POLARIS BRAND PROMOTIONS, LLC PRIVACY POLICY FOR USERS BASED IN THE UNITED STATES, INCLUDING CALIFORNIA

Last Modified: 29 October 2025

This Privacy Policy describes how POLARIS BRAND PROMOTIONS, LLC and its subsidiaries, affiliates, and related entities (collectively, “POLARIS BRAND PROMOTIONS, LLC,” “Company,” “we,” or “us”) collect and process personal information about our consumers. The California Consumer Privacy Act (“CCPA”) requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, and sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy. This policy applies to www.samplefinder.com and any related apps applicable thereto.

This Privacy Policy does not apply to our collection and use of personal information in an employment capacity.

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information“). Personal information does not include:

Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
Lawfully obtained, truthful information that is a matter of public concern.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act.

Personal Information Categories Chart

The chart below identifies which categories of personal information we collected from our consumers within the last 12 months and the expected retention period.

Category	Examples	Collected	Retention Period
A. Identifiers.	A real name, alias, birth date, postal address, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.	YES	Until user requests deletion.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records").	A name and current location.	YES	Until user requests deletion.
C. Protected classification characteristics under California or federal law ("Protected Classes").	Age (40 years or older), sex (including gender.	YES	Until user requests deletion.
D. Commercial information.	Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	Until user requests deletion.
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	Not applicable
F. Internet or other similar network activity.	Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.	NO	Not applicable
G. Geolocation data.	Physical location or movements, such as the time and physical location related to use of our internet website, application, or device, and GPS location data from mobile devices of consumers who visit our websites or use our mobile apps.	YES	Until user requests deletion.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring and store video surveillance.	NO	Not applicable
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO	Not applicable
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information").	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO	Not applicable
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES	Until user requests deletion.
L. Sensitive personal information.	Further identified in the chart below.	YES	Until user requests deletion.

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

Sensitive Personal Information Category	Collected to Infer Characteristics?	Retention Period
L.1. Government identifiers, such as your Social Security number (SSN), driver's license, state identification card, or passport number.	NO	Not applicable
L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.	NO	Not applicable
L.3. Precise geolocation, such as physical store visits or physical locations when visiting websites or using mobile apps.	YES	Until user requests deletion.
L.4. Racial or ethnic origin.	NO	Not applicable
L.5. Citizenship or immigration status.	NO	Not applicable
L.6. Religious or philosophical beliefs.	NO	Not applicable
L.7. Union membership.	NO	Not applicable
L.8. Mail, email, or text messages not directed to the Company.	NO	Not applicable
L.9. Genetic data.	NO	Not applicable
L.10. Neural Data, such as information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information.	NO	Not applicable
L.11. Unique identifying biometric information.	NO	Not applicable
L.12. Health information.	NO	Not applicable
L.13. Sex life or sexual orientation information.	NO	Not applicable

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you, such as from the forms or other information you provide to the Company.
From our service providers, such as payment processors.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes
We may use and disclose the personal information, including sensitive personal information, we collect to advance the Company’s business and commercial purposes, specifically to:

Develop, offer, and provide you with our products and services.
Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
Improve our products or services, marketing, or customer relationships and experiences.
Notify you about changes to our products or services.
Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
Enable your participation in our websites’ or mobile apps’ interactive, social media, or other similar features.
Protect our Company, employees, or operations.
Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
Make suggestions and recommendations to you and other consumers about our goods or services that may interest you or them, including developing profiles.
Manage your consumer relationship with us, including for:
- online account creation, maintenance, and security;
- reaching you, when needed, about your account; and
Perform data analytics and benchmarking.
Administer and maintain the Company’s systems and operations, including for safety purposes.
Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
Comply with all applicable laws and regulations.
Exercise or defend the legal rights of the Company and its employees.
Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
Ensuring physical safety.
Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
- disclose the sensitive personal information to another third party; or
- use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
Activities required to:
- verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
- improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

Because our business is new, we have not disclosed consumers’ personal information to third parties for a business purpose in the preceding 12 months; however, we may do so in the following 12 months.

Selling or Sharing Personal Information

Because our business is new, we have not sold your personal information, including sensitive personal information, to third parties and have not sold it in the preceding 12 months; however, we may do so in the following 12 months.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know“), including the specific pieces of personal information we have collected about you (a “data portability request“). You may make exercise your right to know twice within in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you:

The categories of:
- personal information we collected about you; and
- sources from which we collected your personal information.
The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
- disclosed for a business purpose to each category of persons; and
- sold or shared to each category of third parties.
When your right to know submission includes a data portability request, a copy of your personal information subject to any permitted redactions.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the “right to delete“). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct“). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “right to limit“). As we do not use or disclose sensitive personal information beyond the CCPA’s Permitted SPI Purposes, we do not currently provide this consumer right/Once we receive your valid request, we will limit the use and disclosure of your sensitive personal information to the Permitted SPI Purposes.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out“), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in“)

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, or Correct

To exercise the right to know, data portability, delete, or correct described above, please submit a verifiable request to us by either:

Emailing us at info@POLARISBRANDPROMOTIONS.com

Exercising the Right to Limit or Opt-Out

You can submit your request through:

Emailing us at info@POLARISBRANDPROMOTIONS.com

You can also submit your request to opt-out of personal information sales and sharing through an opt-out preference signal.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. If your minor child is our consumer, you may also make a verifiable request on their behalf. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

Responding to Your Requests to Know, Delete, or Correct

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

We do not charge a fee to process or respond to your verifiable 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.

Response and Timing on Rights to Limit or Opt-Out

In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. You do not need to create an account with us to exercise your limitation and opt-out rights. We will only use personal information provided from your request to comply with the request.

We will also notify our service providers, contractors, and certain other downstream recipients of your request to limit or opt-out and instruct them to both:

Comply with your request.
Forward the request to their own downstream recipients, if applicable.

Once you make a request to limit or opt-out, we will wait at least 12 months before asking you to reauthorize the use or disclosure of your sensitive personal information for purposes other than the Permitted SPI Purposes or personal information sales or sharing. However, you may change your mind and opt back in at any time by:

Emailing us at info@POLARISBRANDPROMOTIONS.com

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, e-mail, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time, as we continue to develop our compliance program in response to legal developments of the CCPA.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, or your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: info@POLARISBRANDPROMOTIONS.com