PRIVACY POLICY

The Scalable Leader (“Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and protect information when you access our website, programs, services, or communicate with us through Application-to-Person (A2P) messaging or other channels (collectively, the “Services”).

By visiting the Services or providing your information to us, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We collect only the information necessary to operate our Services and comply with legal and regulatory requirements.

Information You Provide

When you interact with us, you may provide:

• Contact information such as name, email address, phone number, and mailing address)

• Account or program registration details

• Payment and billing information (when applicable)

• Communications you send to us, including support inquiries

• SMS Opt-in and opt-out preferences for messaging

Information Collected Automatically

• Message metadata (delivery status, timestamps, opt-in/opt-out records)

• Device and browser information

• IP address and general location information

• Website usage data

We do not knowingly collect sensitive personal information unless required for authorized services or legal obligations.

2. How We Use Your Information

We use the personal information we collect to:

• Provide, operate, and improve our Services

• Send authorized service-related communication and A2P messages

• Maintain messaging compliance records

• Respond to inquiries and provide customer support

• Process transactions and administrative communications

• Detect and prevent fraud, abuse, or unauthorized activity

• Comply with applicable laws, regulations, and government requirements

We do not sell your personal information.

3. A2P Messaging & Consent

If you provide a phone number or electronic contact information, you consent to receive A2P messages from the Company related to our Services.

• Message frequency may vary

• Standard message and data rates may apply

• You may opt out at any time by replying “STOP” to any message or contacting us directly

• You may reply “HELP” for assistance

All messaging complies with the Telephone Consumer Protection Act (TCPA), CTIA Messaging Guidelines, and applicable federal and state laws.

4. How We Share Your Information

We may share information  only in the following circumstances:

• Service Providers: We work with trusted third-party service providers who assist us in operating and supporting our Services, such as payment processors, messaging platforms, hosting providers, and analytics services. These providers are contractually required to use personal information only as necessary to perform services on our behalf and to protect it in accordance with applicable laws.

• Legal and Regulatory Requirements: We may disclose your information when required to do so by law, regulation, court order, subpoena, or other lawful government request, or when we believe disclosure is necessary to protect the rights, safety, or  safety of the Company, our users, or the public.

• Business Transactions: If the Company is involved in a merger, acquisition, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to appropriate confidentiality and security safeguards.

• With Your Direction or Consent: We may share your information for a specific purpose at your direction or with your explicit consent.

Note: We do not share personal information for third-party advertising or marketing purposes.

4A. Mobile Information Sharing Statement

We do not share, sell, rent, or disclose mobile phone numbers or SMS consent data to third parties or affiliates
for their marketing or promotional purposes.

Mobile information will only be used to provide the services requested by the user, deliver authorized communications, or as required by law.

Messaging opt-in data and consent will not be transferred, shared, or sold to any third parties except for messaging service providers who support message delivery and are contractually obligated to protect your data.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to support website functionality, improve performance, and understand how visitors interact with our Services. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain preferences.

Types of Cookies We Use

• Essential Cookies: Required for the website to function properly and enable core features

• Analytics Cookies: Help us understand how visitors use our website and improve user experience

• Preference Cookies: Remember your settings and preferences for a consistent experience

Managing Cookies:
You can control or disable cookies through your browser settings at any time. Disabling cookies may affect the availability or functionality of certain features of the website. By continuing to use our website, you consent to our use of cookies as described in this section.

6. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information including:

• Encryption of data in transit and at rest

• Access controls and authentication measures

• Monitoring and logging of system activity

• Employee training on privacy and data protection

Our security practices align with applicable standards, including FISMA and NIST SP 800-53. In the event of a data breach, we will provide notice as required by law.

7. Data Retention

We retain personal information only as long as necessary to provide the Services, maintain compliance records, and meet legal or regulatory obligations. When information is no longer required, it is securely deleted or anonymized.

8. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information. These rights may include access, correction, deletion, and limitation of use, as provided under applicable laws.

California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information. You may:

• Request disclosure of the personal information we have collected about you

• Request correction of inaccurate personal information

• Request deletion of your personal information, subject to certain exceptions

• Exercise your rights without discriminatory treatment

We do not sell personal information. To exercise your rights, please contact us using the information in Section 11. We will verify your identity and respond within the timeframe required by law (typically 45 days).

Other State Privacy Rights:
Residents of other states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, and Utah) may have similar rights to access, correct, delete, or limit the use of their personal information.

Transactional Communications:
Even if you exercise your privacy rights, we may still send you transactional or service-related messages necessary for your account or Services.

9. Children’s Policy

The Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors.

10. Changes to This Privacy Policy

We reserve the Privacy Policy from time to time. Any changes, we will be posted with an updated Effective Date. Continued use of the Services after changes are posted constitutes acceptance of the revised policy.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact:

The Scalable Leader

Email: [email protected]

Phone: 469-331-2328

Mailing Address: 6675 S Custer Rd. Ste 500 PMB 6000, McKinney, Tx 75070

Attn: Privacy Officer

For California residents: You may also contact us to request information about our compliance with California privacy laws and to exercise your CCPA/CPRA rights.

We are committed to protecting your privacy and handling your personal information with transparency and respect. Thank you for trusting us with your information.

Last Updated: December 1, 2025