LUZOLVA LLC — PRIVACY POLICY

Last Updated: July 23, 2026

LUZOLVA LLC ("Luzolva," "we," "us," or "our") is a Wyoming limited liability company that operates a strategic ecosystem connecting content creators, influencers, and "opinion leaders" ("Creators," "you") with institutional and corporate clients, and that provides a Publisher Catalog & Ad Matching Service connecting website and blog owners ("Publishers") with high-paying commercial advertisers. This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you visit our website, register through our Know Your Creator (KYC) onboarding, apply to become a Talent, request a Strategic Consultation, list your platform in our Publisher Catalog, or otherwise interact with our services (collectively, the "Services").

This Policy is designed to comply with applicable data protection laws across the jurisdictions in which our Creators, clients, and audiences are located, including but not limited to:

• European Union / EEA & United Kingdom — the General Data Protection Regulation (GDPR) and UK GDPR / Data Protection Act 2018

• Canada — the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws

• United States — the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA) and other applicable state privacy laws (e.g., Virginia CDPA, Colorado CPA, Connecticut CTDPA, Utah UCPA)

• Africa — South Africa's Protection of Personal Information Act (POPIA), Nigeria's Data Protection Act (NDPA), and other applicable national data protection laws

• Asia — Singapore's Personal Data Protection Act (PDPA), and other applicable regional frameworks

• Australia — the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)

• Brazil — Lei Geral de Proteção de Dados (LGPD), where applicable

Where local law imposes stricter requirements than this Policy, the stricter requirement governs.

1. Who We Are

Data Controller: Luzolva LLC, a Wyoming limited liability company. Registered Agent: Northwest Registered Agent Service Inc, 30 N Gould St Ste N, Sheridan, WY 82801, USA. Contact for privacy matters: contact@luzolva.com Phone / WhatsApp: +1 (402) 816-0759 (official company number, also available on WhatsApp)

If you are located in the EEA, UK, or other jurisdictions that require a local representative, and we do not yet have one designated, please contact us directly using the details above and we will respond in accordance with applicable law.

2. Personal Data We Collect

We collect personal data directly from you, automatically through your use of the Services, and, where applicable, from third parties (such as social media platforms or analytics tools you connect or upload data from).

2.1 Identity & Contact Data

Legal first and last name, creator/stage name, email address, phone/WhatsApp number, country and city of residence, company name and registration number (if you operate as a registered entity), and signature/consent records.

2.2 Commercial & Financial Data

Operational status (sole proprietor, registered company, or agency-represented), estimated or custom baseline campaign rates, currency preference, exclusivity arrangements, and content category exclusions.

2.3 Digital Footprint & Audience Data

Social media handles and profile links (including but not limited to TikTok, Instagram, YouTube, LinkedIn, X, Threads, Telegram, Discord, Reddit, Snapchat, Twitch, Pinterest, and podcast platforms), content language(s), content niches, follower counts, audience location and age demographics, and media kits.

2.4 Verification & Analytics Files

Screenshots, PDFs, or other files you upload to verify your reach, engagement, or audience demographics (e.g., backend analytics dashboards).

2.5 Technical & Usage Data

IP address, browser and device type, operating system, referring URLs, pages viewed, time stamps, and similar data collected automatically via cookies and similar technologies when you browse our website (see Section 8).

2.6 Communications

Records of correspondence, support requests, and negotiation history conducted through our contact channels.

We do not intentionally collect special categories of personal data (e.g., health, religious belief, political opinion, sexual orientation) unless you voluntarily disclose such information as part of your content niche selections (for example, indicating a "Religion & Spirituality" or "Government & Politics" content category). Where you provide such information, you do so voluntarily and consent to its processing strictly for the purpose of campaign and brand matching described below.

3. How We Use Personal Data

We use personal data for the following purposes:

Purpose Examples Onboarding & account administration Verifying your identity, processing your KYC submission, creating your Creator profile Brand & campaign matching Aligning your niche, audience, and reach with corporate or institutional client campaigns ("The Pack Effect") Contract & commercial management Negotiating rates, issuing counter-offers, executing campaign agreements, processing payments Communication Responding to inquiries, sending campaign opportunities, service updates, and administrative notices Publisher Catalog & Ad Matching Onboarding Publishers into our catalog, analyzing site audience data, pitching and matching verified ad campaigns, managing ad placements, tracking performance, and distributing revenue to Publishers Security & fraud prevention Detecting and preventing fraud, unauthorized access, and misuse of our Services Legal compliance Meeting tax, accounting, anti-fraud, and regulatory obligations across applicable jurisdictions Analytics & improvement Understanding aggregate usage trends to improve our Services and matching technology

3.1 Legal Bases (EEA/UK GDPR)

Where GDPR applies, we rely on one or more of the following legal bases: performance of a contract (onboarding and campaign management), consent (e.g., uploading verification files, sharing voluntary niche information, marketing communications), legitimate interests (fraud prevention, service improvement, business development), and legal obligation (tax and regulatory recordkeeping). You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. How We Share Personal Data

We do not sell your personal contact or legal information. We share personal data only as follows:

• Corporate & institutional clients: We share aggregated and anonymized demographic and performance metrics with potential brand partners for campaign matching purposes. Your personal contact details and legal identity information remain confidential and are not disclosed to clients unless and until a campaign contract is executed and disclosure is necessary to perform that contract.

• Service providers: Hosting providers, payment processors, identity verification tools, analytics providers, and customer support platforms, each bound by confidentiality and data protection obligations.

• Professional advisors: Legal, accounting, and insurance advisors as needed to operate our business.

• Legal & regulatory disclosures: Where required by law, court order, or governmental request, or to protect the rights, property, or safety of Luzolva, our Creators, or the public.

• Business transfers: In connection with a merger, acquisition, financing, or sale of assets, subject to confidentiality safeguards.

We require all third parties to respect the security of personal data and to treat it in accordance with applicable law. We do not permit our service providers to use your data for their own independent marketing purposes.

5. International Data Transfers

Luzolva is based in the United States, and our Creators, clients, and audiences are located worldwide. As a result, personal data may be transferred to, stored, and processed in countries other than your own, including the United States, which may not offer the same level of data protection as your home jurisdiction.

Where we transfer personal data from the EEA, UK, or Switzerland to a country not deemed to provide an adequate level of protection, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, or other legally recognized transfer mechanisms. For transfers from other jurisdictions (e.g., Canada, South Africa, Australia, Asia), we implement comparable contractual and technical safeguards consistent with local law.

You may contact us for more information about the safeguards we have in place for a specific transfer.

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, including:

• For active Creators and clients: for the duration of the business relationship and a reasonable period thereafter to handle disputes, enforce contracts, and meet legal/tax obligations (generally up to 7 years following the end of the relationship, unless a longer period is required by law).

• For unsuccessful or abandoned KYC applications: generally up to 24 months, after which data is deleted or anonymized unless you re-engage with us.

• For website analytics and cookie data: as described in our cookie settings, typically no longer than 26 months.

We may retain anonymized or aggregated data indefinitely, as it no longer constitutes personal data.

7. Your Privacy Rights

Depending on your location, you may have some or all of the following rights regarding your personal data:

• Access — obtain a copy of the personal data we hold about you.

• Rectification / Correction — correct inaccurate or incomplete data.

• Erasure / Deletion — request deletion of your data, subject to legal exceptions.

• Restriction — limit how we process your data in certain circumstances.

• Portability — receive your data in a structured, machine-readable format.

• Objection — object to processing based on legitimate interests or for direct marketing.

• Withdraw consent — where processing is based on consent.

• Opt out of "sale" or "sharing" — under U.S. state laws such as the CCPA/CPRA, you have the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising. Luzolva does not sell personal information as defined under these laws, and any sharing of aggregated/anonymized metrics with clients does not involve the disclosure of identifiable contact or legal information.

• Non-discrimination — we will not discriminate against you for exercising your privacy rights.

• Lodge a complaint — with your local data protection authority (e.g., an EU/EEA supervisory authority, the UK Information Commissioner's Office, the Office of the Privacy Commissioner of Canada, South Africa's Information Regulator, or the Office of the Australian Information Commissioner).

To exercise any of these rights, contact us at the email address listed in Section 1. We will respond within the timeframe required by applicable law (typically 30 days, or 45 days for California residents, extendable where permitted). We may need to verify your identity before processing your request.

8. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to operate core functionality, remember preferences, measure performance, and support our advertising matching and Publisher monetization services. Categories of cookies we may use include:

• Strictly necessary cookies — required for the website to function.

• Performance/analytics cookies — help us understand how visitors use our site.

• Functional cookies — remember your preferences.

• Advertising cookies — support our Publisher Catalog & Ad Matching Service, measure campaign ROI for advertisers, and enable accurate revenue tracking and distribution for Publishers.

Where required by law (e.g., EEA/UK, and certain other jurisdictions), we will request your consent before placing non-essential cookies, via a cookie banner or preference center. You can manage or withdraw cookie consent at any time through your browser settings or our cookie preference tool.

9. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encryption in transit, access controls, and secure file-upload handling for analytics verification documents. No system is completely secure, and we encourage you to use strong passwords and protect your account credentials.

In the event of a data breach affecting your personal data, we will notify you and the relevant regulators as required by applicable law (e.g., within 72 hours under GDPR where feasible).

10. Children's Privacy

Our Services are intended for individuals who are at least 18 years old, or the age of majority in their jurisdiction, and are not directed at children. We do not knowingly collect personal data from individuals under this age threshold. If we learn that we have inadvertently collected data from a minor, we will take steps to delete it promptly. Parents or guardians who believe a minor has provided us with personal data should contact us using the details in Section 1.

11. Automated Decision-Making

We may use automated tools to assist in matching Creator profiles with relevant brand campaigns based on niche, audience, and reach data. These tools support, but do not replace, human decision-making in final campaign selection and commercial negotiations. You have the right to request human review of, and to contest, any decision that produces legal or similarly significant effects on you and is based solely on automated processing.

12. Third-Party Links & Platforms

Our Services may reference or link to third-party social media platforms (TikTok, Instagram, YouTube, etc.) and Publisher websites listed in our catalog. We are not responsible for the privacy practices of these third parties. We encourage you to review their respective privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will post the updated version on our website with a revised "Last Updated" date and, where required by law, will provide additional notice or seek renewed consent for material changes.

14. Contact Us

For questions, requests, or complaints about this Privacy Policy or our data practices, please contact:

Luzolva LLC Email: contact@luzolva.com Phone / WhatsApp: +1 (402) 816-0759

Registered Agent (Wyoming): Northwest Registered Agent Service Inc, 30 N Gould St Ste N, Sheridan, WY 82801, USA