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BMODBRIDGE SOLUTIONS LLC

PRIVACY POLICY

Effective Date: October 6, 2026

This Privacy Policy describes how BModBridge Solutions LLC (“BModBridge,” “we,” “us,” or “our”) collects, uses, and shares Personal Information when you access or use our websites, applications, and services (the “Services”). “Personal Information” means information that identifies, relates to, describes, or could reasonably be linked with a particular individual, as defined under applicable data-privacy laws. De-identified and aggregated information is not Personal Information; we may de-identify or aggregate Personal Information, in which case it ceases to be Personal Information for purposes of this Policy.

How This Privacy Policy Works (Our Role)

BModBridge provides the Services primarily to professional customers (such as dog-training businesses) (“Trainers”) and to the individuals those Trainers invite (such as Pet Owners and veterinarians) to use the Services for which the Trainers have subscribed. For Personal Information that a Trainer submits or generates about its own clients through the Services, the Trainer is the controller (or “business”) responsible for that information, and BModBridge acts as its service provider (or “processor”), processing the information on the Trainer’s behalf, on its instructions, and in accordance with the Professional Services Agreement. The Trainer’s own privacy notice and practices govern its collection and use of your information. This Privacy Policy describes BModBridge’s own practices. If you are a client of a Trainer and wish to exercise privacy rights over information the Trainer controls, please contact that Trainer; we will assist as required by law. Information about your own account, including records of your acceptance of our agreements and policies and of your consent choices, is collected by BModBridge for its own purposes and is governed by this Privacy Policy.

1. WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy covers Personal Information we collect through our own Services. It does not cover the practices of third parties we do not control, the independent practices of the professionals who use the Services with their own clients, or third-party sites that may link to or from the Services. In some situations, we may rely on exemptions or other permitted conduct under applicable laws.

2. CONSENT AND OPT-OUT RIGHTS

Analytics. We use product-analytics tools only after you consent. If you decline, we do not associate your activity through those tools with your account. You may withdraw your consent at any time through the analytics setting in the Services.

Email and Text Communications. We may send you service-related communications necessary to use the Services (such as account, security, and transactional messages). We send marketing communications only where you have provided the consent required by law, and marketing emails include an unsubscribe mechanism. Where we send text messages, we obtain the consent required under the Telephone Consumer Protection Act (TCPA), and you may opt out of texts at any time by replying “STOP.” Consent to marketing is not a condition of using the Services.

3. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Account Information. Your email address, display name, and profile photo, and the identifiers associated with your Google, Apple, or magic-link sign-in.

Inquiry and Waitlist Information. If you contact us, request a demo, or join a waitlist or interest list (for example, through a form on our website or at an event), your name, email address, business name, and any other information you choose to provide.

Content You Submit. Information you enter through the Services, including pet names and behavior or journal entries. Some entries include free-text fields (for example, a field describing who was present during an incident) that may contain information about other people who are not users of the Services. You must not enter Personal Information about another person unless you have the authority, and any required consent, to do so.

Photos and Videos. Photographs and videos you upload. We attempt to remove location (GPS) metadata from these before upload, and our policy is that they are automatically deleted after 90 days.

Usage and Analytics Information. With your consent, information about how you use the Services collected through our analytics tools, which may associate your activity, and certain free-text content you enter, with your account and email address.

Device and Diagnostic Information. Log files, crash logs, and similar diagnostic data. Our error-monitoring tools are configured to attempt to remove user information and Personal Information before reports are sent.

Consent and Agreement Records. When you accept our agreements or policies, or give, change, or withdraw a consent (for example, to analytics or marketing communications), we keep a record of that event, which includes your email address, the agreement or consent at issue and its status, your IP address, your browser and device information (such as browser type and operating system), the date and time, and data used to verify the integrity of the record.

Communications. Records of your communications with us and, where applicable, messages sent through the Services.

Payment Information. If you make a payment, our third-party payment processor collects and processes your payment information; we do not store payment-card numbers or other financial-account data.

What We Do Not Collect. We do not knowingly collect device or advertising identifiers (other than the browser and device information included in Consent and Agreement Records), push-notification tokens, precise (GPS) location information, biometric data, or payment or financial-account data (beyond what the processor handles).

4. CATEGORIES OF SOURCES

We collect Personal Information from the following sources: directly from you (when you register, submit content, complete free-form text fields, submit a contact, demo-request, or waitlist form, accept our agreements or make consent choices, or communicate with us); automatically through your use of the Services (usage and diagnostic data, and through cookies and similar technologies); from the professional who invites you, where applicable; from third-party sign-in providers you choose to use (such as Google or Apple); and from our service providers (such as analytics, error-monitoring, messaging, and payment providers).

5. OUR BUSINESS PURPOSES FOR COLLECTING PERSONAL INFORMATION

We collect and use Personal Information for the following business and commercial purposes:

We do not “sell” Personal Information, and we do not “share” it for cross-context behavioral advertising, as those terms are defined under applicable law; and we do not use Personal Information for our own marketing except as permitted by Sections 2 and 11.

6. HOW WE SHARE YOUR PERSONAL INFORMATION

Service Providers (Subprocessors). We share Personal Information with vendors and subcontractors that process it on our behalf to provide the Services, including providers of hosting and content delivery, database and back-end services, authentication, product analytics, error monitoring, messaging, cloud storage, and payment processing. These providers are permitted to use Personal Information only to provide services to us and are required to implement reasonable security measures. A current list of our subprocessors is available here, which we may update from time to time.

Within the Trainer’s Account. Where you access the Services through a Trainer’s account, information is shared among the roles the Trainer has provisioned (for example, the Trainer’s employees and contractors, a Business Manager, or a Veterinarian the Pet Owner has authorized), as described in the Professional Services Agreement and the applicable documentation for the Services.

Legal and Safety. We may disclose Personal Information to comply with law or legal process, to protect our rights and the safety of others, or to enforce our agreements.

Business Transfers. We may disclose or transfer Personal Information in connection with a merger, acquisition, financing, reorganization, or sale of assets.

De-Identified and Aggregated Data. We may create and share de-identified and aggregated data that does not identify any individual.

We do not disclose Personal Information to third parties for their own direct-marketing purposes without your consent.

7. TRACKING TOOLS AND COOKIES

We and our providers use cookies, web beacons, local storage, and similar technologies (collectively, “Cookies”) to operate the Services, remember your preferences, maintain security, and—with your consent where required—measure usage and, if applicable, support marketing. Cookies are small text files stored in your browser that help recognize your device and remember information.

Categories of Cookies. We use: (a) Strictly Necessary Cookies, required for the Services to function and for security; (b) Functional Cookies, which remember your preferences and settings; (c) Analytics/Performance Cookies, which help us understand usage (used with your consent where required); and (d) if applicable, Targeting/Advertising Cookies, which support marketing.

Your Choices. Where required by law, we present a consent banner or cookie-preference tool that lets you accept or reject non-essential Cookies, and we honor recognized opt-out preference signals (such as Global Privacy Control) where required. You may also control Cookies through your browser settings, and you may opt out of certain analytics through tools such as the Google Analytics Opt-out Browser Add-on. Disabling Strictly Necessary Cookies may prevent the Services from functioning.

8. DATA SECURITY

We maintain administrative, technical, and physical safeguards intended to protect Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, or destruction, appropriate to the sensitivity of the data. We restrict access to Personal Information to personnel and service providers who need it to operate, develop, or support the Services, and we require our service providers to implement reasonable security measures. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us of any unauthorized use of your account. If we become aware of a security incident affecting your Personal Information, we will notify you and any affected professional as, and to the extent, required by applicable law and consistent with the Professional Services Agreement.

9. DATA RETENTION

We retain Personal Information only as long as necessary for the purposes for which we collected it, including to operate the Services, to comply with our legal obligations, and to preserve evidence within applicable limitations periods. Retention and deletion after termination are governed by the Professional Services Agreement. That agreement provides a 90-day window to export data, after which the data may be permanently deleted. Our policy is to automatically delete photographs and videos after 90 days, so you should keep your own copies of any records you wish to retain.

Account Deletion and Retained Records. You may request deletion of your account within the Application or by contacting us at contact@bmodbridge.com. When we delete an account or act on a deletion request under Section 11, we will delete or de-identify the associated Personal Information. We may, however, retain records of your acceptance of our agreements and policies and of your consent and opt-out choices (see Section 3), related transaction and account records, and any information we must retain by law. We keep these only as long as reasonably necessary to comply with law and to establish, exercise, or defend legal claims, and we restrict access to them to those purposes.

10. PERSONAL INFORMATION OF CHILDREN

The Services are intended solely for users who are at least 18 years old, and we do not knowingly collect Personal Information from anyone under 18. Consistent with the Children’s Online Privacy Protection Act (COPPA), the Services are not intended for and are not directed to children under 13, and we do not knowingly collect Personal Information from anyone under 13. Trainers must not invite, or provide access to, any individual under 18, and must not enter Personal Information about a child, without appropriate authority and consent. If you are between 13 and 16 and reside in a jurisdiction (such as California) that provides special rights for minors, you should use the Services only with the involvement of a parent or guardian, and we do not sell or share the Personal Information of consumers we know to be under 16 without the affirmative authorization required by law. If we learn that we have collected Personal Information from a person under 18 without required authorization, we will take reasonable steps to delete it. If you believe a child’s Personal Information has been provided to us, please contact us as set forth in Section 14.

11. STATE LAW PRIVACY RIGHTS

Depending on your state of residence, and subject to certain exceptions, you may have privacy rights under laws such as the California Consumer Privacy Act, as amended (CCPA/CPRA), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and other state privacy laws. The scope of these rights and the definitions of terms such as “sale,” “share,” “targeted advertising,” and “sensitive data” vary by state. Depending on the law applicable to you, you may have the right to:

How to Submit a Request. You may submit a request exercising your applicable state law privacy rights by emailing us at privacy@bmodbridge.com. We will verify your request using information associated with your account and, where necessary, other information reasonably needed to confirm your identity (which may include a government-issued ID). We will respond within the time required by applicable law (generally within 45 days, which may be extended where permitted).

Authorized Agents. You may use an authorized agent acting under a valid legal authorization (such as a power of attorney) to submit a request. We may require verification of the agent’s authority and your identity. We do not accept requests from referral agents or third parties acting without your direct, legally valid authorization.

Appeals. Where applicable law provides a right to appeal our decision on a request, we will explain how to appeal in our response to you.

Sale/Share and Targeted Advertising. We do not sell Personal Information for money. To the extent our use of analytics or advertising technologies constitutes a “sale” or “share,” or is used for targeted advertising, to the extent required by applicable law, you may opt out using our “Do Not Sell or Share My Personal Information” link and by enabling a recognized opt-out preference signal such as Global Privacy Control.

Clients of Trainers. If you are a client of a professional (for example, a dog owner) and your request concerns Personal Information the professional controls, we will refer your request to, or assist, that professional as required by law, because the professional—not BModBridge—is the controller of that information.

12. VISITORS FROM OUTSIDE THE UNITED STATES

The Services are intended for users in the United States and its territories, and Personal Information is processed in the United States. We do not target the Services to individuals in the European Union, the United Kingdom, or other jurisdictions with their own comprehensive data-protection laws. To the extent we process Personal Information of such individuals on behalf of a Trainer, we act as a processor and process it in accordance with the Trainer’s instructions and the Professional Services Agreement.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will post the updated version with a new Effective Date and, for material changes, provide additional notice where required by law.

14. CONTACT INFORMATION

Questions or requests regarding this Privacy Policy may be directed to BModBridge Solutions LLC at privacy@bmodbridge.com, with a copy to 202 K Street, South Boston, MA 02127.