Privacy Policy

The Effective date of this Privacy Policy is May 13, 2026

Last revision date is May 13, 2026

This privacy policy (hereinafter the "Privacy Policy") applies to MultiTracks.com LLC ("our", "we", "us") and describes how we use the information you provide to us via email, phone, messaging platforms (such as WhatsApp), or via our website, www.MultiTracks.com (the "Website") or via any mobile applications we make available that are associated with the Website (the "Mobile Apps"). We provide a comprehensive suite of apps and services, products, and/or licenses for worship leaders (collectively, our "Services"). The Website and Mobile Apps are collectively referred to in this Privacy Policy as the "Platforms".

Introduction:

Please read this Privacy Policy carefully before using our Platforms or otherwise before providing information to us through any method or platform. This Privacy Policy governs your access to and use of our Platforms and our Services, both of which are only available for your use on the condition that you agree to this Privacy Policy and our Terms of Use and License. If you do not agree to this Privacy Policy and/or our Terms of Use and License, please do not access or use the Platforms or engage our Services. By accessing or using our Platforms or otherwise engaging our Services, however, you and the entity you are representing signify your agreement and consent to be bound by this Privacy Policy and our Terms of Use and License.

What this policy covers:

This document is intended to help you understand:

• What information we collect about you
• How we use any personal information
• How we share (or don't share) any Personal Information
• How we store and keep secure any Personal Information
• How you can update and control any Personal Information
• Other important information relevant to your privacy

What information we collect about you:

Numerous sections of our Platforms are accessible for browsing without the need to collect any Personal Information. If you wish to use any of our Services, however, you must create an account and provide us with the information we need to provide you with those Services. The information we need to complete such a transaction includes: (a) your name; (b) the name of the company, church, ministry, denomination, or organization on whose behalf you are inquiring or seeking to engage our Services (please note that, because our Services are designed for worship leaders and religious organizations, this information may reveal or imply your religious beliefs or affiliation, which is treated as Special Category Personal Data under applicable law); (c) your email address; (d) your phone number (and, where applicable, your WhatsApp number, which may be used by our customer service and sales teams as a primary means of communication in countries where WhatsApp is a common communication platform); and (e) payment and billing information. We may also need to know some technical information about the device(s) on which you want to use our Services (collectively, your "Personal Information").

As is true of most websites, we gather certain information automatically. This information, which is also included in the scope of your Personal Information may include internet protocol addresses, browser type, internet service provider, time zone, referring/exit pages, the files viewed on our Platforms (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Platforms. We collect this type of device information using the following technologies:

• "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.
• "Log files" track actions occurring on the Website, and collect data including your IP address, browser type, Internet Service Provider, referring/exit pages, and date/time stamps.
• "Web beacons," "tags," and "pixels" are electronic files used to record information about how you browse the Website.

Whenever you create an account with us you agree and acknowledge that you are intentionally providing your Personal Information in compliance with the laws and regulations applicable to you.

If you are from the European Economic Area ("EEA"), our legal basis for collecting and using the personal information described in this Privacy Policy is based on Art. 6(1)(B) of the General Data Privacy Regulation ("GDPR") (performance of a contract); Art. 6(1)(f) GDPR (balancing of interests, based on our legitimate interest in constantly and profitably improving the content, functionality and attractiveness of our Platforms by analyzing your usage, and in conducting internal business analytics, including engagement scoring, customer segmentation, and related analysis using automated or AI-assisted tools, as further described below); Art. 6(1)(c) (necessary for compliance with a legal obligation to which we are subject); and/or Art. 6(1)(a) of the GDPR (consent), depending on the Personal Data we collect and the specific context in which we collect it. For the purposes of this Privacy Policy, "Personal Data" shall mean any information relating to an identified or identifiable natural person ('data subject') - this includes names, identification numbers, location data, online identifiers, and factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.

Special Category Personal Data - Religious Beliefs and Affiliation:

MultiTracks.com provides services specifically designed for worship leaders and religious organizations. Accordingly, the information you provide to us - including the name of your organization, ministry, church, or denomination - may reveal or imply your religious beliefs or religious affiliation. Under GDPR Article 9(1), religious beliefs constitute Special Category Personal Data, which is subject to heightened protections. Where we process such Special Category Personal Data, we do so only on the basis of your explicit consent under Art. 9(2)(a) GDPR, which you provide by affirmatively agreeing to this Privacy Policy and our Terms of Use and License, or as otherwise permitted under Art. 9(2) GDPR (for example, where such processing is necessary for the establishment, exercise, or defense of legal claims under Art. 9(2)(f)). This Special Category Personal Data - to the extent it is incidentally contained in your account information - may be accessed by our third-party service providers listed in this Privacy Policy, including but not limited to our customer support, project management, and artificial intelligence tool providers, solely for the purpose of providing our Services to you. You have the right to withdraw your explicit consent to the processing of Special Category Personal Data at any time by contacting us at privacy@multitracks.com, provided that such withdrawal will not affect the lawfulness of any processing carried out prior to the withdrawal of consent.

AI-Assisted Analytics, Engagement Scoring, and Segmentation:

We may use automated tools and artificial intelligence-assisted platforms to analyze your usage of our Platforms and Services for internal business purposes, including engagement scoring, customer segmentation, and related analytics (collectively, "AI Analytics"). Where such AI Analytics do not involve Special Category Personal Data and do not produce decisions that have a legal or similarly significant effect on you, we rely on our legitimate interests under Art. 6(1)(f) GDPR as the legal basis for such processing, having balanced those interests against your rights and freedoms. Where AI Analytics may involve incidental processing of Special Category Personal Data (such as data revealing your religious affiliation), we rely on your explicit consent under Art. 9(2)(a) GDPR. Where AI Analytics produce or significantly influence a decision that has a legal or similarly significant effect on you, we will either (a) rely on your explicit consent under Art. 6(1)(a) GDPR, (b) rely on the necessity of the processing for the performance of a contract with you under Art. 6(1)(b) GDPR, or (c) ensure that you are informed of such processing and provided with the right to obtain human review, to express your point of view, and to contest the decision, in accordance with Art. 22 GDPR. You have the right to object at any time, on grounds relating to your particular situation, to processing of your Personal Data carried out on the basis of our legitimate interests under Art. 6(1)(f) GDPR, including profiling based on those provisions, by contacting us at privacy@multitracks.com. Upon receipt of a valid objection, we will cease such processing unless we demonstrate compelling legitimate grounds for the processing that overrides your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

We may process your Personal Data because:

• You have given us permission or consent to do so;
• To provide you with our Services as requested by you;
• To process payments;
• To comply with a contract;
• To comply with the legal obligation to which we are subject; and
• Based on our legitimate interests in constantly and profitably improving the content, functionality and attractiveness of the Platforms and/or our Services by analyzing your usage of either or both.

How we use your Personal Information:

We use the information we collect from you for the following purposes, including through the use of third-party service providers and internal business tools such as customer support platforms, project management software, and artificial intelligence tools, as further described in the "Third-Party Service Providers" section of this Privacy Policy:

• To provide, maintain, and to communicate with you about our Services, including via email, phone, or messaging platforms such as WhatsApp where applicable
• To identify your preferences
• To provide you information about our other Services that might be of interest to you
• To comply with our internal record-keeping needs or legal compliance needs
• To notify you about changes to our Services
• To allow you the option to participate in interactive features of our Services
• To detect, prevent, and address technical issues
• To provide you with customer support
• To improve our Services through information analysis
• To protect or otherwise investigate our Services regarding misuse, security breaches, prevention, detection, mitigation, or investigation of fraud, or other potentially prohibited or illegal activities and/or attempts to interfere with the Platforms or Services or to harm others
• With respect to a transfer or sale, including a potential transfer or sale, of any of our assets and/or operations to another party or in the due diligence process in line with a potential transfer or sale
• To determine your level of engagement
• Monitor and improve the information security of the Platforms and/or our Services
• Comply with governmental regulations or to respond to a subpoena or other governmental, court, administrative, Member State, Supervisory Authority or other legal requirement (as those terms are defined by applicable law)
• Hire, train and/or manage our staff/employees
• To enforce our Terms of Use and License Agreement, this Privacy Policy or other policies, and to monitor for violations of our policies or applicable laws
• Combine with information we receive from other sources for the purposes set out in this Privacy Policy
• Any other purpose communicated to you at the time of collecting the Personal Information and if required by law for which consent has been obtained

How we share (or don't share) any Personal Information:

Your Personal Information is not sold, rented or leased to other organizations for commercial/business purposes and has not been in the last 12 months immediately preceding the effective date of this Privacy Policy.

Your Personal Information is only shared with third parties in order to provide the Services you have requested.

Specifically, we work with third-party service providers that supply website and application development, hosting, maintenance, storage, virtual infrastructure, payment processing, analysis, and other services for us, which may require them to access or use your Personal Information.

Social media and other websites that you visit:

This Privacy Policy only applies to our Platforms and Services and does not apply to the following:

1. Any social media posts or comments that you make which are about us or addressed to us on social media platforms or websites (for example, X (formerly Twitter), Instagram, LinkedIn and Facebook). Any such posts or comments will be shared by you under the terms of the relevant social media platform or website on which they are published.
2. Links contained on the Platforms and Services, including links to any advertisers or other third parties.
3. We recommend that you review the terms and conditions and privacy policies of the relevant social media platforms and other websites or apps you visit, to understand how they use your information.

How you can update and control your Personal Information:

You can update certain information related to you and your account through our Platforms. If you wish to have your account deactivated, please contact us at support@multitracks.com. If you wish to be removed from our email list either select the "Unsubscribe" link at the bottom of an email received from us or contact support@multitracks.com.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. MultiTracks.com LLC aims to take reasonable steps to allow you to update, control, and limit the use of your Personal Data. If you wish to exercise any of these rights, contact privacy@multitracks.com. You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in the European Economic Area (EEA).

Do not track (including California and Delaware do not track disclosures):

Some internet browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the "Do Not Track" signal, we do not currently interpret, respond to or alter its practices when it receives "Do Not Track" signals.

Consent to receive electronic notifications:

Electronic communication is the most effective and timely way to provide the users of the Platforms and Services with any optional or required notifications and disclosures. In some circumstances, however, applicable laws may require us to send you disclosures or communications in paper format unless you have affirmatively consented to receiving electronic notifications only in advance of the notification. Through this Privacy Policy, pursuant to 15 U.S.C. § 7001, you hereby affirmatively consent to receive electronic notifications and disclosures from us only (without requiring a paper copy) and you represent that, to date, you have not withdrawn such consent. By providing your phone number during registration, you also consent to receive communications from us via phone call, SMS/text message, or messaging platforms (such as WhatsApp, where applicable) for customer service, account-related, and transactional purposes. Standard message and data rates may apply. You have the right to change your mind and withdraw your consent at any time. If you would like to withdraw your consent to receive electronic notifications, phone or messaging communications, and/or would like to request paper copies of any electronic notifications you receive, you may contact us at privacy@multitracks.com or via mail at Designated Privacy Officer, MultiTracks.com LLC, 1500 Arrow Point Dr. Building VII Ste 701, Cedar Park, TX 78613. To receive electronic records, you will need access to a smart phone, tablet, laptop or computer with internet access and an email account.

Other important privacy information:

Third-party service providers:

The following third parties, as well as other third-party service providers used for internal business operations (including but not limited to customer support, project management, messaging platforms, and artificial intelligence tools), may have access to your Personal Information but only to perform tasks on our behalf. All such third parties are obligated not to disclose or use your Personal Information for any other purpose. Where required by applicable law, we have entered into or will enter into data processing agreements with these providers.

• Google Analytics is a service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Platforms. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on our Platforms available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents the Google Analytics JavaScript (e.g., ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about web activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/
• Facebook Conversion Tracking Pixel is a tool that allows us to follow your actions after you are redirected to our Platforms by clicking on a Facebook advertisement. We are thus able to record the effectiveness of our advertisements. The data collected is not personally identifiable. Facebook cannot see your Personal Information; however, the collected data is saved and processed by Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with their own privacy policy at: https://www.facebook.com/about/privacy/. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. A cookie will be saved onto your computer for these purposes. By using our Platforms, you agree to the data processing associated with the integration of Facebook Pixel. You can revoke your permission at: https://www.facebook.com/ads/settings.
• Apple Store In-App Payments is a feature that allows you to purchase some of our services, products, or licenses through our products sold on Apple's App Store. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/.
• Authorize.net is the third-party service provider we use for payment processing on our Platforms. Their privacy policy can be viewed at https://www.authorize.net/company/privacy.
• Intercom is a third-party service provider we use to assist us with customer support. When you use support on our Platforms by clicking "Support" at the top of our Platforms, you are redirected into their system. Their system may write cookies, and they may retain your personal information. You can view their privacy policy at https://www.intercom.com/legal/privacy
• Atlassian is a third-party service provider we use for internal project management and customer support operations, including through its Jira Service Management platform. Personal Information such as your name, email address, and organization name may be accessed by our team through this platform in connection with processing your support requests or managing internal workflows related to your account. You can view their privacy policy at https://www.atlassian.com/legal/privacy-policy
• Hubspot is a third-party service provider for email campaigns, marketing automation, marketing analytics, and serves as our Customer Relationship Manager (CRM). Personal Information such as your name, email address, phone number, and organization name may be stored and processed by HubSpot in connection with our customer relationship management and marketing operations. You can view their privacy policy at https://legal.hubspot.com/privacy-policy
• EBANX is a third-party service provider we use for payment processing on our Platforms. Their privacy policy can be viewed at https://business.ebanx.com/en/legal-terms/for-customers/privacy-policy
• Anrok is a third-party service provider we use to assist us with calculating, collecting, and remitting US state sales tax. Their privacy policy can be viewed at https://www.anrok.com/privacy-terms
• Microsoft is a third-party provider we use for various purposes such as data processing and website and app performance analytics across all products. Their privacy policy can be viewed at https://privacy.microsoft.com/en-us/privacystatement
• Anthropic, PBC is a third-party artificial intelligence service provider whose AI assistant platform ("Claude") we may use for internal business operations, including customer support assistance, content generation, and operational workflows. In the course of such use, certain Personal Information - such as your name, email address, and the name of your organization or worship ministry - may be incidentally included in inputs submitted to the platform by our staff. We do not intentionally submit your Personal Information to AI platforms for training purposes, and we take reasonable steps to minimize the Personal Information shared with AI tools. Anthropic's privacy policy can be viewed at https://www.anthropic.com/legal/privacy
• Facebook Login is a social authentication service offered by Meta Platforms, Inc. that allows you to log in to our Platforms using your existing Facebook account credentials. When you use Facebook Login, Meta may place a session cookie on your device and receive data about the authentication event, including authentication identifiers and associated session data. X Login is a social authentication service offered by X Corp. that allows you to log in to our Platforms using your existing X (formerly Twitter) account credentials. When you use X Login, X Corp. may place a session cookie on your device and receive data about the authentication event. Use of Facebook Login and X is entirely optional; standard account registration and login remain available at all times. For more information on the privacy practices of Meta, please visit: https://www.facebook.com/about/privacy/. You can manage your Facebook application permissions at: https://www.facebook.com/settings?tab=applications. For more information on the privacy practices of X, please visit: https://x.com/en/privacy.

EEA data subject protection rights under the GDPR:

If you are a resident of the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

If you wish to be informed about what Personal Information we hold about you, have a copy of it, correct or otherwise rectify it, and/or if you want it to be removed from our systems, please contact us using the contact information set out below or fill-out and submit this form.

In certain circumstances, you have the following data protection rights:

• Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you where we are the data controller and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be explained to you, if applicable, at the time of your request.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request that we restrict the processing of your Personal Information. This enables you to ask us to temporarily stop the processing of your Personal Information in the following scenarios: (a) if you have concerns about the accuracy of your information and want to have it rectified; (b) where you believe our use of your information may be unlawful but you do not want us to erase it; (c) where you need us to hold the information for the purposes of defending or exercising your rights with respect to a legal claim even though we may no longer need it; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to keep it.
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided with your consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. If you are located in the EEA, please contact your local data protection authority in the EEA. If you are located in the United Kingdom, you may contact the Information Commissioner's Office (ICO). If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner (FDPIC).

If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, taking into account the administrative costs of providing the information or communication or taking the action requested. Alternatively, we may refuse to comply with your request in such circumstances, and we will inform you of the reasons for our refusal.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure designed to ensure that Personal Information is not disclosed to any person who has no right to receive it. We will only request information that is reasonably necessary for verification purposes. We may also contact you to ask you for further information in relation to your request to speed up our response.

For users in the EEA, the United Kingdom, or Switzerland, we will notify you of any material changes to this Privacy Policy at least 30 days before they take effect by virtue of a pop-up, banner, email notification, or other notification mechanism when you seek to access the Website or Services. For changes that require your consent under applicable law, such changes will only be effective upon your express consent. If you do not consent to material changes, you may terminate your use of the Services, and we will process your personal information in accordance with the Privacy Policy under which it was originally collected, to the extent legally permissible. Upon consent, the revisions on the Website or Services shall apply to all use of the Website or Services and all acts or omissions occurring after the effective date of the revised Privacy Policy.

Notice to California, Nevada, and Utah residents:

We do not disclose a user's personal data to any third party for such third-party's direct marketing purposes. Nevada S.B.220 allows Nevada residents to opt-out of the sale of their personal information now in the event we change our Privacy Policy in the future. If you are a Nevada resident we want you to know that, in the event we sell your Personal Information, you will have choices and can opt-out and can affect them by contacting us at privacy@multitracks.com or via mail at Designated Privacy Officer, MultiTracks.com LLC, 1500 Arrow Point Dr. Building VII Ste 701, Cedar Park, TX 78613. This may prevent or restrict your use of the Services in the future.

California Data Subject Rights:

Shine the Light Law

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal Information that we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to privacy@multitracks.com or via mail at Designated Privacy Officer, MultiTracks.com LLC, 1500 Arrow Point Dr. Building VII Ste 701, Cedar Park, TX 78613. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.

The California Consumer Protection Act (CCPA) and the California Privacy Rights Act (CPRA)

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

• Right to Know. You have the right to, up to twice in a 12-month period, request what categories and specific pieces of Personal Information we collect, use, disclose, share and/or sell, as applicable. You may make a request for this information twice within a 12-month period. You may request any or all of the following: The categories of personal information we have collected about you in the preceding 12 months; the categories of sources from which the personal information has been collected about you in the preceding 12 months; the business or commercial purpose for collecting or selling your personal information in the preceding 12 months; the categories of third parties with whom we have shared your personal information in the preceding 12 months; the categories of your personal information that we sold and the categories of third parties to whom the personal information was sold in the preceding 12 months, listed by category or categories of personal information for each third party to whom your personal information was sold; the categories of your personal information that we disclosed for a business purpose in the preceding 12 months; and/or the specific pieces of personal information we have collected about you.
• Right to Delete. You have the right to request the deletion of your Personal Information that is collected by us.
• Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the sale and sharing of your Personal Information by a business. However, as noted above, we do not currently share or sell any Personal Information. Please note that, for the purposes of this Privacy Policy "sharing" means to share your Personal Information with third parties for the purpose of cross-context behavioral marketing/targeting only.
• Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
• Right to Data Portability. You have the right to request a copy of your Personal Information we have collected and maintained about you in the past 12 months.

Please note that if you request deletion of your Personal Information we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
• Comply with a legal obligation.
• Otherwise use the personal data, internally, in a lawful manner that is compatible with the context in which you provided the information.

Any request you submit to us is subject to an identification and residency verification process ("Verifiable Consumer Request") as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. To process requests about categories of information about you, we require that you provide at least two pieces of personal information that match the personal information we maintain about you. For example, if we collect your name, email and address, we may request you provide us with your name, email, zip code or other pieces of information that we can verify. These rights are also subject to various exclusions and exceptions under applicable laws.

In your request for deletion, specify what information you are requesting to be deleted or state that you are requesting all information we have collected or maintain about you be deleted. Please provide us with an email address to contact you at. If you do not have an email address, please provide either a telephone number and/or postal mailing address to contact you.

You may designate an authorized agent to make a request under the California Consumer Protection Act by providing the authorized agent with written permission to do so or when you have provided the authorized agent power of attorney pursuant to Probate Code sections 4000 to 4465.

We will require the authorized agent to submit proof that they have been authorized by you to act on their behalf, and, except in cases where you have provided the authorized agent power of attorney, we may require that you verify your identity with us. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to privacy@multitracks.com.

We have not sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. We do not knowingly collect, sell or share the Personal Information of minors under 18 years of age.

We do not provide a mechanism for opting-out of the sale or sharing of your Personal Information because we do not sell or share personal information we collect. If we decide to sell or share Personal Information in the future, we will provide a notice of the right to opt-out in this Privacy Policy. We do not sell or share Personal Information collected during the time period during which a notice of opt-out is not posted.

We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13 as we do not collect personal information from any person under the age of 13.

We will respond to your request within 45 days after receipt of a Verifiable Consumer Request for a period covering 12 months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days.

You may exercise any of the rights described in this section by filling out and submitting this form yourself, by having your agent fill out and submit this form on your behalf or sending an email to: privacy@multitracks.com with "California Privacy Rights" as the subject line or mail us a letter to: Designated Privacy Officer, MultiTracks.com LLC, 1500 Arrow Point Dr. Building VII Ste 701, Cedar Park, TX 78613.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We do not currently offer financial incentives or price or service differences online to consumers in exchange for the retention and/or sale of their information.

We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy and may be disclosed to others without limitation and for any purpose.

We do not currently share information about you with third parties for those third parties' direct marketing purposes, but we may in the future elect to do so. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of Personal Information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of Personal Information shared by us and the names and addresses of all third parties that received Personal Information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2026 will receive information about 2025 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to privacy@multitracks.com, with "California Privacy Rights" as the subject line or mail us a letter to our attention at Designated Privacy Officer, MultiTracks.com LLC, 1500 Arrow Point Dr. Building VII Ste 701, Cedar Park, TX 78613. You must include your full name, email address with which you registered on our Platforms or to use our Services, and postal address in your request.

California consumers with disabilities may contact us by phone at 737-232-5518 or email us at privacy@multitracks.com for information on how to access this notice in an alternative format.

Cookie Policy:

Our website and Mobile Apps use cookies and similar tracking technologies (collectively, "Cookies") including pixels, tags, web beacons, and scripts. This section explains what Cookies we use, why we use them, and how you can control them.

What Are Cookies? Cookies are small data files placed on your device or computer when you visit our Platforms. Some Cookies are placed by us directly; others are placed by third parties operating on our behalf (see the "Third-Party Service Providers" section above). Cookies may collect routing, addressing, signaling, or other identifying information about your electronic communications with our Platforms.

California Law Notice: Our website uses tracking technologies that function as "pen registers" or "trap and trace devices" as defined under California Penal Code Section 638.51. These technologies capture and transmit routing, addressing, and signaling information about your electronic communications with our website. In compliance with the California Invasion of Privacy Act (California Penal Code 638.50-638.52), we request your affirmative, informed consent before placing non-essential Cookies or activating non-essential tracking technologies. We only install and use non-essential Cookies with your express consent, as required by California law.

Categories of Cookies We Use:

1. Strictly Necessary Cookies. These Cookies are essential for our Platforms to function and cannot be disabled. They are set in response to actions made by you, such as logging into your account, completing a purchase, or setting your privacy preferences. These Cookies do not collect personal information for marketing purposes and do not require your consent. Examples include session authentication tokens, shopping cart data, and security cookies.
2. Functional / Preference Cookies. These Cookies allow our Platforms to remember choices you make (such as language, region, or display preferences) and provide enhanced, personalized features. They may be set by us or by third-party providers whose services we have added to our Platforms. If you do not allow these Cookies, some or all of these features may not function properly.
3. Analytics / Performance Cookies. These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Platforms. They help us understand which pages are most and least popular and how visitors move around our Platforms. All information collected by these Cookies is aggregated. If you do not allow these Cookies, we will not know when you have visited our Platforms and will not be able to monitor performance.
4. Targeting / Advertising Cookies (including tracking pixels). These Cookies may be set through our Platforms by our advertising partners to build a profile of your interests and show you relevant advertisements on other sites. They do not directly store personal information but are based on uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.
5. Social Login Cookies. These Cookies are set when you choose to authenticate using a third-party social platform account ("Social Login"), such as Facebook Login or X Login. When you use Social Login, the applicable third-party platform (e.g., Meta Platforms, Inc. or X Corp.) places a session cookie on your device to authenticate your session and may receive data about the authentication event. Social Login is an optional feature; you may register and log in to our Platforms using our standard account registration process instead. If you do not allow these Cookies, you will not be able to use the Social Login feature, but you may still access our Platforms and Services using standard registration and login.

Specific Tracking Technologies We Use:

Google Analytics (Analytics / Performance Cookies): A service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Platforms. Data collected includes IP addresses (anonymized where required by law), device information, browser type, operating system, browsing patterns, session data, and referring/exit pages. This information is transmitted to and processed by Google LLC. Google may use the collected data to contextualize and personalize the ads of its own advertising network. Cookie retention period: up to 2 years. You can opt-out of having your activity on our Platforms available to Google Analytics by installing the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout. This add-on prevents the Google Analytics JavaScript (e.g., ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about web activity. For more information on the privacy practices of Google, please visit: https://www.google.com/intl/en/policies/privacy/

Meta / Facebook Conversion Tracking Pixel (Targeting / Advertising Cookies): A tool that allows us to follow your actions after you are redirected to our Platforms by clicking on a Facebook advertisement, enabling us to record the effectiveness of our advertisements. Data collected includes interactions with our Platforms, device fingerprinting, unique device identifiers, IP addresses, and browsing behavior correlated with your Facebook account. This information is transmitted to and processed by Meta Platforms, Inc. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside of Facebook. A Cookie may be saved onto your computer for these purposes. Cookie retention period: up to 180 days. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with their own privacy policy at: https://www.facebook.com/about/privacy/. You can revoke your permission to Facebook at: https://www.facebook.com/ads/settings. For information on Meta's privacy practices, please visit: https://www.facebook.com/about/privacy/.

Social Login - Facebook Login and X Login (Social Login Cookies): Social Login is an optional authentication feature that allows you to log in to our Platforms using your existing Facebook or X account. When you use Social Login, the applicable third-party platform (Meta Platforms, Inc. or X Corp.) may set a session cookie on your device to facilitate and authenticate your login session. Data transmitted to the applicable platform is limited to authentication event data and associated session identifiers; no independent browsing data is collected by us for transmission to these platforms through this feature. Cookie retention period: session-based (cookies are deleted when you end your browser session or log out). Use of Social Login is entirely optional; standard account registration and login are available at all times and are not affected by declining Social Login Cookies. For more information, see the privacy policies of Meta (https://www.facebook.com/about/privacy/) and X (https://www.x.com/en/privacy/).

Cookie Choices and Consent:

We use Cookies and similar technologies (including pixels and tags). In compliance with California law, including the California Invasion of Privacy Act (California Penal Code 638.50-638.52), we request your affirmative, informed consent before placing non-essential Cookies or activating non-essential tracking technologies that may collect routing, addressing, signaling, or other identifying information.

Consent Mechanism: You can accept or reject non-essential Cookies and manage your preferences at any time by clicking [Cookie Preferences] in the footer of our Platforms. We will present you with equal and symmetrical options - including an option to "Accept All" non-essential Cookies, an option to "Decline All" non-essential Cookies, and an option to customize your preferences by category. We will not design our consent interface in a manner that makes it more difficult to decline Cookies than to accept them. Your consent selections will be stored for a period of 12 months, after which we may ask you to renew your preferences.

Strictly Necessary Cookies do not require your consent and cannot be disabled, as they are essential to the functioning of our Platforms. Your ability to access and use our Platforms and Services will not be affected by declining non-essential Cookies, though certain features (such as personalization or targeted advertising) may not function as intended.

Withdrawal of Consent: If you withdraw your consent to non-essential Cookies, we will stop using the relevant technologies going forward and will instruct our third-party partners to cease processing your information for the purposes for which you withdrew consent. However, please note that withdrawal of consent:

1. will not affect the lawfulness of any processing based on consent before its withdrawal;
2. will not delete Cookies or other tracking technologies already stored on your device (you can remove those through your browser settings - visit https://www.allaboutcookies.org for instructions); and
3. will not require third parties to delete information already collected and shared prior to withdrawal, though we will make commercially reasonable efforts to request such deletion where feasible.

Opt-Out Preference Signals: To the extent required by applicable law, we will honor opt-out preference signals (such as the Global Privacy Control) transmitted by your browser as a valid request to opt out of the sale or sharing of your personal information. If we detect a Global Privacy Control signal from your browser, we will treat it as a request to opt out of any sale or sharing of your personal information and will apply it to your device and/or browser.

For Residents of the European Economic Area (EEA), United Kingdom, or Switzerland: Our use of non-essential Cookies is based on your consent under GDPR Article 6(1)(a). You have the right to withdraw your consent to Cookie-based processing at any time without affecting the lawfulness of processing based on consent before its withdrawal. Where our use of Cookies involves the processing of Special Category Personal Data (including data that may reveal your religious beliefs or affiliation, as described above), we rely on your explicit consent under GDPR Article 9(2)(a). You may withdraw either form of consent at any time by using the Cookie Preferences tool or by contacting us at privacy@multitracks.com.

Do Not Track: Some internet browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the "Do Not Track" signal, we do not currently interpret, respond to, or alter our practices when we receive "Do Not Track" signals, except to the extent required by applicable law. Please see the "Do Not Track" section of this Privacy Policy for more information.

For a complete list of the third-party service providers who may place Cookies on our Platforms and their respective privacy policies, please see the "Third-Party Service Providers" section of this Privacy Policy.

Colorado Data Subject Rights

Colorado residents have the right to access, delete, correct, transfer, and opt-out of the sale of their Personal Information under applicable Colorado law. To exercise your rights, email us at privacy@multitracks.com with the subject line "Colorado Data Subject Right Request". If we deny your request to exercise your rights in whole or in part, you may have 45 days from the date you receive our decision to appeal the decision. In such circumstances, you may contact us at privacy@multitracks.com with the subject "Colorado Data Privacy Request Appeal" to provide us with information about details about why you are appealing the decision. In the event you are not satisfied with our response, you may contact the Colorado Attorney General.

In addition, If you are a Colorado resident as of July 1, 2023, you have the right to access, delete, correct, transfer, and opt-out of the sale of your Personal Information for the purposes of targeted advertising, sale to a third party for monetary gain, and/or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer.

You may authorize another person acting on your behalf to opt out of the processing of your Personal Information for any of the reasons set forth above, via a browser setting, browser extension, universal opt-out mechanism that meets the technical specifications established by the attorney general as of July 1, 2024, or global device setting.

Nevada Data Subject Rights

Nevada residents have a right to submit a verified request directing a website operator to not make any "sale" of covered information collected about the consumer for monetary consideration to a person for such person to license or sell the information to additional persons, subject to certain exceptions. If you are a Nevada resident and you would like to opt-out of a future sale of your covered information, you can contact us at privacy@multitracks.com.

Canadian Anti-Spam Legislation ("CASL")

This Section provides additional information regarding the use of Personal Information about Canadian residents and the process to be followed in order to send unsolicited electronic communications to them, and our responsibilities under CASL.

For the purposes of this section:

• Commercial activity: Any transaction of commercial character, regardless of whether there is an expectation of profit or not.
• Commercial electronic message ("CEM"): CEMs are commercial electronic messages that encourage participation in commercial activity. Even if a commercial message is not sent with an expectation of garnering profit, it still qualifies as a CEM.
• Electronic address: An address used in connection with the transmission of an electronic message to an electronic mail account, and instant messaging account, a telephone account or similar account.
• Electronic message: A message sent by any means of telecommunication, including text, sound, voice or image.
• Express consent: Permission obtained when a recipient "opts in" to receive CEMs. Consent can be oral or written and could be an unedited audio recording, paper or electronic checkbox on a website. Express consent never expires unless the recipient chooses to unsubscribe. We will maintain records of all contacts for whom express consent exists.
• Unsubscribe: A withdrawal of consent to receive CEMs.

By submitting forms to us that provide your electronic address (including your email address, phone number, or messaging account such as WhatsApp), you are granting us express consent to send you CEMs via the electronic addresses you have provided. You may unsubscribe via the link found at the bottom of every electronic message or by contacting us at privacy@multitracks.com.

All partners, employees, contractors, vendors and any other person sending CEMs on behalf of us will ensure that all such CEMs contain:

• Full contact information. This includes the sender's first name, last name, title, company name, company mailing address, direct telephone number, electronic address and company web address.
• Information enabling you to contact us and, if the CEM is sent on behalf of another party, the name of this party and the sender, in addition to the information listed above.
• An unsubscribe link that is clearly visible and that is valid for at least 60 days. The unsubscribe mechanism that will be provided to users via this link will be simple, quick and easy for the user to perform.

Unsubscribe Requests: All unsubscribe requests will be managed within 10 days of receipt. Partners, employees, contractors, vendors and any other person sending CEMs on behalf of us will not send an unsubscribed party any further communications by electronic means.

When we plan to introduce significant changes to our privacy practices, we will notify Canadian-resident users and obtain their consent prior to the changes coming into effect. Significant changes include using Personal Information for a new purpose not anticipated originally or a new disclosure of personal information to a third party for a purpose other than processing that is integral to the delivery of a service.

Links to other sites

Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be redirected to that third-party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children's privacy

We do not knowingly collect personally identifiable information from anyone under the age of 13 (16 in the EEA). If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at privacy@multitracks.com. If we become aware that we have collected personal information from anyone under the age of 13 (16 in the EEA) without verification of parental consent, then we will take steps to remove that information from our servers.

What about security

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.

Data Retention Policy

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations, or for other essential purposes such as maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. Please note that Personal Information processed by our third-party service providers - including customer support, project management, and artificial intelligence tool providers - may be subject to those providers' own data retention policies, which we do not control. We take reasonable steps to minimize the Personal Information shared with such platforms and to ensure that our data processing agreements with those providers include appropriate limitations on data retention and use. If you wish to request deletion of your Personal Information from our systems and, to the extent applicable, from the systems of our third-party service providers, please contact us at privacy@multitracks.com.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will email you about the changes and when they will go into effect. Modifications to this Privacy Policy are effective when they are posted on this page and within the Mobile Apps. In the event material changes are made to this Privacy Policy you will be asked to renew your acceptance of this policy the next time you login to your account on our Platforms. If required, we will obtain your consent before the changes go into effect.

Severability and Enforceability

To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Contact Us

State-Specific Privacy Rights: Depending on your state of residence, you may have additional privacy rights. For detailed information about rights available to residents of California, Colorado, Nevada, Utah, and other states with comprehensive privacy laws, please see the "Notice to California, Nevada, and Utah Residents" and related sections of this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us:

Accessibility: If you need this Privacy Policy in an alternative format due to a disability, or if you need assistance submitting a privacy request, please contact us using the methods below and we will work with you to provide reasonable accommodations.

Verification Process: To protect your privacy and security, we may need to verify your identity before processing your request. We will request information such as your name, email address, and other identifying information to match against our records. You may designate an authorized agent to make a request on your behalf by providing written authorization.

By mail:

Designated Privacy Officer
MultiTracks.com LLC
1500 Arrow Point Dr. Building VII Ste 701
Cedar Park, TX 78613
United States of America

For residents of the European Economic Area (EEA), United Kingdom, or Switzerland: You may also contact our Data Protection Officer at privacy@multitracks.com or lodge a complaint with your local supervisory authority.