MC5 ADVISORY PRIVACY POLICY

Effective: October 22, 2025

MC5 Advisory, LLC (the “Company”) is committed to maintain robust privacy protections for its users (defined in Section I). The Company’s Privacy Policy (the “Policy”) is designed to help you understand how the Company collects, uses and safeguards the information you provide to us and to assist you in making informed decisions when enrolling in our Program as defined in Section I below.

1. DEFINITIONS

In addition to certain words and phrases defined in the body of this Policy (i.e., “Information”), the following definitions apply to this Policy.

For purposes of this Policy, “Site” refers to the Company’s website, www.mc5advisory.com.

“AI Agent” refers to our proprietary artificial-intelligence–driven tool and any related AI-powered interfaces that we make available through the Site or in connection with a Program.

“AI Agent Inputs” and “AI Agent Outputs” mean, respectively, (a) prompts, questions, or other data you submit into the AI Agent, and (b) responses, text, recommendations, or other content generated by the AI Agent based on those Inputs. AI Agent Inputs and Outputs may, in some cases, include Personal Information.

“Program” refers to the Company’s Multifaceted Sales Framework© (MSF©) Program, including the online educational course, the community platform, program materials, live group sessions, the follow-up session, and any complimentary or optional access to the AI Agent or other tools the Company may make available.

The terms “we,” “us” and “our” refer to the Company.

“You,” “your” and “users” refer to any person and/or entity that accesses the Site and/or enrolls in a Program.

2. CONSENT/AGREEMENT TO THIS POLICY

By accessing our Site and/or enrolling in a Program, you consent and agree to all of the provisions in this Policy and in the Company’s Terms and Conditions, and you consent to our collection, storage, use, and disclosure of your Information (defined in Section 3) as described in this Policy, including Information processed through any AI-powered tools we provide (such as the AI Agent)..

3. INFORMATION WE COLLECT

We collect “Non-Personal Information” and “Personal Information” (collectively, the “Information”). Non-Personal Information is defined under this Policy as information that cannot be used to personally identify you, including, but not limited to, anonymous usage data, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and the number of clicks. Personal Information includes, but is not limited to, the following: 1), first and last name; 2) email address; 3) phone number; and 4) certain Program records. The circumstances pursuant to which information is collected, and the type of information collected (i.e., Non-Personal and Personal Information) are listed immediately below.

Contact and Identify Information.

We may collect the following information when you fill out forms, enroll in and/or contact us regarding the Program:

  • First and last name;
  • Email address;
  • Phone number;
  • Organization or company name; and
  • Job title.

Account and Transaction Information.

We collect the following information when you create an account with us, enroll in a Program, and/or make a purchase from us:

  • Username and hashed password;
  • Purchase and payment history;
  • Subscription plan and status; and
  • Membership level and/or access status.

Program Enrollment Information.

We collect the following information when you enroll in a Program:

  • Program enrollment and completion records;
  • Program progress and quiz results; and
  • Frequency of accessing and watching Program videos.

Marketing and Communication Data.

We collect the following information via your email communications with us, and upon your interaction with our forms relating to the Program and the Site:

  • Email engagement metrics (i.e., opens, clicks);
  • Preferences and segmentation tags (i.e., Program interest, Program waitlist status); and
  • Form submission dates (i.e., date/time, content, page URL).

Community Profile Information.

We may collect the following information if you join our online community:

  • Public profile information (i.e., display name, avatar, bio); and
  • Posts, comments, and/or other community interactions.

AI Agent Data.
 If you are granted access to our AI Agent (whether as part of a Program or on a trial or evaluation basis), we may collect and process the following Information:

  • AI Agent Inputs: the prompts, questions, context, or other content you enter into the AI Agent;

  • AI Agent Outputs: the responses, recommendations, or other content generated by the AI Agent that may be associated with your account; and

  • AI Agent usage data: technical and usage information related to your use of the AI Agent, such as timestamps, frequency of use, general log information, IP address, browser type, and error or diagnostic logs.

Although we do not require you to include Personal Information in your AI Agent Inputs, you may choose to do so. To protect your privacy, we encourage you not to include sensitive Personal Information in your AI Agent Inputs unless it is strictly necessary for your use of the Program or the AI Agent.

Technical and Tracking Information.

We collect automatically and via integrated tools the following information:

  • IP address;
  • Device and browser type;
  • UTM parameters and referral source (i.e., LinkedIn, email link); and
  • Page visit date and submission timestamps.

4. CHILDREN’S POLICY

The Site and the Program are not directed to anyone under the age of eighteen (18). The Site does not knowingly collect or solicit information from anyone under the age of 18 or allow anyone under the age of 18 to sign up for the Program. In the event we learn we gathered Information from anyone under the age of 18 without the consent of a parent or guardian, we will delete the Information as soon as possible. If you believe we collected Information relating to a minor, please contact us at privacy@mc5advisory.com.

5. COOKIES

We use cookies and similar tracking technologies to improve your experience on our Site and as an enrollee of the Program. Cookies help us:

  • Keep you logged in and remember your preferences;
  • Process purchases and manage access to our program materials and community;
  • Provide secure video playback and protect our content;
  • Understand how visitors use our Site so we can improve it; and
  • Integrate with trusted third-party tools like email forms, scheduling links and Program software.

These cookies and similar technologies may also be used to support the operation, security, performance monitoring, and usage analytics of any AI-powered tools we provide, including the AI Agent.

6. HOW WE USE AND SHARE INFORMATION

Personal Information

We do not sell, trade, rent, or otherwise share your Personal Information with third parties for marketing purposes without your explicit consent.

We may use testimonials provided by Participants—including video or written statements—for marketing purposes, consistent with the Program Terms and Conditions.

We may share Personal Information with trusted third-party service providers who help us operate our website, communicate with users, fulfill transactions, or deliver services. These providers include hosting services, email platforms, payment processors, customer service tools, and analytics solutions. Where applicable, these service providers are contractually obligated to use your data solely for the purposes defined by us, and in compliance with applicable data protection laws.

AI Agent Processing
When you use the AI Agent, we process your AI Agent Inputs and AI Agent Outputs in order to:

  • generate responses and operate the AI Agent;
  • maintain and improve the reliability, safety, and quality of the AI Agent;
  • monitor for abuse, misuse, or security threats; and
  • provide support or troubleshoot technical issues.

We may use trusted third-party artificial intelligence infrastructure providers to host or process AI Agent Inputs and Outputs solely for these purposes. Where we engage such providers, they act as our service providers or processors and are contractually obligated to use your data only on our instructions and to implement appropriate security and privacy protections. We do not use your AI Agent Inputs or Outputs to train foundation models operated by third parties.

If any of these providers process Personal Information outside of the European Economic Area (EEA), we require that they implement appropriate safeguards to ensure the lawful and secure transfer of personal data. This may include the use of the European Commission’s Standard Contractual Clauses (SCCs) or other approved mechanisms under the GDPR.

We also use embedded third-party services, such as secure video streaming providers to deliver program content and other media. These services do not receive personal information directly from us. However, they may collect limited technical data—such as your IP address, browser type, or device information—when you access video content on our site. This data may be used for legitimate operational and security purposes, such as preventing piracy or ensuring compatibility across devices. Such services operate under their own privacy policies and are expected to comply with applicable data protection laws, including the GDPR where relevant.

We use the Personal Information you provide to:

  • Communicate with you regarding your account, inquiries, or transactions;
  • Respond to questions or requests;
  • Provide customer support;
  • Send service-related updates or promotional offers (only where permitted by law or with your consent).

We may also disclose Personal Information if required to:

  • Comply with legal obligations or enforceable government requests;
  • Enforce our Terms & Conditions or investigate potential violations;
  • Detect, prevent, or address fraud, technical, or security issues;
  • Protect the rights, safety, or property of our users, the public, or our business, as required or permitted by law.

Any such disclosures are made in accordance with relevant privacy laws and with appropriate safeguards in place.

Additional terms governing your use of the AI Agent are set out in our AI Agent Terms & Conditions, which work together with this Privacy Policy and our Program Terms & Conditions.

7. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION

You have the right at any time to prevent us from contacting you for marketing purposes. When we send promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail.

You can also indicate that you do not wish to receive marketing communications from us by going to the following webpage:

Visit our https://mc5advisory.com/manage-subscriptions/ to update your marketing preferences.

Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out of email communications from the Company, we may continue to send you administrative emails including, for example, periodic updates to our Policy.

8. LINKS TO OTHER WEBSITES

As part of the Program, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those external websites or the information or content they contain. This Policy applies solely to information collected by us through the Site, the Program, and any AI-powered tools we provide (including the AI Agent).

This Policy does not apply to your use of a third-party website accessed by selecting a link on our Site or through our Program. We encourage users to review the privacy statements of any external websites they visit.

For clarity, the third-party service providers we use to operate our Site, Program, or AI Agent (such as hosting providers, analytics services, or AI infrastructure providers) are not considered third-party “websites” for purposes of this section. Those service providers process Personal Information solely on our behalf and are bound by contractual privacy and security obligations, as described in Section 6 of this Policy.

9. EU GENERAL DATA PROTECTION REGULATION (“GDPR”) NOTICES

Data Controller

The Personal Information collected through the Site, the Program, and any AI-powered tools we provide (such as the AI Agent) is controlled by MC5 Advisory, LLC, located at 4300 E. Camelback Road, Suite 450, Phoenix, Arizona 85018. You may contact us at any time by emailing privacy@mc5advisory.com. The Company will only collect and process Personal Information about you where we have lawful bases to do so. The Company will only collect and process Personal Information about you where we have lawful bases to do so. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you), and “legitimate interests.” Where the Company relies on your consent to process Personal Information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact us at privacy@mc5advisory.com.

Data Processing Addendums for Subprocessors

The Company has in place Data Processing Addendums with those subprocessors that process end-users Personal Information to ensure compliance with the Company’s obligations under applicable data protection laws and regulations.

Users within the EU may email the Company at privacy@mc5advisory.com in order to exercise their GDPR rights to:

  • Access, review restrict processing of, or otherwise request erasure of your Personal Information;
  • Obtain the identity of the source of any Personal Information collected;
  • Request correction of any errors contained within Personal Information;
  • Request the transfer of your Personal Information to another service provider;
  • Object to the manner in which your Personal Information is processed; and
  • Lodge a complaint with a supervisory authority.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary for your enrollment in the Program. Where this is the case, we will inform you of specific details in response to your request.

Where we rely on your consent to collect Personal Information, you may withdraw your consent either through the opt out link provided in this Policy or through the contact information contained within this Section.

For all GDPR based requests made pursuant to this section, the Company will (a) respond as required under applicable law; (b) provide a copy of any requested Personal Information in a structured, commonly used and machine-readable format, and (c) transmit such Personal Information to another service provider without restriction in accordance with applicable law.

10. CALIFORNIA PRIVACY RIGHTS

For Information on your California Consumer Rights, please see California Consumer Privacy Rights Notice (“Notice”).

A verifiable California Consumer Request may be submitted by emailing the Company at privacy@mc5advisory.com or as otherwise designated in the Notice.

The Company will verify all requests with the California Consumer email address on file with the email address submitted in the applicable request form. California Consumers may designate an authorized agent to make a request on the Consumer’s behalf at privacy@mc5advisory.com or as otherwise designated in the Notice.

11. CHANGES TO POLICY

The Company reserves the right to change this Policy at any time. We will notify you of significant changes to our Policy by sending a notice to the primary email address specified in your account or by placing a prominent note on our Site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and the Policy for updates.

12. CONTACT US

Email the Company at privacy@mc5advisory.com if you have any questions regarding this Policy.

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