This Privacy Policy discloses the privacy practices for SPEAKEASY MASTERMIND LLC, a Nevada limited liability company (“Speakeasy Mastermind”) and various related services (together referred to as the “Services”). Speakeasy Mastermind, the provider of the Services (referred to as “us” or “we”), is committed to protecting your privacy. Please read the information below to learn the following regarding your participation in the Services:

1. What information do we collect from you?

2. Where do we collect information from you and how do we use it?

3. With whom do we share your information?

4. How can you update, correct or delete your Personally Identifiable Information?

5. What are your choices regarding the collection, use and distribution of your information?

6. What security precautions are in place to protect against the loss, misuse or alteration of your information?

7. Will use of my image in Speakeasy Mastermind advertising be protected?

8. What should you know about privacy policies and data collection at any third party sites accessible through our Services?

9. What else should you know about your privacy?

You acknowledge that this Privacy Policy is part of our Membership Agreement, and by accessing or participating in our Services, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or participate in the Services. We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to issuing an e-mail to the e-mail address listed by registered users and posting the revised Policy on Speakeasy Mastermind’s website or any other server hosting Speakeasy Mastermind communications. You acknowledge and agree that it is your responsibility to maintain a valid e-mail address as a registered participant, review this Policy periodically and to be aware of any modifications. Your continued participation in the Services after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Policy.

1. What information do we collect from you?

In order to better provide you with the highest level of Services, we collect two types of information about our users: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while participating in the Services.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities, such as registering for a membership, ordering a product or service, submitting content and/or posting content in discussion forums or other public areas, entering a contest or sweepstakes, filling out a survey, or sending us 2 feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), email address, employer, job title and department, telephone and facsimile numbers, and other personal identifying information. When participating in the Services, you may be asked to provide a credit card number. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

Non-Personally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include a visit to Speakeasy Mastermind’s Uniform Resource Locator (“URL”), which URL you go to next, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.

2. Where do we collect information from you and how do we use it?

We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you:

(a) become a member of Speakeasy Mastermind and register your e-mail address with us;

(b) enter sweepstakes or contests sponsored by us or one of our partners;

(c) sign up for special offers from selected third parties;

(d) send e-mail messages, submit forms or transmit other information by telephone, social platform, or letter; or

(e) submit your credit card or other payment information when ordering and purchasing products and services from Speakeasy Mastermind.

We may also collect information from you at other points during the Services that state that such information is being collected.

In addition, we may also collect, or our third party ad server and/or content server may collect, certain Non-Personally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer the Services and to gather demographic information.

We will primarily use your Personally Identifiable Information to provide the Services to you, as required by our agreements with you. We will also use Personally Identifiable Information to enhance the operation and quality of the Services, improve our marketing and promotional efforts, statistically analyze the Services, improve our Service offerings, and customize our Services. We may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices. We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Membership Agreement, Guidelines and this Privacy Policy.

3. With whom do we share your information?

We do not sell, trade, or rent your Personally Identifiable Information to others. We do provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties. We and our service partners use your Personally Identifiable Information to operate the masterminds. For example, we must release your credit card information to the card-issuing bank to confirm payment for the Services; release your address information to the delivery service to deliver products that may order; and provide order information to third parties that help us provide customer service.

We will encourage our service partners to adopt and post privacy policies. However, the use of your Personally Identifiable Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who participate in the Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may also provide Non-Personally Identifiable Information about our customers’ sales, patterns, and related information to third party advertisers, but these statistics do not include any Personally Identifiable Information.

4. How can you update or correct your Personally Identifiable Information?

We believe you should have the ability to access and edit the Personally Identifiable Information that you have provided to us. You may access and correct your personal information and privacy preferences by writing us at [email protected] or directly to any employee of Speakeasy Mastermind. Please include your name, address, and/or e-mail address when you contact us.

We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have information deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions with respect to the Services. In addition, it may be impossible to completely delete your information without 4 some residual information because of backups.

5. What are your choices regarding collection, use, and distribution of your information?

We may, from time to time, send you e-mails regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only Speakeasy Mastermind (or agents working on behalf of Speakeasy Mastermind and under confidentiality agreements) will send you these direct mailings and only if you indicated that you do not object to these offers. If you do not want to receive such mailings, simply tell us when you give us your personal information. Or, at any time you can easily edit your account information to no longer receive such offers and mailings.

6. What security precautions are in place to protect against the loss, misuse, or alteration of your information?

You can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our user is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Your Personally Identifiable Information resides on a secure server that only selected Speakeasy Mastermind personnel and contractors have access to via password. We encrypt your Personally Identifiable Information and thereby prevent unauthorized parties from viewing such information when it is transmitted to us. Personal information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password.

In order to most efficiently serve you, credit card transactions and order fulfillment are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through your participation in the Services cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

7. Will use of my image in Speakeasy Mastermind advertising be protected?

It is understood and agreed that during your participation in the Services, your picture can be taken or you may be filmed while participating in the Services. Except as expressly limited herein, by participating in the Services, you grant Speakeasy Mastermind and its agents, employees and photographers, the right to take, use, publish, and copyright photographs and videos of you in 5 press releases, advertisements, publications, and/or promotions of Speakeasy Mastermind, including on Speakeasy Mastermind’s website and on social media platforms, such as Facebook, Instagram and YouTube, maintained by Speakeasy Mastermind and/or its individual employees and/or agents. Except as expressly limited herein, you release and waive against Speakeasy Mastermind and its agents, employees, photographers and videographers, any and all claims or demands arising out of or in connection with said photographs or videos or the publications of said photographs or videos.

Notwithstanding anything contained in this provision to the contrary, nothing in this provision shall be construed to permit, consent to, release, or waive the taking or use of photographs or video or audio for any purpose or use that is illegal, immoral, or would endanger or harm you or construed or deemed to permit, consent to, release, or waive any rights with regard to the use of your name or other Personally Identifiable Information.

8. What should you know about privacy policies and data collection at any third party sites accessible through your participation in the Services?

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through your participation in the Services have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies which may advertise through the Services may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

9. What else should you know about your privacy online?

You must be at least 18 years old to participate in the Services. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about members that are under 18 years of age.

You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e., your name, e-mail address, etc.) in the discussion forums or other public areas, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you’re online.

If you have any questions about this Privacy Policy, the practices of Speakeasy Mastermind, or your participation in the Services, please contact us by sending an email to [email protected].