LEGAL

Privacy Policy

Effective Date: 19 May 2026 · Last Updated: 19 May 2026

This Privacy Policy explains how LeadSharper, operated by HBN Ventures LLC ("we," "our," or "us"), collects, uses, stores, and protects your personal information when you visit www.leadsharper.com or engage with our services. We are committed to protecting your privacy and complying with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

1. Who We Are (Data Controller)

LeadSharper is operated by HBN Ventures LLC, headquartered in the United States. For the purposes of GDPR, HBN Ventures LLC is the Data Controller. Contact for privacy matters: Email: nevilletarapore@leadsharper.com Website: www.leadsharper.com

2. What Personal Data We Collect

We collect the following personal data when you submit an enquiry form or interact with our services: • Full Name • Email Address • Phone Number (optional) • Company / Organisation name (optional) • Job Title / Role (optional) • LinkedIn Profile URL (where voluntarily provided) • Message content and enquiry details • IP address and browser/device information (collected automatically via our hosting platform) We do not collect sensitive personal data (e.g. race, health, financial account numbers).

3. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) and UK, we process your personal data under the following legal bases: • Consent (Article 6(1)(a)): When you tick the consent checkbox on our contact form, you give us explicit consent to process your data to respond to your enquiry and send relevant communications. • Legitimate Interests (Article 6(1)(f)): For internal analytics, security, and improving our services. • Contract Performance (Article 6(1)(b)): When processing is necessary to fulfil a service agreement with you. You may withdraw consent at any time by emailing us at nevilletarapore@leadsharper.com.

4. How We Use Your Data

We use your personal data to: • Respond to your enquiry or service request • Schedule coaching sessions or discovery calls • Send relevant program information you have requested • Improve our website and services • Comply with legal obligations We do NOT sell your personal data to third parties. We do NOT use your data for automated profiling or decision-making.

5. Data Retention

We retain your personal data for no longer than is necessary for the purposes described in this policy: • Enquiry data: Retained for up to 24 months from date of submission, unless you request deletion earlier. • Client engagement data: Retained for the duration of the coaching relationship plus 3 years for legal and accounting purposes. • You may request deletion of your data at any time (see Section 9).

6. Third-Party Services & Data Processors

We use the following third-party services that may process your data on our behalf: • Base44 (base44.com) — Application hosting and database platform • Resend — Email delivery service • Calendly — Session scheduling (governed by Calendly's own Privacy Policy) • Cloudflare Turnstile — Bot protection (no personal data stored) All third-party processors are contractually required to process data only on our instructions and to maintain appropriate security standards. Where processors are based outside the EEA, we rely on Standard Contractual Clauses (SCCs) or equivalent safeguards.

7. Cookies & Tracking

Our website uses the following types of cookies and scripts: • Strictly Necessary: Required for site functionality (e.g. session management). No consent required. • Third-Party Scripts: Calendly and Cloudflare Turnstile load scripts that may set cookies for functionality and security purposes. We currently do not use advertising or behavioural tracking cookies. You can control cookies through your browser settings. Disabling cookies may affect site functionality.

8. California Residents — CCPA Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA): • Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you. • Right to Delete: You may request that we delete your personal information, subject to certain exceptions. • Right to Correct: You may request correction of inaccurate personal information. • Right to Opt-Out of Sale: We do not sell personal information. No opt-out is needed. • Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA rights. To exercise these rights, contact us at nevilletarapore@leadsharper.com. We will respond within 45 days.

9. Your GDPR Rights (EEA & UK Residents)

If you are located in the EEA or UK, you have the following rights: • Right of Access (Article 15): Request a copy of your personal data. • Right to Rectification (Article 16): Request correction of inaccurate data. • Right to Erasure / "Right to be Forgotten" (Article 17): Request deletion of your data. • Right to Restrict Processing (Article 18): Request we limit how we use your data. • Right to Data Portability (Article 20): Receive your data in a machine-readable format. • Right to Object (Article 21): Object to processing based on legitimate interests. • Right to Withdraw Consent: Withdraw consent at any time without affecting prior processing. To exercise any of these rights, email: nevilletarapore@leadsharper.com You also have the right to lodge a complaint with your local data protection authority (e.g. the ICO in the UK, or your national DPA in the EU).

10. Data Security

We take data security seriously. Measures in place include: • Data is hosted on Base44's secure cloud infrastructure with encryption at rest and in transit (TLS/HTTPS). • Access to personal data in our admin dashboard is restricted to authorised personnel only. • Bot protection via Cloudflare Turnstile on all forms. • We do not store payment card information — payments are handled by our payment processor. No system is 100% secure. In the event of a data breach that poses a risk to your rights, we will notify you and relevant authorities as required by law.

11. International Data Transfers

HBN Ventures LLC is based in the United States. If you are located in the EEA or UK, your data will be transferred to and processed in the US. We rely on Standard Contractual Clauses (SCCs) approved by the European Commission to lawfully transfer data to the US where required.

12. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this policy periodically. Continued use of our website after changes constitutes acceptance of the updated policy.

14. Contact Us

For any privacy-related questions, requests, or complaints: Email: nevilletarapore@leadsharper.com Website: www.leadsharper.com Operated by: HBN Ventures LLC

By submitting an enquiry form on this website, you acknowledge that you have read and understood this Privacy Policy.

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