Allocate LLC Privacy Policy

Effective date: October 9, 2026

1. Introduction and Scope

Allocate LLC ("Allocate," "we," "us," or "our") is a limited liability company organized under the laws of the Commonwealth of Virginia. This Privacy Policy explains how we collect, use, share, and protect personal information when you interact with us.

This Privacy Policy applies to:

• Our primary website, allocateconsult.xyz, and any other websites, subdomains, or landing pages we operate (the "Websites")

• Checkout, order, and payment pages we operate on third-party platforms, including SamCart (the "Checkout Pages")

• Content, business profiles, and storefronts we maintain on social media and content platforms, including Instagram (the "Platform Pages")

• Email, text, and other communications between you and Allocate

• Consulting, advisory, coaching, and digital products or services we provide (the "Services")

Together, the Websites, Checkout Pages, Platform Pages, and Services are referred to as the "Offerings." By accessing or using any of the Offerings, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Offerings.

This Privacy Policy should be read together with our Terms and Conditions, which govern your use of the Offerings.

2. Information We Collect

We collect information in three ways: information you give us, information collected automatically, and information we receive from third parties.

Information you provide to us

• Contact information, such as your name, email address, phone number, mailing address, and company name

• Account and order information, such as the products or services you purchase, order history, and preferences

• Payment information, such as billing name, billing address, and payment method details. Full payment card numbers are collected and processed by our payment processors and checkout providers (such as SamCart and its payment partners) and are not stored on our own systems.

• Communications, such as messages you send us by email, contact forms, direct messages on social platforms, scheduling tools, or during consultations and coaching sessions

• Business and professional information you share with us while receiving the Services, such as information about your company, projects, goals, and challenges

• Marketing preferences, such as newsletter sign-ups, email subscription choices, and opt-ins where you provide your name and email address in exchange for a free resource, guide, training, or webinar

• Survey, testimonial, and feedback responses

Information collected automatically

When you visit the Websites, Checkout Pages, or Platform Pages, we and our service providers may automatically collect:

• Device and browser information, such as IP address, browser type, operating system, device identifiers, and language settings

• Usage information, such as pages viewed, links clicked, time spent, referring URLs, and the date and time of your visit

• Location information, such as the approximate location derived from your IP address

• Cookie and tracking data, as described in Section 5

Information from third parties

We may receive information about you from:

• Checkout and payment platforms (such as SamCart, Stripe, or PayPal), which share order confirmations, payment status, and limited billing details with us

• Social media and content platforms (such as Instagram and Meta), which may share your public profile information, engagement with our content, and messages you send us through those platforms, subject to their own privacy policies and your settings

• Email, scheduling, and analytics providers we use to run the business

• Referrals and business partners who introduce you to our Services

We do not knowingly collect sensitive personal data (such as government identification numbers, health information, or precise geolocation) unless you choose to provide it to us in the course of receiving the Services.

3. How We Use Your Information

We use the information we collect to operate the business, deliver what you purchase, and communicate with you. Specifically, we use personal information to:

• Process transactions, including taking orders, processing payments, issuing receipts, and handling refunds

• Deliver the Services and digital products, including scheduling consultations, providing coaching and advisory services, and giving you access to purchased content

• Communicate with you about your orders, account, and inquiries, and to provide customer support

• Send marketing communications, such as newsletters, offers, and updates about new products or services, where permitted by law and subject to your opt-out rights (see Section 7). This includes uploading your email address to advertising platforms such as Meta and Google, in hashed form, to build custom or lookalike audiences so we can show ads to you or to people with similar interests

• Personalize and improve the Offerings, including understanding which content and pages are most useful

• Analyze usage and performance of the Websites, Checkout Pages, and Platform Pages

• Detect and prevent fraud, abuse, and security incidents, and protect the rights, property, and safety of Allocate, our customers, and others

• Comply with legal obligations, including tax, accounting, and recordkeeping requirements

• Enforce our Terms and Conditions and other agreements

• Any other purpose that we describe to you at the time of collection or to which you consent

Testimonials and public content. If you post a comment, review, or message on our Platform Pages or other public forums, we may reference or repost that content in our marketing. We will not use your name, likeness, or statements as a formal testimonial, case study, or endorsement without first obtaining your written consent in a separate release.

Group programs and public settings. Information you choose to share in group coaching sessions, community spaces, live trainings, webinars, comments, or social media posts may be seen, collected, and used by other participants or the public. We are not responsible for how others use information you voluntarily make public, so please share thoughtfully in those settings.

We may also aggregate or de-identify personal information so that it can no longer reasonably be used to identify you. We may use and share de-identified information for any lawful purpose.

4. How We Share Your Information

We do not sell your personal information, and we do not share it with third parties for their own marketing purposes. We share personal information only in the following circumstances:

• Service providers. We share information with vendors that help us run the business, including checkout and e-commerce platforms (such as SamCart), payment processors (such as Stripe and PayPal), website hosting and domain providers, email and marketing platforms, scheduling tools, customer relationship management tools, video conferencing providers, cloud storage providers, and analytics providers. These providers may use your information only to perform services for us.

• Social media and content platforms. When you interact with our Platform Pages on Instagram or other platforms, the platform operator receives information about that interaction under its own privacy policy.

• Professional advisors. We may share information with our attorneys, accountants, bookkeepers, and insurers as needed to operate the business.

• Legal requirements. We may disclose information when required by law, subpoena, court order, or governmental request, or when we believe disclosure is necessary to protect our rights, property, or safety or that of others, to investigate fraud, or to respond to a lawful request.

• Business transfers. If Allocate is involved in a merger, acquisition, financing, reorganization, or sale of some or all of its assets, your information may be transferred as part of that transaction. We will take reasonable steps to ensure the recipient honors this Privacy Policy.

• With your consent. We may share information for any other purpose with your direction or consent, such as when you ask us to provide a testimonial or introduce you to a partner.

Where we use advertising cookies or pixels from platforms such as Meta or Google (see Section 5), those platforms may receive information about your visits that applicable U.S. state privacy laws treat as "sharing" or "targeted advertising." You can opt out as described in Sections 5 and 9.

5. Cookies and Tracking Technologies

We and our service providers use cookies, pixels, web beacons, local storage, and similar technologies on the Websites and Checkout Pages. These technologies help the pages function, remember your preferences, measure performance, and support marketing.

The types we may use include:

• Strictly necessary cookies, which are required for the Websites and Checkout Pages to work, such as keeping items in your cart and completing a purchase

• Functional cookies, which remember your settings and preferences

• Analytics cookies, such as those from Google Analytics or built-in platform analytics, which help us understand how visitors use our pages

• Advertising and social media pixels, such as the Meta (Facebook and Instagram) Pixel or Google Ads tags, which measure the effectiveness of our ads and may be used to show you relevant ads on other platforms

Third-party platforms that host our Checkout Pages and Platform Pages (such as SamCart and Instagram) set their own cookies and trackers, which are governed by their privacy policies.

Managing cookies. Most browsers let you block or delete cookies through their settings. Blocking some cookies may affect how the Websites and Checkout Pages function. To opt out of interest-based advertising, you can visit the Digital Advertising Alliance or the Network Advertising Initiative, adjust your ad preferences in your Meta and Google account settings, or use a browser-based opt-out signal such as Global Privacy Control, which we honor where required by law.

6. Third-Party Platforms and Links

Many of our Checkout Pages and Platform Pages are hosted on platforms we do not own or control. When you use those pages, the platform operator independently collects and processes your information under its own terms and privacy policy. We encourage you to review them:

• SamCart: samcart.com/privacy-policy

• Instagram and Meta: privacy policy

• Stripe: stripe.com/privacy

• PayPal: paypal.com/privacy

The Offerings may also contain links to other websites, tools, or resources that we do not operate. We are not responsible for the privacy practices or content of those third parties, and this Privacy Policy does not apply to them.

7. Marketing Communications and Your Choices

If you make a purchase, sign up for our newsletter, or otherwise give us your email address, we may send you marketing emails about our products, services, and content. You can opt out at any time by:

• Clicking the "unsubscribe" link at the bottom of any marketing email

• Emailing us at manager@allocate.xyz with "Unsubscribe" in the subject line

We comply with the CAN-SPAM Act: every marketing email identifies Allocate as the sender, includes a working unsubscribe mechanism, and uses accurate subject lines. We honor unsubscribe requests within 10 business days. Opting out of marketing emails does not stop transactional or service messages, such as order confirmations, receipts, scheduling notices, or important updates about the Services you have purchased.

SMS and text messages. If you voluntarily provide your mobile number and opt in, you may receive text messages from Allocate LLC, including transactional messages (such as order confirmations and appointment reminders) and promotional messages (such as new offers or content). Message frequency varies. Message and data rates may apply. Consent to receive text messages is not a condition of any purchase. You can opt out at any time by replying STOP to any message, or get assistance by replying HELP. Mobile phone numbers and text-messaging opt-in data will not be shared with third parties or affiliates for their marketing or promotional purposes.

8. Data Retention and Security

Retention. We keep personal information only as long as reasonably necessary for the purposes described in this Privacy Policy. In general:

• Order, payment, and invoicing records are retained for at least seven years to meet tax and accounting requirements

• Client engagement records and communications are retained for the duration of the engagement and a reasonable period afterward to handle follow-up questions, disputes, or legal claims

• Marketing contact information is retained until you unsubscribe or we determine the information is no longer needed

• Website analytics data is retained according to the settings of the analytics provider

When information is no longer needed, we delete it or de-identify it, subject to any legal hold or retention obligation.

Security. We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including using reputable service providers, limiting access to those who need it, and relying on encrypted connections (HTTPS) for the Websites and Checkout Pages. Payment card data is handled by PCI-compliant payment processors and is not stored by us.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we learn of a data breach that affects your personal information, we will notify you and any required regulators without unreasonable delay, in accordance with Virginia law and other applicable breach-notification laws. If you believe your interaction with us is no longer secure, contact us immediately at manager@allocate.xyz.

Accounts and passwords. Some Checkout Pages and digital products may give you a customer account or login. You are responsible for keeping your login credentials confidential and for all activity under your account. Notify us at manager@allocate.xyz right away if you believe your account has been accessed without authorization.

9. Your Privacy Rights

Depending on where you live, you may have legal rights regarding your personal information. Regardless of whether a particular law applies to Allocate, we extend the following rights to everyone we collect personal information from:

• Access. Confirm whether we are processing your personal information and obtain a copy of it.

• Correction. Ask us to correct inaccurate or incomplete personal information.

• Deletion. Ask us to delete personal information we hold about you, subject to legal retention obligations.

• Portability. Receive a copy of the personal information you provided to us in a portable, readily usable format.

• Opt out. Opt out of targeted advertising, the sale of personal information, and profiling used in decisions that produce legal or similarly significant effects. As stated in Section 4, we do not sell personal information.

• Non-discrimination. We will not deny you goods or services, charge different prices, or provide a different level of service because you exercised your privacy rights.

How to exercise your rights

Send a request to manager@allocate.xyz with the subject line "Privacy Request." Tell us which right you are exercising and the email address associated with your account or purchase. We may need to verify your identity before acting on a request, and we may ask for additional information to do so.

We will respond within 45 days of receiving a verifiable request. If we need more time, we will let you know and may extend the response period by an additional 45 days where permitted by law. You may submit a request through an authorized agent, in which case we may require proof that the agent is authorized to act on your behalf.

Virginia residents

Virginia residents have the rights described above under the Virginia Consumer Data Protection Act (VCDPA), Va. Code § 59.1-575 et seq. If we deny your request, you may appeal our decision within a reasonable period by replying to our response or emailing manager@allocate.xyz with the subject line "Privacy Request Appeal." We will respond to your appeal within 60 days. If your appeal is denied, you may contact the Virginia Attorney General at virginia.gov to submit a complaint.

Residents of other U.S. states

Residents of California, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy laws may have similar rights, including the right to appeal a denied request. California residents also have the right to know the categories of personal information we collect and the categories of third parties with whom we share it (described in Sections 2 and 4), and the right to limit the use of sensitive personal information. We honor Global Privacy Control signals as a valid opt-out request where required.

Residents of the European Economic Area, United Kingdom, and Switzerland

If you are located in these regions, we process your personal data on the following legal bases: performance of a contract (to deliver what you purchase), our legitimate interests (to operate, secure, and improve the business), your consent (for marketing and non-essential cookies), and compliance with legal obligations. In addition to the rights above, you may object to processing based on legitimate interests, withdraw consent at any time, and lodge a complaint with your local data protection authority.

10. Children's Privacy, Do Not Track, and International Transfers

Children. The Offerings are intended for adults and businesses. We do not knowingly collect personal information from anyone under 18, and we do not knowingly collect information from children under 13 in a manner subject to the Children's Online Privacy Protection Act (COPPA). If you believe a child has provided us with personal information, contact us at manager@allocate.xyz and we will delete it.

Do Not Track. Some browsers send a "Do Not Track" signal. Because there is no common industry standard for responding to these signals, we do not currently respond to them. We do honor Global Privacy Control signals where required by law, as described in Section 9.

International transfers. Allocate is based in the United States, and our service providers are primarily located in the United States. If you access the Offerings from outside the United States, your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your country. By using the Offerings, you consent to this transfer. Where required, we rely on appropriate safeguards, such as standard contractual clauses, for transfers from the European Economic Area, United Kingdom, or Switzerland.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Offerings, or applicable law. When we do, we will revise the effective date at the top of this page. If the changes are material, we will provide additional notice, such as by posting a notice on the Websites or emailing customers. Your continued use of the Offerings after the effective date of a revised policy means you accept the changes.

12. Contact Us

If you have questions, concerns, or requests about this Privacy Policy or our handling of your personal information, contact us at:

Allocate LLC

Email: manager@allocate.xyz

Website: allocateconsult.xyz

Please include "Privacy" in the subject line so we can route your message promptly.

This Privacy Policy is governed by the laws of the Commonwealth of Virginia, without regard to its conflict of law principles. It is provided for informational purposes and does not create a contractual relationship beyond the rights and obligations described in our Terms and Conditions.