PRIVACY POLICY Effective Date: March 17, 2026 Aragon Advertising, LLC Product Name: Aria 1. Introduction Aragon Advertising, LLC, a New York limited liability company ("Aragon," "we," "us," or "our"), respects the privacy of our visitors and users (“you” or “your”). This Privacy Policy describes the types of information we collect through Aria (the “Platform”), how we use and disclose such information, and the rights and choices available to Users. By accessing or using the Platform, you acknowledge and agree to the terms of this Privacy Policy. 2. Scope This Privacy Policy applies to all data collected or processed via the Platform, including information collected from visitors and users located in the United States and internationally. 3. Information We Collect We may collect the following categories of information: a. Account and Business Information • Company name, contact name, email address, phone number, job title/role, address • Login credentials and user preferences b. Campaign and Tracking Data • Call time, duration, caller phone number (if available), call outcome (e.g., connected, missed, voicemail) • Tracking metadata (campaign ID, publisher ID, buyer ID) • Call recordings and transcriptions, where enabled • Traffic source information • Click timestamps & IP addresses • Conversion data (what action was completed) • Device information (browser, OS, user agent) • Landing page or ad creative IDs • Cookies and tracking pixels c. Payment & Billing Information (If you process payments) • Billing address • Bank account details • Credit card or payment processor data • Tax information (like W-9, VAT number) d. End User or Lead Data • Phone numbers (for pay-per-call or click-to-call) • Email addresses • IP addresses • Location data (approximate, from IP) • Web activity (what page they visited, how they interacted) • Call recordings or transcripts (depending on your compliance settings): You are responsible for providing or expressly authorizing their use, and for obtaining all necessary consents and approvals as required by applicable laws and regulations. e. Device and Usage Data • IP address, browser type, operating system, referring URLs, Device ID, Date/time stamps • Platform activity logs and usage metrics f. Third-Party Data • Data received from third-party platforms via API integrations for aggregation and reporting purposes 4. How We Use Information We use collected information for the following purposes: • To provide and maintain the Platform and related services • To route, log, analyze, and report call traffic • To facilitate billing, account management, and support • To detect and prevent fraud or abuse • To improve and optimize the performance and security of the Platform • To comply with legal and regulatory obligations 5. Data Sharing and Disclosure We do not sell personal data. We may share information as follows: • With your Consent: Where you instruct us to integrate with third-party services • With Service Providers: For hosting, support, analytics, or infrastructure purposes under contractual obligations of confidentiality • With Other Platform Users: To the extent necessary for routing or reporting on call traffic between buyers and sellers • For Legal Reasons: If required to comply with a subpoena, court order, or other legal process • Using de-identified and aggregated information. We might share information collected from you with a third party if that information has been de-identified or aggregated in a way that does not directly identify you. We may also use campaign performance data generated through the Platform in aggregated and anonymized form for analytics, benchmarking, platform improvement, and marketing or promotion of our services, provided such use does not identify you. 6. Third-Party Integrations The Platform may access or transmit data to third-party platforms (e.g., CRMs, ad networks, analytics tools) at your direction. Aragon disclaims all responsibility for the data practices of such third parties. You are solely responsible for ensuring the lawful collection and use of third-party data through integrations. 7. Data Security We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, or misuse. These measures vary based on the sensitivity of the information we collect, process, and store and the current state of technology. However, no method of transmission over the internet is completely secure. Use of the Platform is at your own risk. 8. Data Retention We retain call records, logs, and platform activity data for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, or enforce agreements. When your information is no longer needed, we will destroy, delete, or erase it. Users may request deletion of data subject to applicable limitations. 9. International Data Transfers The Platform and Services are based in the United States and are governed by United States law. If you access the Platform from outside the United States, you acknowledge and agree that your information may be transferred to, stored, and processed in the United States. By using the Platform, you consent to such transfers. 10. Data Protection Laws and User Rights You are the data controller for any Personal Data processed through the Platform and agree to comply with all applicable data protection and privacy laws, including, but not limited to, the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and any other relevant regulations. You are solely responsible for ensuring that your use of the Platform, including collection, recording, or sharing of call data, complies with all applicable legal requirements, including obtaining any necessary consents. To the extent permitted by law, you agree to indemnify and hold us harmless from any claims arising from your failure to meet these obligations. If your use of the Platform involves protected health information (PHI) or other sensitive data subject to additional regulatory requirements, you must notify us in writing. We may require a separate agreement, such as a Business Associate Agreement (BAA), to ensure appropriate safety measures are in place. We operate as a “data processor” under the “GDPR”, a “service provider” under the CCPA, and, where applicable, a “business associate” under the HIPAA. We will comply with our respective obligations under these and other applicable laws in connection with the services we provide. Depending on your jurisdiction and the nature of the data involved, individuals may have rights under applicable laws, which can include the right to: • Access, correct, or delete your personal data • Object to or restrict certain data processing • Receive a copy of their data in a portable format • Lodge a complaint with a data protection authority Requests to exercise data rights may be submitted using the contact information provided below. We will respond to such requests in accordance with applicable law. 11. Cookies and Tracking Technologies We may use cookies and similar technologies to improve platform functionality, analyze traffic, and support session management. By using the Platform, you consent to our use of cookies in accordance with your browser settings. 12. Children’s Privacy The Platform is intended for business use only and is not directed at children under the age of 13(16 in the EU) (“Children”). We do not knowingly collect personally identifiable information from Children. If we become aware that we have collected Personal Information from a Child without verification of parental consent, we take steps to remove that information from our servers. 13. Changes to This Policy We reserve the right to update or modify this Privacy Policy at any time. We will notify Users of material changes by posting the updated policy to the Platform or via email. Continued use of the Platform after such changes constitutes acceptance. 14. Contact Information For questions or concerns regarding this Privacy Policy, please contact: compliance@aragon-advertising.com

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