PRIVACY POLICY

Last updated: April 25, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Ascendyn, Inc., doing business as Ascendyn Advertising, 77935 Calle Tampico #101, La Quinta, CA 92253.

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: California, United States

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company.

SMS means short message service, including text and multimedia messages sent to and from mobile phone numbers.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.

Website refers to Ascendyn Advertising, accessible from https://directresponseadagency.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number (mobile and/or landline)

• Business name and business information

• Address, State, Province, ZIP/Postal code, City

• Information about Your business, advertising goals, or workshop interest

• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.

• Web Beacons. Certain sections of Our Service and Our emails may contain small electronic files known as web beacons that permit the Company to count users who have visited those pages or opened an email and for other related website statistics.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the following purposes:

Necessary / Essential Cookies - Type: Session Cookies - Administered by: Us - Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features.

Cookies Policy / Notice Acceptance Cookies - Type: Persistent Cookies - Administered by: Us - Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies - Type: Persistent Cookies - Administered by: Us - Purpose: These Cookies allow Us to remember choices You make when You use the Website.

Tracking and Performance Cookies - Type: Persistent Cookies - Administered by: Third-Parties - Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website.

SMS / Text Messaging Communications

When You provide Your mobile phone number and check the SMS consent box on Our website, You opt in to receive transactional text messages from Ascendyn Advertising. These messages may include:

• Workshop registration confirmations and reminders

• Agency client onboarding, project, and meeting updates

• Follow-up communications tied to an existing inquiry, scheduled workshop, or active engagement

• Other service-related updates

Message frequency varies. Message and data rates may apply. Reply HELP for help or STOP to opt out at any time.

Mobile information, phone numbers, and SMS consent will not be shared with or sold to third parties or affiliates for marketing or promotional purposes under any circumstances. Phone numbers may only be shared with Our subcontracted SMS messaging platform strictly for the purpose of delivering the messages You have opted in to receive. This information sharing is limited to message delivery and explicitly excludes any marketing, promotional, or third-party use.

This restriction on SMS information takes precedence over any other provision in this Privacy Policy. Opting out of SMS messages will not affect Your ability to receive service from Ascendyn Advertising through other communication channels such as phone or email.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain Our Service, including to monitor the usage of Our Service.

• To manage Your Account: to manage Your registration as a user of the Service.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services.

• To provide You with information about Our services, workshops, special offers, and general updates about Our business, where You have not opted out of receiving such information. This excludes SMS marketing communications, which are governed by the SMS / Text Messaging Communications section above.

• To manage Your requests: To attend and manage Your requests to Us.

• To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness. This excludes mobile phone numbers and SMS consent information.

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our Service, products, services, marketing and Your experience.

We may share Your personal information in the following limited situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of Our Service, to advertise on third party websites to You after You visited Our Service, and to contact You. Service Providers are contractually required to protect Your information and use it only for the purposes We direct.

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We do not share Your personal information with affiliates, business partners, or other third parties for their own marketing or promotional purposes. Mobile phone numbers and SMS consent information are subject to the additional restrictions described in the SMS / Text Messaging Communications section above.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations, resolve disputes, and enforce Our legal agreements and policies.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. You may contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Analytics

We may use third-party Service providers to monitor and analyze the use of Our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. For more information on the privacy practices of Google, please visit: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

Lead Connector

Their Privacy Policy can be viewed at https://www.gohighlevel.com/privacy-policy

Call Tracking

We use call tracking services to record, analyze, and attribute inbound phone calls made to phone numbers displayed on Our Service. When You call a phone number on Our Service, the call may be recorded and the following information may be collected: Your phone number, the date and time of the call, the duration of the call, the source that referred You (such as the search engine, ad, or page You came from), and the content of the call (audio recording and/or transcript).

Call recordings and transcripts are used for quality assurance, training, customer service, lead attribution, and improving Our marketing and Service. Call data is shared only with Our call tracking provider and is not shared with third parties for marketing or promotional purposes.

CallRail

CallRail is a call tracking and analytics service provided by CallRail, Inc. CallRail’s Privacy Policy can be viewed at https://www.callrail.com/privacy/

Session Recording and Heatmap Analytics

We use session recording and heatmap analytics tools to understand how visitors interact with Our Service. These tools may record Your interactions on the Service, including mouse movements, clicks, scrolls, page views, and form interactions. This information is used to identify usability issues, improve the Service, and analyze how visitors use Our pages.

Session recordings and heatmap data are aggregated and pseudonymized where feasible. Sensitive form fields (such as password fields and payment fields) are masked from recordings.

Crazy Egg

Crazy Egg provides session recording, heatmap, and visitor behavior analytics. Crazy Egg’s Privacy Policy can be viewed at https://www.crazyegg.com/privacy

Behavioral Remarketing and Advertising

The Company uses remarketing services to advertise to You after You accessed or visited Our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use Our Service so that We can improve Our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service

• Show advertisements for Our products and/or services to You on third-party websites or apps

• Match Our website visitors to physical mailing addresses for direct mail retargeting

• Measure and analyze the performance of Our advertising campaigns

You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android).

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. Mobile phone numbers and SMS consent information are excluded from any sharing with these advertising and remarketing vendors.

The third-party vendors We use are:

Google Ads

Google Ads remarketing service is provided by Google Inc. You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting: http://www.google.com/settings/ads

For more information on the privacy practices of Google, please visit: https://policies.google.com/privacy

Microsoft Advertising

Microsoft Advertising (formerly Bing Ads) remarketing service is provided by Microsoft Inc. You can opt out of Microsoft Advertising interest-based ads by following their instructions: https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads

For more information on the privacy practices of Microsoft, please visit: https://privacy.microsoft.com/en-us/privacystatement

Meta (Facebook / Instagram)

Meta remarketing service is provided by Meta Platforms, Inc. You can learn more about interest-based advertising from Meta by visiting: https://www.facebook.com/help/516147308587266

To opt out from Meta’s interest-based ads, follow these instructions: https://www.facebook.com/help/568137493302217

For more information on the privacy practices of Meta, please visit Meta’s Data Policy: https://www.facebook.com/privacy/explanation

Choozle

Choozle is a programmatic display advertising platform that uses cookie data and online identifiers to display Our advertisements on third-party websites. For more information and to opt out, visit: https://choozle.com/privacy

Modern Postcard

Modern Postcard provides direct mail retargeting services. Modern Postcard matches website visitor data (such as cookie data and IP address) to physical mailing addresses to send postcards on Our behalf. To opt out of Modern Postcard direct mail, contact Us at [email protected] or visit https://www.modernpostcard.com.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device.

Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, address, telephone number. Collected: Yes.

Category C: Protected classification characteristics under California or federal law. Collected: No.

Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: No.

Category E: Biometric information. Collected: No.

Category F: Internet or other similar network activity. Examples: Interaction with Our Service or advertisement. Collected: Yes.

Category G: Geolocation data. Examples: Approximate physical location. Collected: No.

Category H: Sensory data. Collected: No.

Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations, business name, business role. Collected: Yes.

Category J: Non-public education information. Collected: No.

Category K: Inferences drawn from other personal information. Collected: No.

Category L: Sensitive personal information. Collected: No.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA/CPRA’s scope, such as health/medical information covered by HIPAA, personal information covered by the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

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

• Directly from You. For example, from the forms You complete on Our Service, or preferences You express or provide through Our Service.

• Indirectly from You. For example, from observing Your activity on Our Service.

• Automatically from You. For example, through cookies We or Our Service Providers set on Your Device as You navigate through Our Service.

• From Service Providers. For example, third-party vendors to monitor and analyze the use of Our Service, third-party vendors to deliver targeted advertising to You, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

• To operate Our Service and provide You with Our Service.

• To provide You with support and to respond to Your inquiries.

• To fulfill or meet the reason You provided the information.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• For internal administrative and auditing purposes.

• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers

• Category B: Personal information categories listed in the California Customer Records statute

• Category F: Internet or other similar network activity

• Category I: Professional or employment-related information

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers (such as analytics, advertising, CRM, and SMS messaging platforms)

• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

We do not share personal information with affiliates or business partners for their own marketing or promotional purposes.

Mobile phone numbers and SMS consent information are NOT included in any sharing described above. Such information is shared only with Our SMS messaging platform for the limited purpose of delivering messages You opted in to receive, as described in the SMS / Text Messaging Communications section.

Sale of Personal Information

We do not sell Your personal information for monetary consideration. We do not sell, rent, lease, or trade Your personal information to any third party in exchange for money.

The CCPA/CPRA defines “sell” and “sale” broadly to include disclosing or making available personal information to third parties in exchange for any valuable consideration, which may include certain advertising and analytics arrangements. Under this broad definition, Our use of cookies and online identifiers with advertising and analytics partners (such as Google Ads, Microsoft Advertising, Meta, and Choozle) for interest-based advertising may be deemed a “sale” or “sharing” of personal information under CCPA/CPRA. You have the right to opt out of these arrangements — see the “Do Not Sell or Share My Personal Information” section below.

Mobile phone numbers, SMS opt-in records, and SMS consent information are never sold, rented, transferred, disclosed, or otherwise shared with any third party for any purpose other than message delivery by Our SMS messaging platform. This restriction applies regardless of how broadly “sale” is defined under any applicable law.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through Our Service. We do not sell, rent, transfer, or share the personal information of any individual We know to be under 16 years of age. If You have reason to believe that a child under the age of 16 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

• The right to know/access. You have the right to request that We disclose information to You about Our collection, use, disclosure for business purposes and share of personal information.

• The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us not to sell or share Your personal information.

• The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected.

• The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You.

• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights.

Exercising Your CCPA/CPRA Data Protection Rights

In order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

• By email: [email protected]

• By phone number: (760) 537-3457

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative

• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell or Share My Personal Information

As described above, We do not sell personal information for monetary consideration. However, Our use of advertising and analytics services may constitute a “sale” or “sharing” of personal information under the CCPA/CPRA’s broad definition. You have the right to opt out of these arrangements.

To opt out:

• Use the privacy preferences/cookie controls (if available) on Our Service to manage Your tracking consent.

• Use the industry opt-out platforms below to limit interest-based advertising:

– The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

– The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

• Use device-level settings on mobile devices (“Limit Ad Tracking” on iOS, “Opt out of Ads Personalization” on Android).

• Contact Us directly at [email protected] to make an opt-out request.

Please note that any browser-based opt-out is specific to that browser and that device. You may need to opt out on every browser and device You use.

Mobile phone numbers and SMS consent information are never sold or shared regardless of any opt-out election.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We do not collect or use sensitive personal information except as necessary to provide the Service.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

We do not share personal information with third parties for their direct marketing purposes. If You’d like to confirm or request more information under the California Shine the Light law, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, You can contact us:

• By email: [email protected]

• By phone number: (760) 537-3457

• By mail: Ascendyn, Inc., 77935 Calle Tampico #101, La Quinta, CA 92253