This Privacy Policy explains how Peli collects, uses, and shares information about you when you use Peli’s Platform (“Platform”), or otherwise interact with us. The Platform is designed to allow creators (“Creators”) to build, design, publish, and sell courses and other services to their Users (“Users”). This Privacy Policy applies when you access or use the services and tools offered through our Platform (“Peli Services”), or otherwise interact with us. Your access to our Platform and use of Peli Services is also governed by our Terms of Use. Capitalized terms used but not defined in this Privacy Policy can be found in our Terms of Use. Please read this Privacy Policy and the Terms of Use carefully prior to accessing our Platform and using Peli Services. If you have any questions, please contact us at: [email protected].

Overview

Peli’s Role as a Controller of Your Personal Information. Peli is the controller of personal information that it collects and processes in connection with the use of our site and the provision of Peli Services. This includes personal information that you provide to us when you create an account on the Platform, subscribe to a Peli plan or services, etc. Please refer to the “Personal Information We Collect” section of this Privacy Policy for more information about personal information that Peli collects as a controller. Peli’s role as a processor of Personal Information Collected by Creators. Creators are the owners of content that they upload, submit, or otherwise provide to the Platform (“Creator Content”) and are the controller with respect to any personal information included in their Creator Content. Peli acts as a processor when it processes Creator Content on behalf of the Creator.

When a User enrolls in Creator Content, Peli will provide the Creator access to a limited set of personal information about the User (“User Data”) to enable the Creator to provide their services to the User. Peli and Creators may each use User Data for their own business purposes, at all times subject to the terms of this Privacy Policy and our Terms of Use. The Creator and Peli each act as an independent controller with respect to their particular use of User Data.

Creators acknowledge and agree that they are responsible for complying with all applicable laws and regulations related to the protection of personal information for which they are controllers. If you are a User whose personal information has been collected by a Creator, please contact the Creator directly and view the Creator’s privacy policy if you have questions about how the Creator uses your personal information.

Personal Information We Collect

Peli collects personal information about you in several different ways, depending on how you interact with our Platform.

Personal Information You Give Us (Or that We May Receive from Others).

We collect personal information you directly provide to us. We may also receive personal information about you from others; e.g. from another user or our payment processors.

Personal Information We May Collect from Any Users of Our Platform.

• Account Information. To use certain features of our Platform, you’ll need to register for an account with Peli. To do so, you’ll need to provide us with certain personal information, such as your name, email address, and password.

• Third Party Integrations. You may allow our Platform to interact with third party services, such as Facebook. The information you allow Peli to access varies by service, and it is affected by the privacy settings you and those that you are connected with establish while using such services. Third-party services are operated, controlled, and maintained by third parties that are not operated, controlled, or maintained by Peli. Such third-party services have their own policies regarding privacy and use of information, and you are encouraged to review such policies. We have no control over such third parties.

• Other Personal Information. You may choose to provide us with other personal information. If so, we may use such information that you have provided to us.

Personal Information We May Collect from Creators.

• Peli Subscription Plans. When you subscribe to a paid Peli plan, we will collect certain personal information from you for the purposes of billing your subscription fees and any payment service fees and you may need to provide payment-related information directly to our third party-payment processors, as described below.

• Creator Payment Information. If you’re a Creator and you are using Peli’s payment gateways, you’ll need to link your payment account to our Platform to receive payouts. By linking your account, Peli will receive certain payment related information about you, including your payment card type and related information, and any email address associated with the payment type. Further, we will collect certain personal information for tax purposes. This tax information may include your full name, address, and tax and/or business registration numbers.

• Content You Submit to Peli. Peli may collect and use all messages, posts, comments and other content you submit to the Peli platform.

Personal Information We May Collect from Users.

• User Payment Information. To purchase a course or other service through our Platform, you’ll need to provide us with certain personal information, such as your name, address, and information about the service you are purchasing. You may also need to provide certain payment-related information directly to our third-party payment processors, as described below.

• Third Party Payment Processors. We use third party payment processors like Stripe to process payments through the Peli Platform. For payments processed via our gateways, the third-party processor provides us with information related to the payment status of your account; this information includes your payment card type and last four digits, payment expiration date, zip code, approximate location based on IP address, country of origin, and any email address associated with the payment type. Third-party payment processors are independent from Peli and have their own privacy policies. We suggest you review such third-party payment processors privacy policies.

• Participation in Creator Content. When you enroll in a course or use or access other Creator Content, Peli will collect personal information relating to your participation in the Creator Content, such as courses you have enrolled in.

Personal Information We May Collect Automatically.

Peli collects information regarding your use of the Platform, as described below:

1. Usage Data. Peli logs usage information when you visit and use our Platform, such as IP address and other information about the use of our website, such as the content or pages you viewed, when you viewed them, and links that were clicked.

2. Cookies and Similar Technology. Peli may collect information about you through the use of cookies and other similar technologies. Cookies are pieces of data in the form of text files that your browser stores on your hard drive and sends back to us when making requests, and similar technologies.

3. Approximate Location. We may receive and process information about your approximate location.

Use of Personal Information We Collect

We use your personal information to provide you with a customized experience, and we use such information for customer support, advertising and marketing communications, research and service development, and to keep our Platform and users safe and secure.

Specifically, we may use your information for the following business purposes:

To provide and improve our services; For customer support; For advertising and marketing communications; For research and service development. We use personal information to conduct market research and to develop new services in order to provide you with a better experience and to drive growth in our business; For legal and security purposes. We use personal information to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to Peli’s or a third party’s rights; and For licensing compliance, such as to comply with regional media licensing requirements through Feed.FM, our music licensing provider.

Legal Disclosures

Peli may be required to disclose personal information if directed by a court of law or other governmental entity. We further reserve the right to disclose such information where we have a good faith basis to believe that such action is necessary to:

• comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests; • protect and defend Peli’s or a third party’s rights and property, or the safety of Peli, our users, our employees, or others; or • prevent, detect, investigate and take measures against criminal activity, fraud and misuse or unauthorized use of our Platform and/or to enforce our Terms of Use or other agreements or policies.

To the extent permitted by law, we will attempt to give you prior notice before disclosing your information in response to such a request.

We may share your information for reasons not described in this policy. We will tell you before we do this.

Your Rights and Choices

Peli gives you choices with respect to our use of your personal information. These choices include accessing, updating, or deleting your personal information, as well as choosing what communications you would like to receive from us. Depending on your location, you may have additional rights related to your personal information (see the ‘Jurisdiction Specific Provisions’ section below for more information about location-specific privacy rights).

You can also choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Platform because that information may be required for you to register for an account, purchase Peli Services, enroll in Creator Content, participate in our promotional offerings, get customer support, or engage in other activities on our Platform.

Please refer to the ‘Data Privacy Requests and Verification’ section below for information on how to make a data privacy request.

Rights of Users Related to Personal Information Shared with a Creator

Please note that in cases where you wish to exercise your data privacy rights with respect to personal information for which a Creator is the controller, you’ll need to directly contact the Creator to exercise your rights.

How We Share Personal Information We Collect

Peli only shares your personal information with third parties under the circumstances described below. We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration.

Sharing of User Information with Creators

When you participate in Creator Content, Peli will share certain personal information about you (“User Data”) with the Creator to allow the Creator to provide you with their services. The personal information we may provide includes: • Account information, including your name and email address; • Purchase information, including amount paid, your address, and other billing information (but never your complete card number, which we do not collect); • IP address; • Information about your participation in the Creator Content, including the Creator Content you enrolled in, view completion status, view progress; • Any messages you exchange with the Creator through Peli.

Any additional personal information that is shared by a User with a Creator is done so at the discretion of the User. The Creator is responsible for protecting Users’ personal information that they collect and processing that information in accordance with applicable data protection laws. Users who have questions about Creators’ privacy practices should contact the Creators directly and ask to review the Creators’ privacy policies.

Sharing of Creator Information with Users and Other Users. When a Creator publishes Creator Content, information contained in your Creator Content will be viewable to users who are given access to your Creator Content.

Please keep in mind that all of the information that you share or content that you publish in public portions of our Platform becomes public information, and thus, neither you, nor us, can control how others treat it.

We may also share your personal information in the following ways:

With Third-Party Services

When you use third party services with our Platform, we recommend that you read the terms of use and privacy policies of those third-party services to understand how they collect, use, and share your personal information.

With Your Consent

Peli may send your personal information to a third party when you give us consent to do so or at your direction. For example, this may occur when we complete a transaction at your request.

With Service Providers and Business Partners

We may share personal information with service providers that provide us with certain services and process personal information on our behalf, such as those who provide customer support, support our website functionality, payment processors, advertisers, analytic partners and related features of our Platform. We sometimes partner with third parties on certain programs and offers. You may be required to share you email or other personal information. These third parties may collect unique identifiers, such as your IP address.

With Affiliates and Purchasers

We may share personal information with our parent, affiliates, and other companies under common control and ownership, subject to the terms of this Privacy Policy. We may also share your personal information in connection with a substantial corporate transaction, such as a sale of our business. Any other entity which buys us or becomes part of our business will have the right to continue to use your personal information, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Accessing, Updating, and Deleting Your Personal Information

You can access and update certain personal information about you by visiting your Account Settings.

You can also submit a data privacy request to receive a copy of personal information that we hold about you, free of charge. If you believe that any personal information, we are holding about you is incorrect or incomplete, we will work with you to make corrections deemed necessary. Note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you’d like Peli to delete your account or delete personal information it holds about you, you can submit a deletion request by emailing us at [email protected] from the email address associated with your account. Note that when we delete your account, personal information that you have shared with others (for example, through comments or an intake form) may still be visible. Peli will also retain certain personal information about you where reasonably necessary to comply with our legal obligations or for our legitimate business purposes.

Data Privacy Requests and Verification

If you would like to make a request under the privacy laws of your jurisdiction, please let us know where you reside and which rights you’d like to exercise. For more information about exercising your jurisdiction-specific privacy rights, please see section ‘Jurisdiction Specific Provisions’ below.

To protect your privacy, we need to verify your identity before we process your data privacy request. As part of this process, you may contact us via the email address associated with your account. Depending on the nature of the request, we may also need to obtain additional information necessary for us to verify your identity.

You may designate an authorized agent to make a data privacy request on your behalf. To do so, we will need to receive written permission by you or a valid power of attorney, and we may also verify the validity of the request directly with you.

Controlling Promotional Communications

You can opt out of receiving some or all of our promotional communications through the unsubscribe link in the email or by emailing [email protected].

If you opt out of promotional communications, we may still send you transactional communications, such as service announcements, administrative and legal notices, and information about your account, without offering you the opportunity to opt out of these communications. If you no longer wish to use our Platform or receive any communications from us (except for those that are legally required), please contact [email protected] to have us delete your account.

Please note that opting out of promotional email communications only affects future communications from us. If we have already provided your information to a third party (such as a credit card processing partner) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party. Additionally, it will take a period of time for us to process your request.

Do Not Track Signals

Your browser may give you the option to send a “Do Not Track” instruction to websites you visit. However, since there is no accepted standard for how a website should respond to this instruction, we do not currently recognize or respond to these signals.

Consent. We will process your personal information when you have given us consent to do so, such as when you consent to receive certain communications from us.

If you’d like to withdraw your consent or object to our processing of your personal information, see above under Data Privacy.

If you believe that we have not adequately addressed your concerns or wish to report an alleged infringement of applicable data privacy laws, you may file a complaint with your local supervisory authority.

Other Information

Information Security

Peli uses a range of physical, technical, and administrative security measures to protect your personal information. We use encryption in the transmission of financial information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. However, no method of data transmission or storage system is absolutely secure, and we cannot guarantee that your personal information will not be accessed, disclosed, altered, or destroyed in the event of a breach of any of our security measures.

Where we have given you (or where you have chosen) a password to access certain parts of our Platform, you are responsible for protecting this password and keeping it confidential. As the safety and security of your information also depends on the precautions you take, we ask you not to share your password with anyone. If you believe your password or the security of your account has been compromised, you should change your password immediately and contact [email protected] with any concerns.

Data Retention

We save personal information we collect for as long as it is necessary for the purposes for which the personal information is collected and processed. Generally, we will keep your personal information until your account is deleted, or as needed to provide you with our services. We will also retain certain personal information to comply with our legal obligations or for our legitimate business purposes.

International Transfers of Information

Peli is based in the United States and it stores, processes, and transfers information in and to servers and databases located in the United States. It may also store, process, and transfer information in and to servers in other countries depending on the location of its affiliates and service providers. At this time, only users in the United States may use the Peli Service.

Third Parties and Other Personal Information Collectors

Except as otherwise expressly specified in this Privacy Policy, this document only addresses the use and disclosure of personal information Peli collects from you. To the extent that you disclose your personal information to other parties through our Platform, whether between Creator and User or with other users, different rules may apply to how they use and share your personal information. Accordingly, you will need to look at the privacy policies of these third parties to understand their data privacy practices.

As further explained in our Terms of Use, our Platform may include links to third party websites. We are not responsible for the content of such websites or the protection and privacy of any information which you provide while visiting those sites. We recommend that you exercise caution and review the privacy policies applicable to the websites in question.

Jurisdiction Specific Provisions

Peli uses the following legal bases for processing:

For the performance of a contract. We will process your personal information to fulfill our contractual obligations with you, such as to provide you with access to Peli Services, to communicate with you regarding your use of Peli Services, and to comply with our Terms of Use.

For legitimate interests. We will process your personal information for our legitimate interests or those of others (as long as the processing is not outweighed by your data protection interests). This includes but is not limited to, preventing fraud and other abuse, ensuring the security of our Platform, protecting our legal rights and interests, conducting market research and product development, and for marketing purposes.

To comply with legal obligations. We will process your personal information to comply with all applicable laws, regulations, court orders, and government and law enforcement agencies’ requests.

Users in California

California Consumer Privacy Act. If you are a California resident, you have specific privacy rights governed by the California Consumer Privacy Act (“CCPA”). These rights include:

• Right to Know. You have the right to request a report showing the Personal Information collected, shared, and sold about you in the past 12 months; • Right to Opt-Out of Sale of Your Personal Information. You have the right to opt-out of the sale of your Personal Information to third parties; • Right to Deletion. You have the right to request that we delete any Personal Information collected from you; • Right to Non-Discrimination. We shall not discriminate against you based on your exercise of any of the above rights.

You or your authorized agent may submit a request to exercise any of the above rights by emailing us at [email protected] with the subject line “CCPA Request”. Please also provide us with your mailing address and state of residence.

We may require additional information to verify your identity or to verify that your authorized agent has the authority to make the request on your behalf before responding to a CCPA rights request. We will respond to your request within 45 days if possible and required under the law.

Personal Information Collected on California Residents

The following are categories of Personal Information that we may collect about you, as well as examples of the types of Personal Information that may be collected:

Identifiers

• Names and Aliases; • Physical Address; • Phone Number; • E-Mail Address; • IP Address; • Unique Identifiers

Commercial Information

• Information about transactions made on our Platform, including purchase history; • Interactions with Customer Support

Usage Information

• Services enrolled in; • Usage of services enrolled in

Financial Information

• Last 4 digits of your credit card; • Account payment status

Geolocation

• Information related to your location, including your IP address

Internet/ Electronic Activity

• Information from your browser, such as usage information and cookies; • Information related to your location, including your IP address; • Passwords; • Device attributes

We collect Personal Information from the following sources:

• Directly from you (e.g. Information provided when you register on our Platform, submit payment, or use any of our Platform’s services); • Automatically collected information (e.g. collected automatically through cookies, etc.); • Information provided by third parties, including those that you request to share information with us.

Personal Information Disclosed for a Business Purpose to Third Parties

The categories of Personal Information listed above may be disclosed to the following categories of third parties:

• For Users, we may share your information with Creators; • For Creators, we may share your information with Users and on our Platform for the purposes of marketing or sharing information about our services; • Integrated third parties with whom you choose to share information; • Our service providers (e.g. cloud services providers, technical service providers, law firms, accounting firms, etc.); • Business partners (e.g. companies that we partner with for events, promotions and contests, etc.); • Advertising partners to provide advertising based on your interests; • Peli affiliates, including our parent company and other companies under common control and ownership; • When you ask us to provide information to a third party; or • To law enforcement or others if required by law.

The disclosures to third parties listed above may be for any of the following business purposes:

• To provide you with our services; • For marketing purposes; • To provide you with ads or information we think may be of interest to you; • To improve our Platform and services; • To maintain the safety and security of our services; or • As otherwise permitted by law.

We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration.

Under California’s ‘Shine the Light’ law, California residents have the right to request certain information relating to personal information we have shared with third parties for those third parties’ direct marketing purposes. Note that we only share information with third parties for their direct marketing purposes when you request us to do so or you expressly consent to it.

If you are a California resident and would like to exercise your rights under the CCPA or California’s ‘Shine the Light’ law, email us at [email protected] pursuant to the ‘Data Privacy Requests and Verification’ section above. Please specify which privacy right you’re exercising in the subject line (for example ‘CCPA deletion request’) and provide us with your mailing address and state of residence.

No Rights of Third Parties; Changes to our Privacy Policy

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

Changes to Our Privacy Policy

We encourage you to periodically review this Privacy Policy to stay informed about our privacy practices, as we may review and update our processes from time to time. If we make a change that, in our sole discretion, is material, we will notify you through email, by posting a notification on our website, or as required by law. Unless otherwise stated, changes to this Privacy Policy will take effect immediately as of the date it is posted. By continuing to use our Platform after Privacy Policy changes go into effect, you agree to be bound by the revised Privacy Policy.

Contact Us

If you have questions or concerns regarding this Privacy Policy or Peli’s handling of your personal information, or if you would like to exercise your rights described in this Privacy Policy, please contact us at:

[email protected]

Peli uses a range of security measures to protect your personal information. We use encryption in the transmission of financial information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. However, no method of data transmission or storage system is absolutely secure, and we cannot guarantee that your personal information will not be accessed, disclosed, altered, or destroyed in the event of a breach of any of our security measures.

You need a password to access certain parts of our Platform. You are responsible for protecting this password and keeping it confidential. As the safety and security of your information also depends on the precautions you take, we ask you not to share your password with anyone. If you believe your password or the security of your account has been compromised, you should change your password immediately and contact [email protected] with any concerns.