Privacy Policy

Effective Date: March 5, 2025

Introduction

We at Brophy Family Holdings LLC & Midwest Business
Marketing and Your-Birthday.com("we," "us,"
"our") respect your privacy. This Privacy Policy is designed to
explain how we collect, use, and protect the personal information you provide
to us when you access our website, purchase our goods or services, engage with
our AI-powered features, or interact with us on social media, as well as your
own rights to the information we collect.

Please read this Privacy Policy carefully. We will alert you
to any changes to this Policy by changing the "last updated" date at
the top of this Policy. Any changes become effective immediately upon
publication on our website, and you waive specific notice of any changes to the
Policy by continuing to use and access our site(s). We encourage you to review
this Privacy Policy periodically, when you use our website for any purpose,
engage with our AI technologies, or interact with us on social media. You are
deemed to have accepted any changes to any revised Privacy Policy by your
continued use of our website after the revised Privacy Policy is posted.

INFORMATION THAT WE COLLECT

We collect a variety of information from you when you visit
our website, make purchases, interact with our AI-powered features, or engage
with us on social media. By accepting this Privacy Policy, you are specifically
consenting to our collection of the data described below, to our use of the
data, to the processing of this data, and to our sharing of the data with
third-party processors as needed for our legitimate business interests. The
information we collect may include:

PERSONAL DATA

Personal Data is information that can be used to identify
you specifically, including your name, shipping address, email address,
telephone number, or demographic information like your age, gender, or
hometown. You consent to giving us this information by providing it to us
voluntarily on our website or any mobile application. You provide some of this
information when you register with or make purchases from our website. You may
also provide this information by participating in various activities associated
with our site, including responding to blogs, contacting us with questions, or
participating in group training. Your decision to disclose this data is
entirely voluntary. You are under no obligation to provide this information,
but your refusal may prevent you from accessing certain benefits from our
website or from making purchases.

DERIVATIVE DATA

Derivative data is information that our servers
automatically collect about you when you access our website, such as your IP
address, browser type, the dates and times that you access our website, and the
specific pages you view. If you are using a mobile application, our servers may
collect information about your device name and type, your phone number, your
country of origin, and other interactions with our application. Derivative data
may also include data collected by third-party service providers, such as
advertising and analytics providers, and may include cookies, log data, or web
beacons. Cookies are discussed more fully below. Derivative data collected by
third-party service providers generally does not identify a specific
individual.

VOICE AND CONVERSATION DATA

When you interact with our AI voice agents or text-based AI
assistants, we may collect and process voice recordings, transcripts, and
contextual information from these interactions. This data is used to provide
the requested services, improve our AI systems, and enhance your user
experience. We collect this information with your explicit consent, which you
provide when you engage with these features. You can withdraw this consent at
any time by contacting us, though this may limit your ability to use certain
AI-powered features.

FINANCIAL DATA

Financial data is data that is related to your payment
method, such as credit card or bank transfer details. We collect financial data
in order to allow you to purchase, order, return, or exchange products or
services from our website and any related mobile apps. We store limited
financial data. Most financial data is transferred to our payment processors,
STRIPE, PAYPAL, and INTUIT, and you should review these processors' Privacy
Policy to determine how they use, disclose, and protect your financial data. As
a courtesy, these payment processors' Privacy Policies can be found here:

STRIPE: https://stripe.com/privacy

INTUIT: https://www.intuit.com/privacy/

PAYPAL:
https://www.paypal.com/us/webapps/mpp/ua/privacy-full

SOCIAL NETWORKING DATA

We may access personal information from social networking
sites and apps, including Facebook, Instagram, LinkedIn, Twitter, Snapchat, or
other social networking sites or apps not named specifically here, which may
include your name, your social network username, location, email address, age,
gender, profile picture, and any other public information. If you do not want
us to access this information, please go to the specific social networking site
and change your privacy settings.

MOBILE DEVICE DATA

If you use our website via a mobile device or app, we may
collect information about your mobile device, including device ID, model and
manufacturer, and location information.

OTHER DATA

On occasion, you may give us additional data in order to
enter into a contest or giveaway or to participate in a survey. You will be
prompted for this information and it will be clear that you are offering this
kind of information in exchange for an entry into such a contest or giveaway.

MOBILE APPLICATION INFORMATION

If you connect to us using a mobile application, we may
request geolocation information, which includes permission to track your mobile
device, in order to provide you with location-based services. We may also
request access to certain features on your device, including your device's
calendar, camera, contacts, social media accounts, Bluetooth, and storage. We
may also send you "push notifications" regarding your account or our
mobile application. If you wish to change our access to any of this
information, you may do so by changing your device settings.

AI TECHNOLOGIES AND DATA PROCESSING

AI-POWERED FEATURES AND SERVICES

We incorporate artificial intelligence (AI) technologies in
various aspects of our services, including but not limited to:

AI text agents for customer support and communication

AI voice agents for automated assistance

AI-powered Quality Assurance systems

AI features integrated into our products and services

HOW WE USE AI WITH YOUR DATA

Our AI systems may process your personal data for various
purposes, including:

Analyzing customer interactions to improve service quality

Automating responses to common inquiries

Providing personalized recommendations

Quality assurance monitoring

Enhanced security and fraud detection

Content moderation and filtering

AI DATA PROTECTION COMMITMENTS

We are committed to using AI technologies responsibly and
ethically. When processing your data with AI systems, we:

Do not use AI to make automated decisions with significant
legal or similar effects without human oversight

Implement technical safeguards to prevent unauthorized
access to data processed by our AI systems

Train our AI systems on properly authorized data in
compliance with applicable laws

Maintain transparent AI processes with appropriate human
supervision

Regularly test and audit our AI systems for bias, security
vulnerabilities, and compliance with this privacy policy

Apply the principle of data minimization to ensure our AI
systems only process the data necessary for their intended functions

Provide you with the right to opt out of AI-based processing
where feasible

VOICE RECORDING AND PROCESSING

When you interact with our AI voice agents:

Voice recordings are processed to provide the requested
service and may be retained for quality assurance, training purposes, and
service improvement

You will be notified when voice recording begins and have
the option to opt-out

Voice data may be transcribed into text for further
processing

We implement enhanced security measures for voice data

You can request deletion of your voice recordings by
contacting [email protected]

HOW WE USE YOUR INFORMATION

Your information allows us to offer you certain products and
services, including the use of our website and AI-powered features, to fulfill
our obligations to you, to customize your interaction with our company and our
website, and to allow us to suggest other products and services we think might
interest you. We generally store your data and transmit it to a third party for
processing. However, to the extent we process your data, we do so to serve our
legitimate business interests (such as providing you with the opportunity to
purchase our goods or services and interact with our website, AI systems, or
mobile app).

Specifically, we may use the information and data described
above to:

Create and administer your account;

Deliver any products or services purchased by you to you;

Correspond with you;

Process payments or refunds;

Contact you about new offerings that we think you will be
interested in;

Interact with you via social media;

Send you a newsletter or other updates about our company or
website;

Deliver targeted advertising;

Request feedback from you;

Notify you of updates to our product and service offerings;

Resolve disputes and troubleshoot any problems;

Administer contests or giveaways;

Generate a profile that is personalized to you, so that
future interactions with our website will be more personal;

Compile anonymous statistical data for our own use or for a
third party's use;

Assist law enforcement as necessary;

Prevent fraudulent activity on our website or mobile app;

Analyze trends to improve our website and offerings;

Train and improve our AI systems;

Provide AI-powered customer support and product features;

Conduct quality assurance reviews of interactions.

WHEN DO WE COLLECT INFORMATION?

We collect information from you when you subscribe to a
newsletter, fill out a form, enter information on our site, make a purchase,
interact with our AI-powered features or agents, or engage with our customer
support systems.

HOW DO WE PROTECT VISITOR INFORMATION?

Your personal information is contained behind secured
networks and is only accessible by a limited number of persons who have special
access rights to such systems and are required to keep the information
confidential. In addition, all sensitive/credit information you supply is
encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user
enters, submits, or accesses their information to maintain the safety of your
personal information. All transactions are processed through a gateway provider
and are not stored or processed on our servers.

For AI-processed data, we implement additional security
measures, including:

Encrypted storage of voice recordings and transcripts

Access controls limiting which staff can access AI-processed
data

Regular security audits of our AI systems

Data anonymization techniques where appropriate

Regular deletion of AI training and processing data when no
longer needed

DATA SHARING COMMITMENT

WE DO NOT SELL YOUR DATA

We do not sell, trade, or otherwise transfer to outside
parties your personally identifiable information for marketing or promotional
purposes. Your information will never be sold, exchanged, transferred, or given
to any other company for any reason whatsoever, without your consent, other
than for the express purpose of delivering the purchased product or service
requested.

LIMITED SHARING WITH SERVICE PROVIDERS

We may share your information with trusted third parties who
assist us in operating our website, conducting our business, processing
payments, or servicing you, so long as those parties agree to keep this
information confidential. These service providers include:

Payment processors (Stripe, PayPal, and Intuit) – solely for
the purpose of processing your payments

Email service providers – solely for sending communications
you have opted into

Website hosting services – solely for the purpose of hosting
our website and its content

SMS message aggregators and providers – solely for
delivering text messages you have opted into receiving

HighLevel CRM – for client relationship management (see
special provisions below)

AI technology providers – to power our AI-enabled features
and services

Cloud storage providers – for secure storage of data
processed by our systems

AI SERVICE PROVIDER LIMITATIONS

When we engage third-party AI service providers, we impose
the following limitations:

AI service providers may only process your data for the
specific purposes outlined in our agreements

They must implement appropriate technical and organizational
security measures

They cannot use your data to train their AI models for
purposes outside of providing services to us without your explicit consent

They must comply with all applicable data protection laws
and regulations

They must promptly notify us of any security incidents or
unauthorized data access

They must delete or return all personal data upon
termination of services

Important Note About SMS Data: All text messaging originator
opt-in data and consent information will not be shared with any third parties,
excluding aggregators and providers of the Text Message services necessary to
deliver the SMS service. Your mobile information will not be shared with third
parties or affiliates for marketing or promotional purposes.

WHITE-LABELED CRM SERVICES

We provide white-labeled HighLevel CRM services to our
clients. Please be aware of the following regarding these services:

Third-Party Platform: HighLevel CRM is a third-party
platform that we provide access to under our brand. The actual software,
servers, and infrastructure are owned and operated by GoHighLevel.

Limitation of Liability: We are not responsible for any
issues, outages, data breaches, or other problems that may occur with the
HighLevel platform. This includes but is not limited to:

Service interruptions or downtime

Data loss or corruption

Security breaches or unauthorized access to data

Changes to the HighLevel platform's features or
functionality

Any other technical issues related to the HighLevel platform

Support for Platform Issues: For any issues related to the
core functionality of the HighLevel platform, clients may need to contact
GoHighLevel directly at gohighlevel.com.

Data Processing: When you use our white-labeled HighLevel
CRM services, your data may be processed according to GoHighLevel's own privacy
policy and terms of service, in addition to our policies.

Service Continuity: We cannot guarantee the continued
availability of the HighLevel platform or its features, as these decisions are
made by GoHighLevel and are beyond our control.

OTHER LIMITED DISCLOSURES

We may also disclose your information:

As required by law, such as to comply with a subpoena or
similar legal process

When we believe in good faith that disclosure is necessary
to protect our rights, protect your safety or the safety of others, investigate
fraud, or respond to a government request

To enforce our Terms of Service

In the event of a merger, acquisition, bankruptcy, or sale
of assets, in which case the privacy policy of the new entity will govern

COOKIES

We may use cookies for tracking purposes. Cookies are small
files that a site or its service provider transfers to your computer's hard
drive through your Web browser (if you allow) that enables the site's or
service provider's systems to recognize your browser and capture and remember
certain information.

You can choose to have your computer warn you each time a
cookie is being sent, or you can choose to turn off all cookies. You do this
through your browser (like Internet Explorer, Chrome, Firefox, or Safari)
settings. Each browser is a little different, so look at your browser's Help
menu to learn the correct way to modify your cookies.

If you disable cookies, some features may be disabled and
some of our services may not function properly.

THIRD PARTY INTEGRATIONS

GOOGLE

Google's advertising requirements can be summed up by
Google's Advertising Principles. They are put in place to provide a positive
experience for users.
https://support.google.com/adwordspolicy/answer/1316548?hl=en

We have implemented the following:

Remarketing with Google AdWords

Google Display Network Impression Reporting

Demographics and Interests Reporting

We, along with third-party vendors such as Google, use
first-party cookies (such as the Google Analytics cookies) and third-party
cookies (such as the DoubleClick cookie) or other third-party identifiers
together to compile data regarding user interactions with ad impressions and
other ad service functions as they relate to our website.

Opting out of Google Analytics: You can opt out of having
your activity on our website made available to Google Analytics by installing
the Google Analytics opt-out browser add-on. This add-on prevents Google
Analytics from retrieving information about your visits to our website. For
more information about Google's Privacy Policy, please visit:
https://policies.google.com/privacy.

FACEBOOK

Facebook's advertising requirements can be summed up by
Facebook's Advertising Principles. They are put in place to provide a positive
experience for users. https://www.facebook.com/policies/ads/

We have implemented the following:

Advertising with Facebook Advertising

Retargeting with Facebook Advertising

Demographics and Interests Reporting

We, along with third-party vendors such as Facebook, use
first-party cookies (such as the Facebook Pixel) or other third-party
identifiers together to compile data regarding user interactions with ad
impressions and other ad service functions as they relate to our website.

Opting out of Facebook's interest-based ads: You can opt out
of Facebook's interest-based ads by visiting:
https://www.facebook.com/help/568137493302217.

You can learn more about Facebook's Privacy Policy at:
https://www.facebook.com/full_data_use_policy.

Facebook Custom Audiences Opt-Out: You can opt out of any
present and future campaigns by visiting:
https://brophyfam.com/optout

GROUNDS FOR USING AND PROCESSING YOUR DATA

The information we collect and store is used primarily to
allow us to offer goods and services for sale. In addition, we may collect,
use, and process your information based on the following grounds:

LEGITIMATE BUSINESS INTERESTS

We may use and process your data for our legitimate business
interests, which include, among other things, communicating with you, improving
our goods or services, improving our website, and providing you with the
information or products that you have requested.

PERFORMANCE OF A CONTRACT

We may use and process your information to enter into a
contract with you and to perform our contractual obligations to you.

CONSENT

We may use your data, or permit selected third parties to
use your data, based on your consent to our use and sharing of that data. You
may withdraw your consent at any time, but doing so may affect your ability to
use our website or other offerings.

AS REQUIRED BY LAW

We may also use or process your data as required for us to
comply with legal obligations.

INTERNATIONAL DATA

Our website is hosted by servers located in the United
States of America. Therefore, if you reside outside the United States of
America, some of your data will be transferred internationally to and stored on
those servers. In addition, we may use third-party processors (including
payment processors) and subcontractors located in the United States of America.
We use all reasonable methods to protect the safety of your data during
transfer, including hosting our website on reputable servers and engaging reputable
third-party processors. By using this site and providing us with information,
you consent to this transfer, processing, and storage of your information in
the United States of America. Note that the privacy laws in the United States
of America may not be as strict as those in other countries. Please be aware
that:

We may transfer data that we collect to locations outside of
our headquarters for processing or storing, and the data may be processed by
our staff or by third-party processors. For example, we may engage third
parties to fulfill orders. By submitting your personal data, you agree to this
transfer, storing, and processing. We take all reasonable steps to make sure
your data is treated securely and in conformity with this Privacy Policy.

Data that is provided to us is stored on secure servers.
Payment information and other sensitive data will be encrypted to ensure its
safety.

The transmission of data via the internet is never
completely secure, and we cannot guarantee the security of data that is sent to
us electronically. Your transmission of data to us is at your own risk.

Where data that you have transmitted to us is password
protected, you are responsible for keeping the password confidential. You are
exclusively responsible for any breaches of your data that results from your
own disclosure of or failure to protect your password.

DATA RETENTION

We retain personal data as long as it is needed to conduct
our legitimate business purposes or to comply with our legal obligations, or
until you ask us to delete your data. For example, we will retain certain
personal information indefinitely for the purposes of maintaining your account,
unless and until you delete your account. Data that we gather for a specific
and particular purpose, such as assisting law enforcement or analyzing trends,
will be kept for no longer than is necessary for that particular purpose. Data
that is no longer needed by us for any of the purposes listed above will be
permanently deleted.

For AI-processed data, including voice recordings and
interaction data:

Voice recordings are typically retained for no more than 90
days unless a longer retention period is necessary for legal compliance,
dispute resolution, or ongoing service improvement

Conversation transcripts may be retained for up to 12 months
to improve our AI systems and service quality

Anonymized or aggregated data derived from AI interactions
may be retained indefinitely for analytical purposes

We will honor your request to delete your data, as described
more fully below, unless we are required by law to retain access to the data.
However, note that we cannot control the retention policies of third parties.
If you wish to have any third parties, including those to whom we've
transmitted your data, delete that data, you will need to contact those third
parties directly. You may request from us a list of all third parties to whom
we have transmitted your data.

We may retain usage data (that is, data that is gathered by
our company or third-party analytics companies for the purpose of analyzing the
use of our website) as needed for internal analysis purposes. This type of data
is usually retained for a shorter period of time than personal data, unless the
data is necessary to improve the security or functionality of our website or
offerings, or we are legally obligated to retain the data for a longer period
of time.

SECURITY OF YOUR INFORMATION

We take all reasonable steps to protect your personal data
and keep your information secure. We use recognized online secure payment
systems and implement generally accepted standards of security to protect
against personal data loss or misuse. However, no security measure is
foolproof, and no method of data transmission can be guaranteed against
interception or misuse. We cannot guarantee complete security of any
information you transmit to us.

By consenting to this Privacy Policy, you acknowledge that
your personal data may be available, via the internet, around the world. We
cannot prevent the use or misuse of your data by other parties.

We will notify you promptly of any known breach of our
security systems or your data which might expose you to serious risk.

SENSITIVE DATA

We request that you do not submit any sensitive data to us,
via public postings, email correspondence with us, or any other method,
including social security number, health data, genetic data, or information
related to your ethnic origin, religious beliefs, or criminal history. If you
do send us this information, then by doing so you are consenting to our use,
storage, and processing of this information in accordance with this privacy
policy.

SPECIAL NOTE ABOUT AI VOICE AND TEXT INTERACTIONS

Our AI systems are designed to detect and prevent the
collection of sensitive data. However, if you inadvertently share sensitive
information during an interaction with our AI technologies:

We will make reasonable efforts to delete such information
upon detection

We have implemented automatic filtering systems to identify
and remove sensitive data from AI training datasets

Human reviewers who may access conversation data for quality
assurance purposes are bound by strict confidentiality obligations

You may request immediate deletion of any interaction
containing sensitive information by contacting [email protected]

SMS/TEXT MESSAGE PRIVACY

If you have opted in to receive SMS/text messages from us,
we are committed to protecting your privacy regarding these communications:

No Data Sharing: All text messaging originator opt-in data
and consent information will not be shared with any third parties, excluding
the aggregators and providers necessary to deliver the SMS service.

Marketing Restrictions: Your mobile information will not be
shared with any third parties or affiliates for marketing or promotional
purposes.

Limited Use: Your SMS opt-in data will only be used for the
specific purposes you have consented to, such as appointment reminders, event
notifications, receipts, customer service updates, and promotional messages
you've explicitly opted into.

Opt-Out Control: You can stop receiving text messages at any
time by texting "STOP" to our shortcode. Upon doing so, we will
confirm your opt-out status via SMS and will cease sending you text messages.

YOUR RIGHTS

You have certain rights with respect to your personal data,
as outlined below. Note that we may charge you a reasonable fee for actions
that you ask us to take with respect to your data. In addition, we reserve the
right to request that you provide us with evidence of your identity before we
take any action with respect to the exercise of your data rights. Further, your
rights may be restricted or nullified to the extent they conflict with our
compelling business interests, the public interest, or the law.

UPDATE ACCOUNT INFORMATION

You have the right to update or change any information you
have provided to us. To update or delete your information, please contact us at
[email protected].

CONFIRM PERSONAL DATA AND ITS USE

You have the right to request that we confirm what data we
hold about you, and for what purposes. You also have the right to confirmation
of whether we process your data or deliver your data to third-party processors,
and for what purposes. We will supply you with copies of your personal data
unless doing so would affect the rights and freedoms of others.

CHANGE CONSENT

You have the right to change your consent to our use of your
information. In such cases, we may require you to delete your account with us,
as described above, and you may not have full access to our website.

REQUEST A COPY OF DATA

You have the right to request a digital copy of the data
that we hold about you. Your first request for a copy of your personal data
will be provided free of charge; subsequent requests will incur a reasonable
fee.

TRANSFER YOUR DATA

You have the right to request that we gather and transfer
your data to another controller, in a commonly used and machine-readable
format, unless doing so would cause us an undue burden.

DELETE ALL DATA

You have the right to request that we delete all data that
we hold about you, and we must delete such data without undue delay. There are
exceptions to this right, such as when keeping your data is required by law, is
necessary to exercise the right of freedom of expression and information, is
required for compliance with a legal obligation, or is necessary for the
exercise or defense of legal claims. Such a request may result in a termination
of your account with us and you may have limited or no use of our website.

AI-SPECIFIC RIGHTS

In addition to the above rights, you have the following
rights specifically related to our AI technologies:

Right to opt out of AI voice recording: You may opt out of
having your voice recorded and processed by our AI voice agents at any time

Right to access AI decisions: You may request information
about any significant decisions made about you by our AI systems

Right to human review: You may request human review of any
decision made solely by automated means that produces legal or similarly
significant effects

Right to AI data deletion: You may request the deletion of
any voice recordings, transcripts, or other data collected through your
interactions with our AI systems

EMAILS AND COMMUNICATIONS

You may opt out of receiving future email correspondence
from us by checking the appropriate box when you register for the account or
make a purchase. You may change your communication settings by contacting us at
[email protected].

MARKETING COMMUNICATIONS

You may opt out of receiving any third-party marketing
communications or having your personal information used for marketing purposes.
You may do this by contacting us at [email protected].

PROCESSING

You may, in some circumstances, restrict the processing of
your data, such as when you contest the accuracy of your data or when you have
objected to processing, pending the verification of that objection. When
processing has been restricted, we will continue to store your data but will
not pass it on to third-party processors without your consent, or as necessary
to comply with legal obligations or protect your rights or those of others or
our company. In addition, you may opt out of any processing of your data
altogether. Note, however, that doing so may result in the termination of your
account and loss of access to our website.

COMPLAINTS

If you believe we are misusing your data or have violated
any of your rights under this Privacy Policy or applicable law, you have the
right to file a complaint with us directly or with a regulatory body or data
protection authority.

CALIFORNIA PRIVACY RIGHTS

The State of California has established its own unique
regulations that apply to California residents. As of its effective date of
January 1, 2020, we are also compliant with the California Consumer Privacy Act
Of 2018, Cal. Civ. Code §§ 1798.100 Et Seq. (CCPA).

Any California resident may request, free of charge, the
personal information we have collected or stored about themselves or about a
member of their household. For security purposes, we reserve the right to ask
for verification of your identity and proof of your California residency at the
time of your request.

Any California resident has a right to request the personal
data we have collected, or request deletion of the personal data we have
collected, including but not limited to:

Any personally identifying information, such as a real name,
alias(es), mailing or resident address, IP address, email address, account
name, biometrics, or any other data that could uniquely identify a California
resident; and

Commercial information, including products or services
purchased, obtained, or considered, search history, interactions with our
website, or any other purchasing or browsing history of our site and/or
offer(s); and

Site comments made publicly or privately; and

Geolocation data; and

Professional or employment-related information; and

Education information; and

Voice recordings and transcripts from interactions with our
AI systems.

We reserve the right to collect any of the above data on
California residents and their households.

We DO NOT sell your data. California residents can email us
at [email protected] to explicitly request to opt-out of any future data
sales, should our policies change.

California residents also have the option to request a full
deletion of their account and any data we have collected and associated with
them.

We agree to comply with any data request or deletion made
pursuant to the CCPA in a reasonable timeframe, during normal business hours
and excluding holidays or our pre-scheduled time off.

COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)

When it comes to the collection of personal information from
children under 13, the Children's Online Privacy Protection Act (COPPA) puts
parents in control. The Federal Trade Commission, the nation's consumer
protection agency, enforces the COPPA Rule, which spells out what operators of
websites and online services must do to protect children's privacy and safety
online.

We do not specifically market to children under 13 and do
not knowingly collect personal information from children under 13.

FAIR INFORMATION PRACTICES

The Fair Information Practices Principles form the backbone
of privacy law in the United States and the concepts they include have played a
significant role in the development of data protection laws around the globe.
Understanding the Fair Information Practice Principles and how they should be
implemented is critical to comply with the various privacy laws that protect
personal information.

In order to be in line with Fair Information Practices, we
will take the following responsive action, should a data breach occur:

We will notify the users via email within 7 business days.

We also agree to the individual redress principle, which
requires that individuals have a right to pursue legally enforceable rights
against data collectors and processors who fail to adhere to the law. This
principle requires not only that individuals have enforceable rights against
data users, but also that individuals have recourse to courts or a government
agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM ACT

The CAN-SPAM Act is a law that sets the rules for commercial
email, establishes requirements for commercial messages, gives recipients the
right to have emails stopped from being sent to them, and spells out tough
penalties for violations.

We collect your email address in order to:

Send information, respond to inquiries, and/or other
requests or questions.

To be in accordance with CANSPAM, we agree to the following:

NOT use false, or misleading subjects or email addresses

Identify the message as an advertisement in some reasonable
way

Include the physical address of our business or site
headquarters

Monitor third-party email marketing services for compliance,
if one is used

Honor opt-out/unsubscribe requests quickly

Allow users to unsubscribe by using the link at the bottom
of each email

If at any time you would like to unsubscribe from receiving
future emails, you can email us at [email protected] or follow the
instructions at the bottom of each email to unsubscribe, and we will promptly
remove you from ALL correspondence.

HIPAA PRIVACY POLICY

GENERAL HIPAA STATEMENT

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY
BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE
REVIEW IT CAREFULLY.

Brophy Family Holdings LLC & Midwest Business Marketing
provides electronic messaging and related technology services to and on behalf
of health care providers for potential health care customers. By submitting
individually identifiable health information to Brophy Family Holdings LLC
& Midwest Business Marketing, including your name, contact information, and
potential health concerns, it is expected that Brophy Family Holdings LLC &
Midwest Business Marketing will possess such individually identifiable health
information that may be protected under the Health Insurance Portability and
Accountability Act of 1996 (HIPAA). Furthermore, by submitting this potentially
protected health information (PHI) to Brophy Family Holdings LLC & Midwest
Business Marketing

In compliance with HIPAA, the HIPAA Privacy Regulations, and
the Health Information Technology for Economic and Clinical Health Act of 2009
(HITECH), Brophy Family Holdings LLC & Midwest Business Marketing:

Does not use or further disclose PHI other than as expressly
permitted;

Does not sell, trade, or otherwise transfer to outside
parties your PHI;

Keeps your PHI stored in secured networks and is only
accessible by Brophy Family Holdings LLC & Midwest Business Marketing
agents, who have special access to such systems; furthermore, all sensitive
and/or credit information you submit is encrypted via Secure Socket Layer (SSL)
technology;

Agrees to ensure that any agents, including subcontractors,
to whom it provides PHI received from, or created or received by Brophy Family
Holdings LLC & Midwest Business Marketing on behalf of the medical
provider, also will agree to the same restrictions and conditions of
confidentiality; and,

Shall make reasonable efforts to limit the use and/or
disclosure of PHI to the minimum amount of information necessary as required by
the medical provider to accomplish the intended purpose of the use or
disclosure.

Implements strict controls on any AI systems that may
process PHI, including enhanced encryption, access controls, and audit logs.

If you have any questions or request further information
about Brophy Family Holdings LLC & Midwest Business Marketing's privacy
policies, please contact us via email at [email protected].

AI ETHICS AND COMMITMENTS

As we continue to develop and deploy AI technologies, we are
committed to the following ethical principles:

Transparency: We will be transparent about when and how AI
is being used in our services

Human oversight: We maintain appropriate human supervision
and review of AI systems

Data privacy: We use personal data for AI training and
operation only with appropriate consent and safeguards

Non-discrimination: We regularly test our AI systems for
bias and work to ensure fair treatment

Security: We implement robust security measures to protect
data processed by AI systems

Accountability: We take responsibility for the proper
functioning of our AI systems

We continuously evaluate our AI technologies against these
principles and make adjustments as necessary to ensure responsible use. Our AI
development roadmap includes regular ethical reviews and impact assessments.