PRIVACY POLICY

MembersDigital.com

Last Updated: August 20th, 2026

This Privacy Policy ("Policy") describes how Members Digital LLC ("Company," "we," "us," or "our"), a Florida limited liability company with its principal place of business in Hillsborough County, Florida, collects, uses, discloses, and protects your personal information when you visit MembersDigital.com, use our Platform, purchase our Services, or otherwise interact with us. By using our website, Platform, or Services, you consent to the practices described in this Policy.

This Policy should be read in conjunction with our Terms of Service, which are available on MembersDigital.com and incorporated herein by reference.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly. We may collect the following categories of personal information that you voluntarily provide to us:

(a) Contact Information: full name, email address, phone number, mailing address;

(b) Account Information: username, password, account preferences;

(c) Payment Information: credit card or debit card number, billing address, payment history (note: full payment card numbers are processed by our third-party payment processors and are not stored on our servers);

(d) Business Information: business name, title, industry, EIN (for A2P 10DLC registration);

(e) Communications: emails, messages, support tickets, survey responses, and other correspondence with us;

(f) User Content: any content you upload, create, or submit through the Platform;

(g) Marketing Preferences: communication preferences, subscription choices; and

(h) Identity Verification: government-issued identification, if required for compliance purposes.

1.2 Information Collected Automatically. When you access MembersDigital.com or use our Platform, we may automatically collect:

(a) Device Information: device type, operating system, browser type and version, screen resolution;

(b) Usage Data: pages visited, features used, clickstream data, time spent on pages, referring URLs;

(c) Log Data: IP address, access times, server logs, error logs;

(d) Location Data: approximate geographic location based on IP address;

(e) Cookies and Similar Technologies: cookies, web beacons, pixel tags, and similar tracking technologies (see Section 4 below); and

(f) Communication Metadata: date, time, duration, and status of SMS, MMS, email, and voice communications sent through the Platform (message content is not monitored except as required for compliance).

1.3 Information from Third Parties. We may receive information about you from third-party sources, including: (a) payment processors (transaction confirmations and fraud screening data); (b) analytics providers (aggregated usage data); (c) marketing partners (if you opted into cross-promotional communications); and (d) publicly available sources (business directories, public records).

2. HOW WE USE YOUR INFORMATION

2.1 Purposes of Use. We use the information we collect for the following purposes:

(a) to provide, maintain, and improve the Services and Platform;

(b) to process transactions, send invoices, and manage billing;

(c) to create and manage your account;

(d) to communicate with you about your account, Services, and support requests;

(e) to send you marketing and promotional communications (with your consent, where required);

(f) to facilitate SMS, MMS, email, and voice communications through the Platform on your behalf;

(g) to comply with legal obligations, including TCPA record-keeping, A2P 10DLC registration, and tax reporting;

(h) to detect, prevent, and address fraud, security issues, and technical problems;

(i) to enforce our Terms of Service and protect our rights and property;

(j) to monitor compliance with our Acceptable Use Policy and Communications Services requirements;

(k) to conduct analytics and research to improve our Services; and

(l) for any other purpose disclosed to you at the time of collection or with your consent.

2.2 Legal Bases for Processing. We process your personal information based on one or more of the following legal bases: (a) performance of a contract (providing Services you have purchased); (b) legitimate business interests (improving our Services, preventing fraud, enforcing our Terms); (c) compliance with legal obligations; and (d) your consent (marketing communications, cookies).

3. HOW WE SHARE YOUR INFORMATION

3.1 Service Providers. We share your information with third-party service providers who perform services on our behalf, including: (a) payment processors (to process transactions); (b) telecommunications providers (to facilitate SMS, MMS, and voice communications); (c) cloud hosting providers (to store data); (d) email service providers (to send transactional and marketing emails); (e) analytics providers (to analyze usage patterns); and (f) customer support tools. Our service providers are contractually obligated to use your information only for the purposes of providing services to us and are required to maintain appropriate security measures.

3.2 Legal Requirements. We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or when we believe in good faith that disclosure is necessary to: (a) comply with applicable law or legal process; (b) protect the rights, property, or safety of Company, our users, or the public; (c) detect, prevent, or address fraud, security, or technical issues; or (d) enforce our Terms of Service.

3.3 Business Transfers. In the event of a merger, acquisition, reorganization, bankruptcy, dissolution, sale of all or a portion of our assets, or similar transaction, your personal information may be transferred to the acquiring entity. We will provide notice before your information becomes subject to a different privacy policy.

3.4 With Your Consent. We may share your information with third parties when you have provided explicit consent for such sharing.

3.5 No Sale of Personal Information. We do not sell your personal information to third parties for monetary or other valuable consideration. We do not share your personal information with third parties for their direct marketing purposes without your consent.

3.6 Aggregated or De-Identified Data. We may share aggregated or de-identified data that cannot reasonably be used to identify you for analytics, research, marketing, or other business purposes.

4. COOKIES AND TRACKING TECHNOLOGIES

4.1 Types of Cookies. We use the following types of cookies and similar technologies on MembersDigital.com:

(a) Essential Cookies: necessary for the website to function properly, including authentication, security, and session management. These cannot be disabled.

(b) Analytics Cookies: help us understand how visitors interact with our website by collecting information about pages visited, time spent, and navigation patterns. We may use tools such as Google Analytics for this purpose.

(c) Functionality Cookies: remember your preferences and settings to enhance your experience.

(d) Marketing/Advertising Cookies: used to deliver relevant advertisements and track the effectiveness of marketing campaigns. These may include cookies from third-party advertising networks such as Meta (Facebook) Pixel, Google Ads, and similar services.

4.2 Managing Cookies. You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, blocking essential cookies may affect the functionality of the website. You may also opt out of interest-based advertising through the Digital Advertising Alliance (DAA) at www.aboutads.info/choices or the Network Advertising Initiative (NAI) at www.networkadvertising.org/choices.

4.3 Do Not Track. Some browsers transmit "Do Not Track" (DNT) signals. There is currently no universal standard for responding to DNT signals, and our website does not currently respond to DNT signals. However, you may manage your tracking preferences using the methods described above.

5. DATA SECURITY

5.1 Security Measures. We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, use, alteration, or destruction. These measures include encryption of data in transit (SSL/TLS), secure server infrastructure, access controls, and regular security assessments.

5.2 No Absolute Security. No method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security. You acknowledge that you transmit information to us at your own risk.

5.3 Breach Notification. In the event of a data breach that affects your personal information, we will notify you in accordance with applicable law, including the Florida Information Protection Act of 2014, Fla. Stat. § 501.171, which requires notification to affected individuals within thirty (30) days of the determination of a breach, or as soon as reasonably practicable.

6. DATA RETENTION

6.1 Retention Periods. We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Specific retention periods include:

(a) Account data: retained for the duration of your account and for a period of three (3) years following account closure or termination;

(b) Transaction and billing data: retained for seven (7) years for tax and accounting purposes;

(c) Communications compliance records (consent records, opt-out logs, messaging logs): retained for a minimum of five (5) years to support TCPA compliance;

(d) Website analytics data: retained in aggregated form for up to three (3) years; and

(e) Marketing consent records: retained for as long as the consent is active, plus three (3) years after withdrawal.

6.2 Deletion. When personal information is no longer needed, we will securely delete or anonymize it. You may request deletion of your personal information as described in Section 8 below, subject to our legal and contractual retention obligations.

7. CHILDREN'S PRIVACY

7.1 COPPA Compliance. Our website, Platform, and Services are not directed to children under the age of thirteen (13). We do not knowingly collect personal information from children under thirteen (13). If we learn that we have collected personal information from a child under thirteen (13) without verification of parental consent, we will promptly delete that information. If you believe we have collected information from a child under thirteen (13), please contact us immediately at the contact information provided below.

7.2 Age Requirement. You must be at least eighteen (18) years of age to create an account, purchase Services, or use the Platform. By using MembersDigital.com, you represent and warrant that you are at least eighteen (18) years of age.

8. YOUR RIGHTS AND CHOICES

8.1 General Rights. Depending on your jurisdiction, you may have the following rights regarding your personal information: (a) the right to access and obtain a copy of your personal information; (b) the right to correct inaccurate personal information; (c) the right to request deletion of your personal information; (d) the right to restrict or object to processing; (e) the right to data portability; and (f) the right to withdraw consent. To exercise any of these rights, contact us using the information in Section 13 below.

8.2 Marketing Communications. You may opt out of receiving marketing communications from us at any time by: (a) clicking the "unsubscribe" link in any marketing email; (b) replying "STOP" to any marketing SMS or MMS message; or (c) contacting us directly. Please note that you may continue to receive transactional communications (e.g., account notifications, billing confirmations, service updates) even after opting out of marketing communications.

8.3 Account Information. You may review and update your account information at any time by logging into your account on the Platform. If you wish to close your account, contact us using the information in Section 13.

9. CALIFORNIA RESIDENTS — CCPA/CPRA NOTICE

9.1 Applicability. This Section applies to residents of California and supplements the information in this Privacy Policy. If the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act of 2020 ("CPRA"), applies to our processing of your personal information, you have the following additional rights.

9.2 Categories of Information. In the preceding twelve (12) months, we may have collected, used, and disclosed the following categories of personal information as described in Section 1 of this Policy: (a) identifiers (name, email, phone, IP address); (b) personal information under Cal. Civ. Code § 1798.80(e) (name, address, credit card number); (c) commercial information (purchase history, products or services purchased); (d) internet or electronic network activity (browsing history, search history, interaction with website); (e) geolocation data (approximate location from IP address); and (f) professional or employment-related information (business name, title).

9.3 Your CCPA/CPRA Rights. As a California resident, you have the right to: (a) know what personal information we collect, use, and disclose about you; (b) request deletion of your personal information, subject to certain exceptions; (c) opt out of the sale or sharing of your personal information (we do not sell your personal information); (d) correct inaccurate personal information; (e) limit the use of sensitive personal information; and (f) not be discriminated against for exercising your privacy rights.

9.4 Exercising Your Rights. To exercise your CCPA/CPRA rights, you may: (a) submit a request through the contact information in Section 13; or (b) email us at the address listed on MembersDigital.com with the subject line "CCPA Request." We will verify your identity before processing your request. We will respond to verifiable requests within forty-five (45) days, with one extension of forty-five (45) days if reasonably necessary.

9.5 Authorized Agent. You may designate an authorized agent to submit requests on your behalf. We may require the agent to provide proof of your written authorization and may verify your identity directly.

9.6 Financial Incentives. We may offer financial incentives (such as discounts or free content) in exchange for your personal information. Participation is voluntary, and you may opt out at any time. The value of the incentive is reasonably related to the value of the personal information provided.

10. RESIDENTS OF OTHER STATES — ADDITIONAL PRIVACY RIGHTS

10.1 Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and Other States. If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Tennessee, Indiana, or another state with a comprehensive consumer privacy law, you may have similar rights to those described in Section 9, including the right to access, correct, delete, and opt out of certain processing of your personal information. To exercise your rights, contact us using the information in Section 13. We will respond within the timeframe required by your state's applicable law.

10.2 Appeal Process. If we deny your privacy rights request, you may appeal our decision by contacting us in writing with the subject line "Privacy Rights Appeal." We will respond to your appeal within the timeframe required by applicable law. If your appeal is denied, you may have the right to contact your state's attorney general.

11. FLORIDA-SPECIFIC DISCLOSURES

11.1 Florida Information Protection Act. In accordance with the Florida Information Protection Act of 2014, Fla. Stat. § 501.171, we will notify affected Florida residents of any breach of security involving their personal information within thirty (30) days of determining that a breach has occurred, or as soon as reasonably practicable. If a breach affects more than five hundred (500) individuals in Florida, we will also notify the Florida Department of Legal Affairs.

11.2 Florida Deceptive and Unfair Trade Practices Act. Our data collection and use practices are designed to comply with the Florida Deceptive and Unfair Trade Practices Act ("FDUTPA"), Fla. Stat. § 501.204. We do not engage in unfair or deceptive acts or practices in the collection, use, or disclosure of personal information.

11.3 Social Security Number Protection. We do not collect Social Security numbers through MembersDigital.com or the Platform. If we are ever required to collect Social Security numbers for tax or compliance purposes, we will protect such information in accordance with Florida Statute § 501.171 and all applicable law.

12. INTERNATIONAL DATA TRANSFERS

12.1 Location of Processing. Your personal information is primarily processed and stored in the United States. If you access MembersDigital.com from outside the United States, you acknowledge and consent to the transfer, processing, and storage of your personal information in the United States, where data protection laws may differ from those of your country.

12.2 GDPR (EU/EEA Residents). If you are located in the European Union or European Economic Area, we will process your personal information in compliance with the General Data Protection Regulation ("GDPR") where applicable. You may have additional rights under the GDPR, including the right to lodge a complaint with your local data protection authority. For purposes of the GDPR, Members Digital LLC acts as a data controller with respect to personal information we collect directly from you.

13. CONTACT INFORMATION

13.1 Contact Us. If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Members Digital LLC

Hillsborough County, Florida

Website: MembersDigital.com

Email: [email protected]

Phone: 888-450-8707

13.2 Privacy Requests. For all privacy-related requests (access, deletion, correction, opt-out), please email us with the subject line "Privacy Request" and include your full name, email address associated with your account, and a description of your request. We will respond within the timeframe required by applicable law.

14. CHANGES TO THIS PRIVACY POLICY

14.1 Updates. We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will indicate the date of the most recent update at the top of this Policy. Material changes will be communicated by posting a prominent notice on MembersDigital.com or by sending you an email notification. Your continued use of the website, Platform, or Services after any changes constitutes your acceptance of the updated Privacy Policy.