Privacy Policy

Last Updated: September 26, 2026

This Privacy Policy describes how CleverMind Entertainment (“CleverMind Entertainment,” “CME,” “we,” “us,” or “our”) collects, uses, discloses, retains, and otherwise processes information in connection with our websites, online and offline services, emails, communications, and other services that link to or reference this Privacy Policy (collectively, the “Sites” or “Services”).

Information collected through the Sites or Services may be processed by CME and, where appropriate, by service providers, contractors, business partners, artists, clients, representatives, affiliates, and other parties acting on our behalf or as otherwise described in this Privacy Policy.

When we use the terms “personal information” or “personal data,” we generally mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual, household, or device, as defined under applicable law.

We encourage you to review this Privacy Policy in its entirety.

1. Information We Collect

The information we collect depends on how you interact with CME and our Sites or Services.

Information You Provide Directly

We may collect information that you voluntarily provide to us, including:

❖ Contact information, such as your name, email address, telephone number, mailing address, or other contact information you choose to provide;

❖  Newsletter and communication preferences, such as your email address, subscription choices, and marketing preferences;

❖  Communications and inquiries, including information you provide when you contact CME, request information, submit an inquiry, request a consultation, or otherwise communicate with us;

❖  Business and professional information, such as your company, brand, artist, label, organization, professional role, or other information you choose to provide in connection with an inquiry, project, or business relationship;

❖  Project and creative materials, including descriptions, documents, photographs, videos, audio, music, written materials, creative assets, or other content you voluntarily provide in connection with a project, inquiry, or Service; and

❖  Other information you voluntarily provide in connection with your interaction with CME.

Please do not submit Social Security numbers, government-issued identification numbers, financial-account credentials, health information, or other highly sensitive information through general website forms or communications unless CME specifically requests such information for a legitimate purpose.

Information Collected Automatically

When you visit or interact with our Sites, CME and certain service providers may automatically collect limited technical and usage information, which may include:

❖ Internet Protocol (“IP”) address;

❖ browser type and version;

❖ operating system;

❖ device type or device information;

❖ referring and exit pages;

❖ pages or content viewed;

❖ links or features used;

❖ dates and times of visits;

❖ approximate location derived from an IP address;

❖ cookie or similar identifiers; and

❖ other technical information concerning your interaction with or performance of the Sites.

The specific information collected depends on the technologies and service providers used by the applicable Site.

Deidentified, Aggregated, Hashed, and Pseudonymized Information

We may aggregate, hash, pseudonymize, or deidentify information where appropriate.

Information that has been pseudonymized or hashed may continue to constitute personal information under applicable law if it can reasonably be linked to an individual, household, or device.

Where information has been deidentified within the meaning of applicable law, we will maintain and use it in deidentified form and will not attempt to reidentify it except as permitted or required by law.

2. Sources of Personal Information

We may collect personal information from:

❖ you directly;

❖ your browser or device when you interact with our Sites;

❖ service providers that support our website, communications, security, hosting, or related business operations;

❖ artists, clients, representatives, business partners, or other parties where information is provided in connection with a CME project, campaign, Service, or business relationship;

❖ publicly available sources, where appropriate; and

❖ other sources when you direct or authorize the disclosure of information to us.

We may combine information received from different sources where permitted by applicable law.

3. How We Use Personal Information

We may use personal information for purposes including:

❖ providing, operating, maintaining, and improving our Sites and Services;

❖ responding to inquiries, requests, consultations, questions, or communications;

❖ providing requested information regarding CME, our Services, artists, projects, content, or other offerings;

❖ administering newsletter subscriptions and communication preferences;

❖ sending marketing communications where permitted by law;

❖ managing client, artist, partner, or business relationships;

❖ performing or administering projects and Services;

❖ communicating regarding projects, Services, agreements, or business matters;

❖ personalizing and improving Site experiences;

❖ understanding how visitors use and interact with our Sites;

❖ conducting research, measurement, and analytics;

❖ maintaining the security, functionality, and integrity of our Sites and systems;

❖ identifying, investigating, preventing, and responding to fraud, misuse, security incidents, or other potentially unlawful activity;

❖ enforcing applicable agreements and protecting our legal rights;

❖ maintaining appropriate business and operational records;

❖ complying with applicable legal, regulatory, contractual, accounting, or reporting obligations;

❖ establishing, exercising, or defending legal claims; and

❖ carrying out another purpose disclosed to you at the time information is collected or with your consent.

We will not use personal information for materially different purposes without providing any notice or obtaining any consent required by applicable law.

4. Cookies and Similar Technologies

CME and certain service providers may use cookies and similar technologies in connection with our Sites.

Cookies are small files or pieces of information stored on or accessed through a browser or device. Depending on how the applicable Site is configured, cookies and similar technologies may be used to:

❖ provide essential website functionality;

❖ remember preferences;

❖ improve security;

❖ maintain website performance;

❖ understand how visitors use the Sites;

❖ diagnose technical problems;

❖ measure engagement or performance; and

❖ support other website functions.

Our Sites may also use technologies such as pixels, web beacons, local storage, embedded scripts, or similar tools where applicable.

You can manage certain cookie preferences through the Manage Cookies or similar cookie-control mechanism made available on the applicable Site.

Please review our Cookie Policy for additional information regarding cookies and similar technologies used on our Sites.

5. Analytics and Advertising Technologies

CME may use service providers or technologies that help us understand Site performance and how visitors interact with our Sites.

Depending on the technologies enabled on a Site, certain disclosures of identifiers, device information, or internet activity to advertising or analytics providers may be considered a “sale,” “sharing,” or use for “targeted advertising” under certain privacy laws, even where no money is exchanged.

CME does not sell personal information to third parties for monetary compensation.

Where applicable law provides an individual with the right to opt out of a sale, sharing, or targeted advertising, CME will provide or honor the applicable method for exercising that choice as required by law.

6. Global Privacy Control and Browser Signals

Certain browsers or browser extensions allow users to transmit privacy preference signals.

Where required by applicable law, CME will recognize and process qualifying opt-out preference signals, including Global Privacy Control (“GPC”), in accordance with applicable legal requirements.

Traditional Do Not Track signals are different from legally recognized opt-out preference signals. Because there is no single universally adopted standard governing traditional Do Not Track signals, our Sites may not respond to those signals.

7. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients where reasonably necessary.

Service Providers and Contractors

We may disclose information to companies and individuals that perform services on our behalf, including providers that support:

❖ website hosting and infrastructure;

❖ website administration and technical services;

❖ cybersecurity and fraud prevention;

❖ email and communications;

❖ data storage;

❖ analytics, where applicable;

❖ customer or client support;

❖ marketing-related services, where applicable;

❖ professional services; and

❖ other business operations.

These parties may process information as reasonably necessary to provide services to CME, subject to applicable contractual and legal requirements.

Artists, Clients, Partners, and Representatives

Where appropriate to a particular project, request, campaign, or Service, we may disclose relevant information to CME artists, clients, representatives, business partners, or other parties involved in delivering the applicable Service.

Legal and Safety Purposes

We may disclose personal information where we reasonably believe disclosure is necessary to:

❖ comply with applicable law, regulation, court order, subpoena, or other legal process;

❖ respond to lawful governmental or regulatory requests;

❖ investigate or prevent fraud, abuse, or unlawful conduct;

❖ enforce applicable agreements;

❖ protect the rights, property, safety, or security of CME, our users, clients, artists, partners, or others; or

❖ establish, exercise, or defend legal claims.

Business Transactions

Personal information may be transferred or disclosed in connection with an actual or proposed merger, acquisition, financing, restructuring, reorganization, sale of assets, bankruptcy, or other business transaction involving all or part of CME.

At Your Direction

We may disclose information to another party when you direct or authorize us to do so or otherwise provide valid consent.

8. Marketing Communications and Your Choices

You may choose whether to receive marketing communications from CME.

Email Communications

You may unsubscribe from marketing emails by following the unsubscribe or preference-management instructions contained in the applicable communication.

If you unsubscribe from marketing communications, CME may still send communications that are necessary for an existing business relationship, requested Service, security matter, or other non-marketing purpose.

Cookie Preferences

Where available, you may adjust certain cookie or tracking preferences through the Manage Cookies or similar functionality provided on the applicable Site.

Changing your cookie preferences may affect certain Site features or functionality.

9. Retention of Personal Information

We retain personal information only for as long as reasonably necessary and proportionate to fulfill the purposes for which it was collected or otherwise processed.

Factors we may consider when determining retention periods include:

❖ the nature of the information;

❖ the purpose for which it was collected;

❖ the duration of our relationship with you;

❖ whether the information is necessary to provide a requested Service;

❖ contractual or legitimate business requirements;

❖ applicable legal, regulatory, tax, accounting, or reporting requirements;

❖ applicable statutes of limitation;

❖ fraud-prevention and security needs; and

❖ whether retention is reasonably necessary to establish, exercise, or defend legal rights.

Where applicable law requires more specific retention disclosures, CME will provide them as required.

10. Information Security

CME maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, loss, or misuse.

However, no method of transmission over the internet, electronic storage system, or security measure can guarantee absolute security.

If you believe information you provided to CME may no longer be secure, please contact us through our Contact page.

11. Third-Party Websites and Services

Our Sites may contain links to or embedded content from websites, applications, platforms, or services operated by third parties.

CME does not control the privacy or security practices of independent third parties, and this Privacy Policy does not apply to information collected directly by those parties.

We encourage you to review the privacy notices of any third-party website, application, platform, or service you use.

12. Processing in the United States and Other Locations

CME is based in the United States.

Information collected through our Sites or Services may be processed or stored in the United States or other jurisdictions in which CME or our service providers operate.

Privacy and data-protection laws in those jurisdictions may differ from those in the jurisdiction where you reside.

Where applicable law requires particular safeguards for transfers of personal information, CME will implement appropriate measures as required.

13. Children’s Privacy

Our Sites and Services are intended for a general audience and are not directed to children under 13.

CME does not knowingly collect personal information from children under 13 in circumstances requiring verifiable parental consent without obtaining such consent.

If we learn that personal information from a child under 13 has been collected in violation of applicable law, we will take reasonable steps to delete or otherwise appropriately address that information.

CME does not knowingly sell or share for cross-context behavioral advertising the personal information of consumers under 16 without any affirmative authorization required by applicable law.

14. U.S. State Privacy Rights

Residents of certain U.S. states may have additional rights concerning their personal information.

Depending on your jurisdiction, whether the applicable law applies to CME, and applicable exceptions or limitations, those rights may include the right to:

❖ confirm whether CME processes your personal information;

❖ request access to personal information maintained about you;

❖ obtain a portable copy of certain personal information;

❖ request correction of inaccurate personal information;

❖ request deletion of personal information;

❖ opt out of certain sales of personal information;

❖ opt out of targeted advertising;

❖ opt out of certain profiling or automated processing producing legal or similarly significant effects;

❖ withdraw consent where applicable;

❖ obtain information regarding certain third parties to whom information has been disclosed, where required;

❖ appeal certain decisions concerning a privacy-rights request, where provided by applicable law; and

❖ exercise applicable privacy rights without unlawful discrimination or retaliation.

These rights are subject to the definitions, applicability thresholds, exceptions, limitations, and eligibility requirements of applicable law.

Exercising a Privacy Right

If an applicable privacy law provides you with a right concerning your personal information, you may submit your request through the Contact page available on our Site.

Please identify the communication as a “Privacy Request” and provide enough information for us to understand the nature of your request.

You may also submit a written privacy-related request to:

ATTN: CleverMind Entertainment Privacy Office
CleverMind Entertainment
3104 E Camelback Rd
Unit #2769
Phoenix, AZ 85016

We may request information reasonably necessary to verify your identity and determine whether the request relates to personal information concerning you.

The nature of any verification process will depend on the type and sensitivity of the information, the right being exercised, and applicable law.

If applicable law requires CME to provide an additional designated request method, CME will make that method available as required.

Authorized Agents

Where permitted by applicable law, you may authorize another person to submit a privacy request on your behalf.

We may request documentation demonstrating the agent’s authority and may independently verify your identity or ask you to confirm the authorization, except where applicable law provides otherwise.

Appeals

Where applicable law provides a right to appeal a decision concerning a privacy request, you may submit an appeal through our Contact page and identify the communication as a “Privacy Request Appeal.”

15. California Privacy Notice

This California Privacy Notice supplements the remainder of this Privacy Policy and provides additional information for California residents.

Certain rights and requirements described in this section apply only to the extent CleverMind Entertainment is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act and applicable implementing regulations (collectively, the “CCPA”), or another applicable California privacy law.

Where applicable California law provides you with a right concerning your personal information, CME will honor that right as required by law.

California Consumer Rights

To the extent applicable, California residents may have the following rights:

Right to Know and Access. You may have the right to request information concerning personal information collected about you, including applicable categories of personal information, sources, purposes, categories of recipients, and specific pieces of personal information.

Right to Delete. You may have the right to request deletion of certain personal information, subject to applicable exceptions.

Right to Correct. You may have the right to request correction of inaccurate personal information maintained about you.

Right to Data Portability. Where applicable, you may have the right to receive certain personal information in a portable format.

Right to Opt Out of Sale or Sharing. If CME engages in activity constituting a sale or sharing of personal information under applicable California law, eligible consumers may have the right to opt out.

Right to Limit Certain Uses or Disclosures of Sensitive Personal Information. Where applicable, California law may provide a right to limit certain uses or disclosures of sensitive personal information.

Right to Non-Discrimination and Non-Retaliation. CME will not unlawfully discriminate or retaliate against an individual for exercising an applicable privacy right.

Personal Information Relevant to Our Public-Facing Sites

Depending on how you interact with our Sites, CME may collect the following categories of personal information:

CME will update these disclosures if its data practices materially change.

Sale and Sharing of Personal Information

CME does not sell personal information to third parties for monetary compensation.

Certain advertising or analytics technologies may result in disclosures that constitute a “sale” or “sharing” under California law even when no money is exchanged.

Where CME becomes subject to an applicable requirement concerning the sale or sharing of personal information, CME will provide any disclosure, opt-out mechanism, or other consumer choice required by law.

Personal Information Disclosed for Business Purposes

CME may disclose the following categories of personal information to service providers or contractors for legitimate business purposes:

❖  Identifiers, such as contact information voluntarily provided to CME; and

❖  Internet or Other Electronic Network Activity, to the extent such information is processed through website hosting, security, technical, communications, or similar services.

Such disclosures may support:

❖ operation and maintenance of the Sites;

❖ website hosting and infrastructure;

❖ website and information security;

❖ delivery of communications;

❖ administration of newsletter subscriptions;

❖ response to inquiries and requests;

❖ diagnosis of technical issues; and

❖ CME’s internal business operations.

A qualifying disclosure to a service provider or contractor for a business purpose does not necessarily constitute a sale or sharing of personal information.

Sensitive Personal Information

CME does not ask visitors to submit highly sensitive personal information through ordinary public-facing Site forms unless such information is specifically necessary for a legitimate purpose.

Please do not submit Social Security numbers, government-issued identification documents, financial-account credentials, health information, precise geolocation information, or similar sensitive information through a general inquiry or subscription form unless specifically requested by CME.

If CME collects sensitive personal information in circumstances governed by applicable California law, CME will provide any required disclosures and applicable rights concerning that information.

Consumers Under 16

CME does not knowingly sell or share personal information of consumers under 16 without any affirmative authorization required by applicable law.

Global Privacy Control

Where CME is legally required to provide a right to opt out of the sale or sharing of personal information, CME will recognize qualifying browser-based opt-out preference signals, including Global Privacy Control, as required by applicable law.

California Privacy Requests

Where applicable California law provides you with a privacy right, you may submit a request through our Contact page.

Please identify the communication as a “California Privacy Request” and describe the right you wish to exercise.

You may also write to:

ATTN: CleverMind Entertainment Privacy Office
CleverMind Entertainment
3104 E Camelback Rd
Unit #2769
Phoenix, AZ 85016

If applicable law requires CME to provide additional designated methods for submitting requests, CME will make those methods available as required.

Authorized Agents

Where provided by applicable California law, a consumer may designate an authorized agent to submit an eligible privacy request on the consumer’s behalf.

CME may request documentation demonstrating the agent’s authority and may independently verify the consumer’s identity or request confirmation of the authorization, except where applicable law provides otherwise.

California “Shine the Light”

California residents may have rights under California Civil Code § 1798.83 concerning certain disclosures of personal information to third parties for their own direct-marketing purposes.

Eligible requests may be submitted in writing to:

ATTN: CleverMind Entertainment Privacy Office
CleverMind Entertainment
3104 E Camelback Rd
Unit #2769
Phoenix, AZ 85016

Please identify the correspondence as a “California Shine the Light Request” and provide sufficient information for CME to identify and respond to your request.

16. Questions About This Privacy Policy

If you have questions or concerns regarding this Privacy Policy, CME’s privacy practices, or the handling of your personal information, you may contact us through the Contact page available on our Site.

You may also write to:

ATTN: CleverMind Entertainment Privacy Office
CleverMind Entertainment
3104 E Camelback Rd
Unit #2769
Phoenix, AZ 85016

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, technologies, Services, business operations, or legal obligations.

When we update this Privacy Policy, we will revise the Last Updated date at the top of the policy.

Where required by applicable law, we will provide additional notice regarding material changes and obtain consent where required.