We are committed to protecting your privacy and preserving your trust. Please carefully review this Privacy Policy (the “Privacy Policy”), which provides transparency about our privacy practices, including how American Operator Holdings Co. and its affiliates, including American Operator LLC and American Operator Capital I LLC (together, “American Operator,” “we,” “us,” “our” and the “Company”) collect, process, and disclose any Personal Information, and how you can control and manage your privacy choices.

In this Privacy Policy, a “Visitor” or “you” refers to any visitors of American Operator and its affiliates’ websites (collectively, the “Platform”).

By using the Platform, you agree to this Privacy Policy. You acknowledge and consent to our privacy practices as described below. Failure to maintain compliance with this Privacy Policy may result in losing access to the Platform.

1. Scope and Applicability

The scope of this Privacy Policy applies to American Operator and any of our affiliates with whom we may share Personal Information.

Our relationship with you will determine how this Privacy Policy applies to you and your information. In general, if you engage with us directly and independently of a third party, this Privacy Policy applies. To the extent that your information is processed by an independent third party (e.g., an identity verification provider), then that third party may be responsible for your privacy with respect to that information. If you have any questions as to who is responsible for your information, you may contact us at support@americanoperator.com.

2. Information We Collect and Receive

Visitors

The Personal Information we collect from Visitors includes, but is not limited to:

Your name;
Your email address; and
Your address or general geographic location.

Program Participants / Entrepreneurs

We may offer programs, communities, or resources focused on small business ownership and related topics. Visitors (whether natural persons or entities) who participate in such programs (“Program Participants,” which may include “Entrepreneurs”) may provide additional information, such as:

Legal physical address;
Telephone number;
Date of birth;
Business name and contact details, if applicable;
Responses to further questions answered during profile or program registration;
Username;
Password(s);
Your Google information if you are signing up via Google (this will authenticate your identity and link your information, such as your name, profile image, and email address, to your account);
Your biographical information as used in your profile;
Your address or geographic location;
Your profile image;
Further information to help validate your identity, such as driver’s license information or a government-issued identification number; and
Other information you choose to provide in connection with your participation (for example, business background or experience).

We may also collect additional information as reasonably necessary to support Your use of the Platform.

3. Our Uses of Personal Information

American Operator will use Personal Information to:

Operate, maintain, and provide you with offerings on the Platform;
Facilitate your participation in discussions, groups, and other community features on the Platform;
Communicate with you and send you service-related and marketing communications;
Keep the Platform and other Visitors secure;
Analyze your preferences, interests, and behavior to provide you with tailored and relevant content and communications;
Improve and develop the Platform;
Enforce our Terms of Service, enforce our legal rights, comply with applicable law, and respond to government and legal requests; and
Determine and understand demographics and usage patterns on the Platform.

Depending on your circumstances and your relationship with American Operator, we may process your Personal Information on the following lawful bases (for example, under applicable data protection laws such as the GDPR):

Consent: where you have given consent to the processing of your Personal Information for one or more specific purposes;
Contract: where the processing is necessary for the performance of a contract with you (for example, to deliver any services you have requested);
Legal Obligation: where processing is necessary for compliance with a legal obligation to which we are subject; and
Legitimate Interests: where the processing is necessary for the purposes of our legitimate interests or those of a third party, and such interests are not overridden by your interests or fundamental rights and freedoms (for example, for product development, analytics, and improving the Platform).

5. Communications and Marketing

When you enter your Personal Information, including but not limited to, your email on the Platform, we may send periodic emails to you regarding the Platform or tell you about new features, content, programs, or resources we believe will interest you. You may also subscribe to our blog, newsletter, or other updates. You can opt out of promotional or marketing email communications (including marketing on behalf of our affiliates) by:

Clicking on the unsubscribe link in any email you receive from us;
Accessing your notification settings by logging into your account (if applicable); or
Contacting us at support@americanoperator.com.

Please note: Opting out will not unsubscribe you from important communications regarding your account, security-related matters, or notices required by applicable law.

6. Data Retention and Disposal

American Operator retains Personal Information in accordance with applicable law and our business needs. In general, we retain Personal Information for as long as reasonably necessary to: fulfill the purposes described in this Privacy Policy; comply with legal, tax, accounting, or regulatory requirements; and resolve disputes and enforce our agreements.

We will take reasonable steps to delete, de-identify, or anonymize Personal Information when it is no longer needed for these purposes, subject to any legal or regulatory recordkeeping obligations.

7. Cookies and Other Identifiers

We use cookies and similar technologies throughout our websites and web applications to:

Track Visitor interactions;
Personalize your experience on the Platform; and
Promote and improve our Platform.

Cookies are small files stored on a computer designed to hold small amounts of data specific to a Visitor and the websites or applications to help tailor that Visitor’s experience. You may be able to control or limit cookies through your browser settings; however, disabling cookies may impact certain features or functionality of the Platform.

9. General Data Protection Regulation and International Transfers

American Operator is based in the United States and your Personal Information may be collected and processed in the United States. American Operator has affiliates outside of the United States. If transferred, data is transferred subject to appropriate transfer mechanisms and safeguards.

If you are outside the United States, you use or access the Platform solely at your own risk and initiative. The Platform is controlled and operated from facilities within the United States.
American Operator makes no representations that the Platform is appropriate or available for use in any other jurisdictions.
Accessing the Platform is prohibited from territories where the content on the Platform is prohibited.

WE MAKE NO REPRESENTATION THAT THE CONTENT ON THE PLATFORM CONFORMS TO YOUR LOCAL LAWS, AND IF YOU ARE ACCESSING THE PLATFORM FROM A LOCATION OUTSIDE THE UNITED STATES, YOU ALONE ARE RESPONSIBLE FOR COMPLIANCE WITH YOUR LOCAL LAWS.

11. California Residents

Privacy Rights of California Residents. If you are a California resident, under the California Consumer Privacy Act (“CCPA“) and its successor, the California Privacy Rights Act (“CPRA“) you have additional rights regarding your Personal Information. Subject to certain limitations, your rights include:

Right to Know. You have the right to know and see what Personal Information American Operator has collected about you over the preceding 12 months, including:
- the categories of Personal Information American Operator has collected about you;
- the categories of sources from which Personal Information is collected;
- the purposes for collecting your Personal Information in accordance with this policy;
- the commercial purposes for collecting your Personal Information;
- the categories of third parties with whom American Operator has shared your Personal Information; and
- the specific pieces of Personal Information American Operator has collected about you.
Right to Deletion. You have the right to request that American Operator delete the Personal Information we have collected from you. However, there are exceptions under which we may retain your Personal Information and where we are not required to delete your Personal Information.
Right to Correction. You have the right to request that American Operator correct the Personal Information collected from you.
Right to Portability. You may have the right to request that we transfer certain Personal Information to another entity, subject to certain exceptions.
Right to Opt-Out of the Sale or Sharing of Personal Information. We do not “sell” or “share” Personal Information as defined by the CCPA or the CPRA. You have the right to opt out of any processing for cross-context behavioral advertising, targeted advertising or profiling in connection with decisions that produce legal or similarly significant effects, if applicable.
Right to Opt-Out of Automated Decision-Making. You have the right to opt out of automated decision-making, if applicable.
Right to Opt-Out of the Use and Disclosure of Sensitive Personal Information. If we collect sensitive Personal Information, we will restrict its use to what is necessary to allow for your experience on the Platform.
Right to be free from discrimination. You can be free from discrimination for exercising your rights under the CCPA/CPRA.

If you are a California resident and would like to exercise your rights in accordance with the CCPA, you may contact American Operator via email at support@americanoperator.com. We will process a verified California consumer privacy request within 45 days of receiving the request. If we require more time, we will inform you of the reason and extension period in writing. Please note that requests are subject to appropriate verification before processing.

11. Your Privacy Preferences

American Operator may provide you the opportunity to exercise certain preferences with respect to your Personal Information, such as accessing, updating, deleting, and exporting Personal Information, by logging into your account profile or by making a request to: support@americanoperator.com. American Operator may, in its discretion, process such requests as a courtesy, subject to appropriate prior verification.

12. Children’s Data

American Operator recognizes the sensitivity of Personal Information concerning children under the age of majority (“Minors”). Our Platform and any potential offerings on the Platform is not marketed to Minors and we do not knowingly solicit or collect Personal Information from Minors. If you believe that a Minor has created an account or disclosed Personal Information to us, please notify us immediately at support@americanoperator.com.

13. Information Security

We take reasonable measures to protect our systems from harm and to safeguard the confidentiality, integrity, and availability of your Personal Information. Our efforts include implementing appropriate physical, technical, and administrative controls to ensure a level of security commensurate with the risk, in particular, to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed.

14. Breach Notification

If your Personal Information is the subject of a data breach under applicable law or regulation, we will take appropriate action, including providing you with notice, as such law or regulations may require.

15. General Inquiries and Updates

For inquiries about this Privacy Policy, or to make a request or file a privacy complaint, please contact us at support@americanoperator.com or at:

American Operator LLC
Attn William Fry
13740 N Highway 183 Ste L2
Austin, TX 78750

This Privacy Policy may be updated from time-to-time, so please check back regularly for updates.

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