A.B.L.E. Privacy Policy

SECTION 1 — Scope and Definitions

This Privacy Policy applies to all visitors, account holders, subscribers, cohort participants, coaching clients, community members, Personal Study walkers (anonymous or authenticated), and any other person who interacts with the Services.

For purposes of this Privacy Policy:

• "Personal Information" means information that identifies, relates to, describes, or could reasonably be linked to an identified or identifiable individual, such as your name, email, mailing address, phone number, payment information, account credentials, or any data submitted under your account.
• "Personal Study Data" means information you provide while walking the Personal Study, including your identity claim, item responses, verification responses, cost answer, generated reflection points (also called "gap lines"), and session metadata.
• "User Content" has the meaning set out in the Terms of Use.
• "Anonymous Personal Study Data" means Personal Study Data submitted during an anonymous Personal Study walk where no exit email is provided.
• "Sensitive Data" has the meaning set out in Section 2A.1.

SECTION 2 — Information We Collect

2.1 — Information you provide directly

We collect information you provide directly to us when you:

• visit the website;
• walk the Personal Study;
• create an account;
• enroll in a cohort, coaching engagement, or other paid service;
• submit a Client Intake or Fitness-for-Coaching form;
• participate in coaching sessions, cohort meetings, community spaces, events, or other Services;
• contact us through email, support channels, or other communication methods;
• complete optional forms, surveys, testimonial releases, or feedback requests.

Information collected directly may include:

• name, email, mailing address, phone number, and other contact information;
• account credentials and authentication data (we use magic-link authentication; we do not store passwords);
• payment information (processed by third-party payment processors; the Company does not directly store full payment card data);
• physical location information sufficient to confirm jurisdictional eligibility (country and state or province) per Section 2 of the Terms of Use;
• Personal Study Data, including your identity claim, item responses, verification responses, cost answer, and generated gap lines;
• intake and fitness-for-coaching responses, where applicable;
• coaching session content (your reflections, comments, PUC entries, journal entries, and similar User Content);
• community posts, comments, and interactions;
• testimonial content where you have provided a Media, Testimonial, and Marketing Release;
• communications you send to us.

2.2 — Information collected automatically

When you interact with the Services, we automatically collect:

• device information (browser type, operating system, screen size, device identifier);
• IP address and approximate geolocation derived from IP;
• usage data (pages viewed, features used, session duration, click patterns);
• referral source (the website or campaign that brought you to us, where available);
• cookies and similar technologies (described in Section 8).

2.3 — Information from third parties

We may receive information about you from third parties, including:

• payment processors (confirmation of payment, not full card data);
• email service providers (delivery status, open rates, click rates for marketing emails only — not for Personal Study exit-path or transactional emails);
• analytics providers (aggregated platform usage data);
• scheduling tools (appointment metadata for coaching sessions).

2.4 — Information we do not collect

We do not collect:

• social security numbers, government identification numbers, passport numbers, or driver's license numbers (unless required for a specific operational purpose and collected through a separate consent process);
• full payment card numbers (processed by payment processor, not stored by the Company);
• biometric data (fingerprints, facial recognition, voice prints);
• precise GPS geolocation (we derive approximate geolocation from IP only);
• information from children under 18 (the Services are 18+ per Section 12).

SECTION 2A — Sensitive Data and Standalone Consent

2A.1 — Highest-Common-Denominator Sensitive-Data Consent Model

The Company voluntarily applies a highest-common-denominator sensitive-data consent model that meets or exceeds the requirements of applicable U.S. state privacy laws (including the Texas Data Privacy and Security Act, the California Consumer Privacy Act and California Privacy Rights Act, and similar state frameworks), Canadian privacy law (the Personal Information Protection and Electronic Documents Act and applicable provincial privacy frameworks, including Quebec's private sector privacy law), and general best practices for platforms handling spiritually, emotionally, and assessment-related disclosures.

Under this highest-common-denominator model, the Company recognizes certain categories of information as sensitive data requiring heightened protection and standalone consent before collection. Sensitive data under this Privacy Policy includes:

• Religious and faith-informed reflections — including identity claims, cost answers, gap-line responses, coaching reflections, and any other Personal Study Data or User Content that reflects religious belief, spiritual practice, faith commitment, or related personal disclosure;
• Health-adjacent information — including self-reports about physical health, mental health, substance use, sleep, stress, trauma history, eating, or other matters that relate to health even where the Company is not providing health care;
• Emotionally and relationally sensitive disclosures — including disclosures about relationships, family dynamics, vulnerability, conflict, regret, identity, or other matters the Company recognizes as carrying emotional weight;
• Information about minors — to the extent any information about minors is incidentally collected, even though A.B.L.E. Services are intended for adults eighteen (18) or older;
• Other categories identified as sensitive data by applicable law.

2A.2 — Standalone Consent Requirement

Before the Company collects sensitive data, the Company will:

• present a standalone consent disclosure identifying the specific category of sensitive data being collected, the purpose of collection, the retention period, and the rights available to the individual;
• obtain explicit opt-in consent that is distinct from general acceptance of these terms — the consent is not bundled inside general Privacy Policy acceptance, Terms of Use acceptance, account-creation acceptance, or checkout acceptance;
• capture and log the consent event including the consent version, the date and time of consent, and the consent action.

The standalone consent disclosure appears at Personal Study entry (before any Personal Study walk), at account creation (before any account-bound sensitive data is collected), at checkout (before any program-bound sensitive data is collected), and at any platform feature that initiates a new category of sensitive data collection.

2A.3 — Right to Withdraw Consent

You may withdraw consent to sensitive data collection at any time by contacting the Company at info@ableframework.com. Withdrawal of consent does not affect the lawfulness of processing based on consent before the withdrawal, but no further sensitive data collection of the withdrawn category will occur. Withdrawal of consent may affect the Company's ability to provide certain Services where the sensitive data is necessary to the Service.

2A.4 — Operational Implementation

The Company's standalone sensitive-data consent architecture is implemented in coordination with the Company's platform systems and is subject to operational verification before launch and at periodic audit cycles. Operational implementation requirements are set out in the Company's internal Information Security Policy.

2A.5 — Sensitive Information Disclosed During Sessions

During participation in the A.B.L.E. Practice, a member may voluntarily disclose information concerning personal beliefs, health, emotional experiences, or other sensitive matters. Where A.B.L.E. processes information qualifying as special-category personal data, it will do so only where an applicable lawful basis and additional legal condition are satisfied. Where explicit consent is relied upon, A.B.L.E. will obtain and record that consent before processing the information for the stated purpose. Members may decline to provide sensitive information and may withdraw consent where consent is the applicable processing condition, subject to applicable legal requirements. Consent given for the Personal Study under Section 2A.2 does not by itself authorize the recording or further processing of sensitive information disclosed later in a session.

SECTION 3 — How We Use Information

We use the information we collect to:

• provide, operate, maintain, and improve the Services;
• authenticate your account and process magic-link sign-ins;
• enable Personal Study walks (anonymous and authenticated);
• deliver coaching sessions, cohort participation, community access, and related Services;
• process payments and manage billing;
• communicate with you about your account, sessions, scheduling, billing, and Services;
• send Personal Study exit-path follow-up communications per Section 7.2 if you provided an email at the Personal Study exit;
• send re-engagement communications per Section 7.3 if you elected the deferred state at Personal Study exit;
• send marketing communications per Section 7.4 if you have opted in;
• enforce the Terms of Use and any policy incorporated by reference;
• comply with law, court order, regulatory request, or other legal process;
• protect the safety of users, the Company, or the public, including under the Company's safety protocols described in Section 4.4 and the Master Success Architect Coaching Agreement;
• conduct internal research, product evaluation, platform analytics, and business development (using aggregated, de-identified, or anonymized data where individual identification is not necessary);
• support AI-assisted features as described in Section 6.

Lawful bases for processing. Where the UK General Data Protection Regulation, the General Data Protection Regulation, or a similar law requires the Company to identify a lawful basis for processing, the Company relies on the following, depending on the processing activity: contractual necessity, for creating and delivering memberships and sessions and for processing payments and refunds; compliance with legal obligations, for tax, accounting, statutory, and mandatory reporting records and, where applicable, for payment records; legitimate interests, supported by a documented balancing assessment, for security and fraud prevention; and consent, or another basis permitted in the relevant jurisdiction, for marketing communications, which the Company sends in compliance with applicable electronic marketing rules. Where special-category personal data is processed, including Personal Study responses and sensitive information disclosed during sessions, the Company relies on the lawful basis for the underlying activity together with an additional condition, ordinarily explicit consent obtained under Section 2A. AI-assisted preparation under Section 6 relies on the lawful basis of the underlying activity together with any additional condition that applies to special-category data; the use of a technology provider does not itself create a new lawful basis.

SECTION 4 — How We Store and Retain Information

4.1 — Storage

We store information using third-party infrastructure providers (including database and authentication providers) that operate under contractual data-protection commitments. Information is stored in the United States.

4.2 — Anonymous Personal Study Data retention

Anonymous Personal Study Data (Personal Study walks where no email is provided at exit) is retained for a maximum of ninety (90) days from the date of the Personal Study walk. After 90 days, Anonymous Personal Study Data is automatically purged from active systems and from routine backups consistent with the Company's Data Retention Policy. Limited backup retention may apply per Section 4.4.

4.3 — Member account and Personal Study Data retention

Personal Study Data submitted under an authenticated account, account profile data, coaching session content, and other Personal Information associated with an account is retained for the duration of your active engagement plus a post-closure period of three (3) years for legal, operational, and audit purposes. After the three-year post-closure period, retained Personal Information is either deleted from active systems or archived in a secure read-only format as described in the Data Retention Policy.

4.4 — Retention exceptions

The following categories of information may be retained longer than the periods described in Sections 4.2 and 4.3:

• Financial transaction records — retained per applicable tax and financial recordkeeping law (typically seven (7) years).
• Legal compliance records — retained for the duration legally required.
• Mandatory reporting records — reports of suspected abuse, neglect, exploitation, or endangerment involving children, elderly adults, dependent adults, or other persons at risk; threats made to or about Clients where reporting is mandated under applicable law — retained permanently as required by applicable jurisdictional reporting law (based on the client's physical location, the location of the person at risk, and the most protective applicable standard per the Company's Jurisdictional / Highest Common Denominator safety reporting standard) and federal record-preservation obligations.
• Litigation-hold records — retained for the duration any litigation hold is in effect.
• Backup retention — limited backup retention may extend beyond active-system deletion windows; backups are purged on a defined cycle described in the Data Retention Policy.

4.5 — Re-engagement workflow data

If you provided an email at Personal Study exit and elected the deferred state ("I'll come back to this"), the Company retains:

• the email you provided;
• the Personal Study walk record associated with that email;
• the re-engagement cadence state per Section 7.3.

This retention continues until you re-engage, opt out, or eight (8) weeks have elapsed from the deferred Personal Study walk, whichever is first. After eight weeks without re-engagement, the email is removed from the active re-engagement workflow and is retained only per the retention rules applicable to general contact information.

SECTION 5 — How We Share Information

5.1 — Operational vendors

We share information with operational vendors that perform Services for us, including:

• database and authentication providers (Supabase, Render, or successor vendors);
• payment processors (Stripe or successor vendors);
• email service providers (transactional and marketing email delivery);
• scheduling tools;
• analytics providers (aggregated, non-identifying data only);
• AI service providers under the controls described in Section 6;
• counsel and accounting professionals as needed for Company operations.

Vendors operate under contractual data-protection commitments, including written Data Processing Agreements (DPAs) where applicable. Vendors are permitted to use shared information only to perform Services for the Company and not for the vendor's own purposes.

Vendors handling sensitive data identified in Section 2A operate under DPAs that specifically address sensitive data handling, no-training-on-customer-content commitments where applicable, and prohibition on secondary use beyond the contracted service.

5.2 — Within the Company

We share information internally among Company personnel, including Success Architects, administrative staff, and the founder, on a need-to-know basis for the operation of the Services. Internal sharing is limited to what is necessary to support your participation and operate the practice.

5.3 — Legal compliance

We may share information when required by law, court order, subpoena, regulatory request, or other legal process. We may also share information to:

• enforce our Terms of Use;
• protect the safety of users, the Company, or the public;
• comply with mandatory reporting obligations per the Company's Jurisdictional / Highest Common Denominator safety reporting standard;
• respond to fraud, security, or technical issues;
• defend the Company in legal proceedings.

5.4 — Business transfers

If the Company is involved in a merger, acquisition, sale of assets, reorganization, or similar transaction, information may be transferred to the successor entity, subject to the protections of this Privacy Policy or a successor privacy policy that provides comparable protections.

5.5 — With your consent

We may share information with third parties when you provide consent for the specific sharing.

5.6 — What we do not share

The Company does not:

• sell your Personal Information for monetary or other valuable consideration;
• share your Personal Information for cross-context behavioral advertising;
• share your Personal Study Data, coaching session content, or sensitive User Content with third parties for marketing purposes;
• share your information with data brokers;
• create or contribute to "lookalike audiences" using your Personal Information;
• license your User Content to third parties for AI model training;
• treat your Personal Information as a commodity.

The Company recognizes that men have to feel safe in their transparency for the formation work of the Services to operate as intended. The Company's posture toward third-party sharing reflects this operational reality and the Company's commitment to the dignity of every man who engages with the Services.

SECTION 6 — AI-Assisted Features

6.1 — How AI is used

The Company uses artificial intelligence and large-language-model technology to support certain aspects of the Services, which may include:

• pattern recognition and summarization across Personal Study responses, PUC entries, and reflective content;
• preparation support for Success Architects in advance of coaching sessions;
• content delivery, prompt generation, and reflective exercise support;
• platform features that may use AI-assisted personalization.

AI is used as enhancement to the Company's coaching methodology and to the Success Architects' professional judgment. AI is not a substitute for human Success Architect engagement.

6.2 — Artificial Intelligence Processing

A.B.L.E. may use commercial artificial intelligence services to support administrative preparation, organization of information, and the delivery of authorized services. Where A.B.L.E. submits personal information to an artificial intelligence provider, that processing is subject to applicable contractual, privacy, and data protection requirements. A.B.L.E. uses commercial services whose applicable business terms restrict the use of customer content for model training, subject to the terms, settings, and exceptions governing the particular service. These restrictions do not mean that submitted information is never temporarily retained or otherwise processed. Information may be processed or retained for service delivery, security, abuse prevention, or other purposes permitted under the applicable service agreement. A.B.L.E. will apply appropriate data minimization measures and will process special-category personal information only where the applicable lawful basis and additional legal condition have been satisfied. A.B.L.E. will not represent that a provider operates under a zero data retention arrangement unless that arrangement has been confirmed for the applicable service and configuration. AI service providers operate under written Data Processing Agreements, which the Company reviews periodically and retains in its legal operations file; the Company controls what User Content is submitted to AI features and may restrict AI submission for sensitive data categories per Section 2A.

6.3 — Data submitted to AI features

Specific data categories that may be submitted to AI features include:

• Personal Study responses (for pattern recognition and Success Architect preparation);
• PUC entries (for reflective summary and challenge design support);
• coaching session content (for Success Architect preparation, with Success Architect discretion over what is submitted);
• platform analytics queries (for product improvement, using aggregated and de-identified data).

The Company does not submit to AI features:

• payment information;
• account credentials;
• mandatory reporting records;
• litigation-hold records;
• legal-privileged communications.

SECTION 7 — Communications and Re-Engagement

7.1 — Transactional and service communications

We send transactional and service communications related to your account, sessions, scheduling, billing, security, terms changes, policy changes, and similar operational matters. You cannot opt out of transactional and service communications while you have an active account.

7.2 — Personal Study exit-path communications

If you provided an email at the Personal Study exit, the Company may send:

• a confirmation email summarizing what comes next based on your exit choice (book a call, deferred state, or other path);
• scheduling information if you elected to book a call;
• materials related to your Personal Study walk and the Company's Services.

Personal Study exit-path communications are transactional in nature where they continue the process you initiated by providing your email. They are not marketing communications.

7.3 — Re-engagement cadence

If you walk the Personal Study, provide your email at exit, and elect the deferred state ("I'll come back to this"), the Company may send re-engagement communications to you on a low-frequency cadence:

• approximately seven (7) days after the deferred Personal Study walk;
• approximately three (3) weeks after the deferred Personal Study walk;
• approximately eight (8) weeks after the deferred Personal Study walk.

After the eight-week communication, the Company does not send further re-engagement messages unless you re-engage with the Services (return to the Personal Study, book a call, contact the Company, or take similar action).

Re-engagement communications honor the deferred-state register: they are patient, not urgent, and reflect the man's own declaration that he intends to come back when he is ready.

7.3.1 — CAN-SPAM classification of re-engagement communications

Re-engagement communications classified under Section 7.3 may contain a combination of transactional/service content (continuing a process the user initiated by submitting email at Personal Study exit) and promotional content (encouraging return to the Services). To address the CAN-SPAM Act and the FTC CAN-SPAM Rule, the Company:

• includes an opt-out mechanism in every re-engagement email regardless of classification;
• includes accurate header information identifying the Company as sender;
• includes the Company's physical mailing address in every re-engagement email;
• honors opt-out requests within ten (10) business days of receipt;
• does not classify re-engagement communications as transactional-only where the predominant content is promotional.

Users who wish to opt out of re-engagement communications but maintain other account-related communications may do so by using the unsubscribe link in any re-engagement email or by contacting the Company at info@ableframework.com.

7.4 — Marketing communications

The Company may send marketing communications about the Services, including new programs, content, events, and offerings, only to users who have opted in to receive marketing communications. You may opt out of marketing communications at any time by:

• using the unsubscribe link in any marketing email;
• updating your communication preferences in your account settings;
• contacting the Company at info@ableframework.com.

SECTION 8 — Cookies and Similar Technologies

The Services use cookies and similar technologies (web beacons, pixel tags, local storage) for:

• session management (keeping you signed in across pages);
• authentication (magic-link sign-in);
• preference storage (your settings and choices);
• analytics (understanding how the Services are used, on an aggregated basis);
• security (detecting unusual activity).

The Company does not use cookies for cross-context behavioral advertising or for "lookalike audience" construction.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect Service functionality (for example, disabling authentication cookies will prevent magic-link sign-in).

If you access the Services through a third-party platform (such as a social media link or external scheduling tool), that platform's cookie practices apply to your interaction with it. The Company does not control third-party cookie practices on third-party platforms.

SECTION 9 — Security

The Company implements reasonable administrative, technical, and physical safeguards designed to protect Personal Information against loss, unauthorized access, disclosure, alteration, and destruction. Security measures include:

• encryption of data in transit and at rest;
• access controls limiting Company personnel access to Personal Information on a need-to-know basis;
• magic-link authentication (we do not store passwords);
• vendor security commitments under Data Processing Agreements;
• regular security review of platform infrastructure.

No security measures are perfect. The Company cannot guarantee that information will never be accessed by unauthorized parties, lost, or compromised. You are responsible for maintaining the security of your account credentials and notifying the Company promptly if you suspect unauthorized access.

In the event of a data breach affecting Personal Information, the Company will provide notification consistent with applicable law, including Wyoming breach notification law (Wyo. Stat. § 40-12-501 et seq.), which requires notification in the most expedient time possible and without unreasonable delay. Notification to applicable state attorneys general, regulators, or other authorities will be provided where required by applicable law based on the residency of affected individuals and the materiality of the incident.

SECTION 10 — Your Rights and Choices

10.1 — Right to access

You have the right to request access to the Personal Information the Company holds about you. The Company will provide a reasonable response within a reasonable timeframe.

10.2 — Right to correction

You have the right to request correction of inaccurate Personal Information. You may correct most account information directly through your account settings.

10.3 — Right to deletion

You have the right to request deletion of your Personal Information. The Company will honor deletion requests subject to:

• legal retention obligations (financial records, mandatory reporting records, litigation-hold records);
• operational retention necessary to complete a transaction the user initiated;
• the Company's right to retain de-identified or aggregated data that no longer reasonably identifies the individual.

The Company processes deletion requests within a reasonable timeframe consistent with applicable law.

10.4 — Right to portability

You have the right to request a copy of your Personal Information in a portable format. The Company will provide a portable copy within a reasonable timeframe consistent with applicable law.

10.5 — Right to opt out of marketing

You have the right to opt out of marketing communications at any time per Section 7.4.

10.6 — How to exercise your rights

To exercise any right under this Section 10, contact the Company at info@ableframework.com. The Company may verify your identity before honoring a rights request to protect against unauthorized access to your information.

10.7 — Jurisdiction-specific rights

Residents of certain jurisdictions may have additional rights under applicable law:

• United States — California residents may have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what categories of Personal Information are collected, the right to opt out of sale or sharing of Personal Information (the Company does not sell or share Personal Information for cross-context behavioral advertising), and the right to non-discrimination for exercising rights.
• United States — Texas residents have rights under the Texas Data Privacy and Security Act (TDPSA), including specifically the right to standalone consent before collection of sensitive data as set out in Section 2A of this Privacy Policy.
• United States — other states may have rights under state-specific consumer privacy laws (Colorado, Connecticut, Virginia, Utah, and others). The Company honors the rights described in Sections 10.1 through 10.6 as standard for all users regardless of jurisdiction.
• Canada — Canadian residents have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, including the right to access Personal Information held by the Company, the right to correction, the right to withdraw consent (subject to operational implications of withdrawal), and the right to file a complaint with the Office of the Privacy Commissioner of Canada or applicable provincial privacy commissioner.
• Quebec — Where the Company has authorized enrollment or purchase for individuals located in Quebec, those individuals, and individuals in Quebec who visit the website or otherwise interact with the Company, have the rights applicable to them under Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, including the rights of access, rectification, and withdrawal of consent, and the right to file a complaint with the Commission d'accès à l'information du Québec. These rights may be exercised through the contact in Section 10.8.
• United Kingdom — Where the Company has authorized enrollment or purchase for individuals located in the United Kingdom, those individuals have rights under the UK General Data Protection Regulation and the Data Protection Act 2018, including the rights of access, rectification, erasure, restriction of processing, data portability, and objection, and the right to lodge a complaint with the Information Commissioner's Office.
• Nigeria — Where the Company has authorized enrollment for individuals located in Nigeria, those individuals have the rights described in the Nigeria disclosures in Section 13 and under the Nigeria Data Protection Act 2023.
• European Union and European Economic Area — Individuals in the European Union or European Economic Area who visit the website, walk the Personal Study, enroll, or otherwise interact with the Company have the rights provided by the General Data Protection Regulation, including access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with their supervisory authority, exercisable through the contact in Section 10.8.

The Company honors the rights described in Sections 10.1 through 10.6 as standard for all users regardless of jurisdiction. Where a jurisdiction-specific right exceeds the standard rights, the jurisdiction-specific right applies.

SECTION 11 — Changes to This Privacy Policy

The Company may, from time to time, update, modify, or amend this Privacy Policy. The Company will communicate material changes through reasonable means, including posting on the website, posting on the platform, email to your account address if you have one, or other reasonable notification methods. The "Last Updated" date at the top of this Privacy Policy reflects the most recent material change.

For material changes that affect how the Company handles Personal Information you have already provided, the Company will provide reasonable advance notice of the change and, where applicable law requires, obtain renewed consent.

For non-material updates (clarification of language, formatting changes, correction of typographical errors), notice through the website or platform is sufficient.

If you have entered into the Master Success Architect Coaching Agreement, that Agreement's committed-member protection provisions apply to material changes that affect your privacy rights under this Privacy Policy.

SECTION 12 — Children

The Services are intended for adults eighteen (18) years of age or older. The Company does not knowingly collect Personal Information from children under 18.

If you are under 18, do not use the Services and do not provide Personal Information to the Company.

If the Company learns that it has inadvertently collected Personal Information from a child under 18, the Company will delete the information promptly from active systems and from routine backups consistent with the Company's data deletion protocols.

Parents or guardians who believe a child under 18 has provided Personal Information to the Company may contact the Company at info@ableframework.com to request deletion.

SECTION 13 — Operations Location and Cross-Border Services

The Services are operated by A.B.L.E. Framework, LLC, a Wyoming limited liability company, operating as a Wyoming-anchored, mobile, virtual coaching and platform enterprise. The Services are available to individuals worldwide, except in jurisdictions the Company has restricted under Section 2 of the Terms of Use, as disclosed through the enrollment process.

International Processing and Transfers. A.B.L.E. Framework LLC is established in the United States and uses technology service providers that may process personal information in the United States and other countries. Where personal information originating in the United Kingdom, European Economic Area, or Switzerland is subject to applicable international transfer restrictions, A.B.L.E. will rely on a legally recognized transfer mechanism appropriate to the relevant transfer. Depending on the provider, jurisdiction, and processing activity, these mechanisms may include the European Commission's Standard Contractual Clauses, the United Kingdom's International Data Transfer Agreement or Addendum, applicable adequacy arrangements, or other safeguards permitted by law. Where applicable, A.B.L.E. will assess the risks associated with restricted international transfers and implement supplementary protections when required. A.B.L.E. does not represent that it is independently certified under the EU-US Data Privacy Framework. Information concerning applicable transfer safeguards may be requested using the contact information provided in this Policy.

For Canadian residents, the Company's cross-border data transfer is grounded in the Personal Information Protection and Electronic Documents Act (PIPEDA) accountability framework and, for individuals in Quebec, the transfer provisions of Quebec's private sector privacy law. The Company maintains comparable levels of protection for Canadian personal information transferred to the United States as required by applicable Canadian law.

United Kingdom Residents. Where the United Kingdom General Data Protection Regulation and Data Protection Act 2018 apply, A.B.L.E. processes personal information in accordance with the lawful bases and, where applicable, special-category processing conditions identified in this Policy. These may include contractual necessity, compliance with legal obligations, legitimate interests, and consent, depending on the processing activity. Personal information may be processed outside the United Kingdom, including in the United States, subject to applicable international transfer requirements and safeguards. Individuals whose information is subject to UK data protection law may exercise the applicable rights described in Section 10.7. Individuals also have the right to lodge a complaint with the United Kingdom Information Commissioner's Office. A.B.L.E. encourages individuals to contact the company with privacy concerns so that they may be reviewed and addressed promptly. Contacting A.B.L.E. is not a prerequisite to filing a complaint with the Information Commissioner's Office.

Individuals located in jurisdictions the Company has not authorized are not eligible to enroll in the Services per Section 2 of the Terms of Use.

Nigeria — Additional Privacy Disclosures

Application. These additional disclosures apply where A.B.L.E. processes personal information concerning individuals in Nigeria and Nigerian data protection law applies.

Applicable Law. The Company recognizes applicable obligations under the Nigeria Data Protection Act 2023 and implementing regulations and guidance issued by the Nigeria Data Protection Commission.

Sensitive Personal Data. The Personal Study and related coaching activities may involve information revealing religious beliefs, health-related circumstances, and other sensitive personal information. The Company provides separate information and obtains the consent or other authorization required by applicable law before processing sensitive personal information.

International Processing. A.B.L.E. Framework LLC is established in the United States. Personal information may be processed by the Company and authorized service providers outside Nigeria, including in the United States. The Company will undertake international transfers only where an applicable lawful transfer basis and required safeguards have been established. Additional information concerning applicable transfer safeguards may be requested using the privacy contact details provided in this Policy.

Individual Rights. Subject to applicable law, individuals may exercise rights concerning access to personal information, correction, deletion, objection, withdrawal of consent, and other rights provided under Nigerian data protection law. Requests may be submitted to info@ableframework.com.

Complaints. Individuals may contact A.B.L.E. regarding concerns about the processing of their personal information. Where applicable, individuals may also exercise their right to complain to the Nigeria Data Protection Commission.

Regulatory Status. The Company will maintain any registration, designation, or other regulatory status required under applicable Nigerian data protection law.

SECTION 14 — Contact

Questions about this Privacy Policy, requests to exercise rights described in Section 10, or other privacy-related concerns may be directed to:

A.B.L.E. Framework, LLC

Attn: Privacy

info@ableframework.com

30 N Gould St Ste R, Sheridan, WY 82801, USA

The Company will respond to privacy inquiries within a reasonable timeframe and consistent with applicable law.

END OF PRIVACY POLICY