;
• verification information if required.

Send requests to:

privacy@meet-crew.com or https://meet-crew.com/contact