Last revised: June 11, 2025 Thank you for visiting the online services (the “Site”) operated by Cogent Digital, LLC, a Delaware limited liability company with its principal place of business in Cottonwood, Arizona USA (collectively, “Cogent Digital,” “we,” “our,” or “us”). We respect your privacy and are committed to protecting your personal data in compliance with:

• the EU & UK General Data Protection Regulation (collectively, “GDPR”);
• the ePrivacy Directive and evolving EU/UK cookie‑consent requirements;
• the California Consumer Privacy Act and its amendment, the California Privacy Rights Act (together, “CCPA”);
• and other applicable privacy laws (jointly, the “Privacy Laws”).

By accessing or using the Site, you acknowledge that you have read and understood this Privacy & Cookie Policy (the “Policy”). If you do not agree, please do not use the Site. We may update this Policy from time to time; material changes will be announced on the Site and, where required, via additional notice or consent.

1. Personal Data We Collect

* Under GDPR we rely on the legal bases shown above; where consent is relied upon you may withdraw it at any time.

2. How We Use Your Personal Data

We use the data described above to:

1. Provide & maintain the Site and deliver products/services you request;
2. Verify identity, process payments, and prevent fraud;
3. Respond to inquiries and provide technical or customer support;
4. Send administrative notices such as transaction confirmations, policy updates, or security alerts;
5. Improve the Site, develop new features, and perform analytics;
6. Conduct direct marketing by email, SMS, phone, or online ads where permitted by law or with your consent; and
7. Comply with legal obligations and protect our rights or the rights of others.

We will not sell or lease your personal data to third parties for their own marketing without your explicit consent. Where we “share” data for cross‑context behavioral advertising (as defined under CCPA), you have the right to opt out.

3. Cookies & Similar Technologies

We use essential cookies that are necessary for the Site to function, analytics cookies to understand how visitors interact with the Site, and advertising cookies to deliver targeted ads. Except for essential cookies, we place cookies only after obtaining your granular consent via our cookie banner. You can change or withdraw your consent at any time by clicking “Cookie Settings” in the footer. For detailed information on each cookie category, retention period, and provider, please view our Cookie Table (link displayed in the banner).

4. Disclosures to Third Parties

We disclose personal data only to:

• Service providers that process data on our behalf (e.g., cloud hosting, payment processors, email service providers) under data‑processing agreements;
• Analytics & advertising partners (only with consent for non‑essential cookies);
• Affiliates and subsidiaries of Cogent Digital for internal administrative purposes;
• Legal authorities or other parties when required to comply with law, enforce agreements, or protect rights/safety.

Whenever we transfer personal data outside the European Economic Area, we rely on an adequacy decision or execute Standard Contractual Clauses with supplementary measures as required by GDPR.

5. Your Privacy Rights

Depending on where you reside, you may have rights to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete data;
• Erase data (“right to be forgotten”);
• Restrict or object to processing;
• Data portability (receive a copy in a structured, machine‑readable format);
• Opt out of the sale or sharing of personal data and of targeted advertising;
• Withdraw consent at any time for processing based on consent;
• Lodge a complaint with a supervisory authority (e.g., your local Data Protection Authority).

To exercise any of these rights, please contact us at privacy@cogent.digital (or one of the addresses below). We will respond within the timeframe required by applicable law.

6. Data Security & Retention

We implement administrative, technical, and physical safeguards—such as TLS 1.3 encryption, least‑privilege access controls, and periodic penetration testing—to protect personal data. While no online transmission is completely secure, we strive to reduce risks to a commercially reasonable level. We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, including satisfying legal, accounting, or reporting requirements. Retention periods differ by data category and processing purpose.

7. Children’s Privacy

The Site is not directed to children under 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

8. Changes to This Policy

We may amend this Policy from time to time. If we make material changes, we will notify you by updating the “Last revised” date and, where required, seek your renewed consent.

9. Contact Us

Cogent Digital, LLC Attn: Privacy Team Cottonwood, AZ 86326 USA Phone: (888) 508‑5151 General inquiries: help@cogent.digital Legal & DPO: legal@cogent.digital / privacy@cogent.digital If you have questions about this Policy or wish to exercise your privacy rights, please reach out using any of the methods above.