Privacy Policy

01.

Scope and Application

This Privacy Policy applies to REACH Projects, Inc. ("REACH," "we," "our," or "us") and governs the collection, use, and disclosure of personal information obtained through our website located at https://reachprojects.co (the "Site") and through our services, including REACH Marketing, REACH Talent, and REACH Ventures (collectively, the "Services").

Talent and creators who have entered into a signed REACH Talent Terms & Conditions agreement are additionally subject to the terms of that agreement. To the extent any provision of this Privacy Policy conflicts with the REACH Talent Terms & Conditions, the Talent Terms & Conditions shall control with respect to the talent relationship.

BY ACCESSING OR USING THE SITE OR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, PLEASE DO NOT ACCESS OR USE THE SITE OR SERVICES.

02.

Information We Collect

We may collect the following categories of information when you interact with our Site or Services:

Personal Information

Information that identifies or could reasonably identify you as an individual, including:

• Contact details such as name, email address, phone number, and mailing address
• Social media usernames, handles, follower counts, engagement metrics, and profile information
• Demographic information such as age, gender, interests, and content categories
• Financial information including payment details, banking information, and tax identification numbers where required for compensation purposes
• Information you voluntarily submit through forms, inquiries, applications, or account registration
• Any other information you authorize us to collect ("Customer Data")

Non-Personal Information

We may also collect non-identifying information automatically when you visit our Site, including browser type, device type, IP address, pages visited, referring URLs, and time spent on pages. This information is used in aggregate to improve site performance and user experience and is not used to identify you individually.

03.

Talent and Creator Data

In connection with our talent management and influencer marketing services, REACH Projects collects and processes a category of information specific to creators, influencers, brand ambassadors, and other talent represented by or partnered with REACH. This may include:

• Social media performance data including reach, impressions, views, engagement rates, and audience demographics across platforms such as TikTok, Instagram, YouTube, and Snapchat
• Brand partnership history, campaign performance records, and deal terms
• Content deliverable records, posting schedules, and campaign reporting data
• Financial information including compensation rates, payment history, and tax documentation (e.g., W-9 forms and Social Security or EIN numbers) required for lawful payment processing
• Likeness, image, and biographical information used in talent representation and marketing materials
• Communications between talent and REACH personnel regarding campaigns, brand relationships, or contractual matters

This information is collected and retained in accordance with applicable law and any obligations set forth in the REACH Talent Terms & Conditions. Talent who wish to request deletion of their personal information following the conclusion of their relationship with REACH may submit a written request to the contact address in Section 15, subject to any retention rights reserved under the Talent Terms & Conditions and applicable law.

04.

User-Generated Content

As part of our Services, creators, talent, brands, and other parties may submit photographs, videos, written content, or other creative materials ("User-Generated Content" or "UGC") to REACH Projects for purposes including influencer marketing campaigns, portfolio materials, pitch decks, or internal reporting. REACH Projects stores and processes UGC solely in connection with the delivery of the Services for which it was submitted.

Any rights REACH Projects holds with respect to UGC — including any rights to reproduce, distribute, or publicly display content — are determined by the agreement, whether written or otherwise, between REACH and the submitting party at the time of submission. For talent represented by REACH, those rights are governed by the REACH Talent Terms & Conditions. For content submitted in connection with a marketing engagement, those rights are governed by the applicable project or campaign terms agreed upon between the parties. This Privacy Policy does not independently grant, expand, or modify any such rights.

05.

How We Use Your Information

REACH Projects uses the personal information we collect for the following purposes:

• To provide, operate, and improve our Services
• To manage talent relationships, campaign execution, and client reporting
• To process payments and fulfill tax and financial reporting obligations
• To communicate with you regarding inquiries, agreements, deliverables, or updates
• To personalize your experience with our Site and Services
• To conduct research and analysis to improve our offerings
• To detect, prevent, and address fraud, security incidents, or other harmful activity
• To comply with applicable legal obligations and regulatory requirements
• For any other purpose to which you provide your express consent

We will not use your personal information in a manner inconsistent with the purposes described in this Policy without prior notice or your consent.

06.

Disclosure of Information

REACH Projects does not sell your personal information. We may disclose your information to the following categories of recipients only to the extent necessary to fulfill the purposes described in this Policy:

• Brand and advertising clients for whom REACH executes campaigns, limited to the information necessary to fulfill campaign obligations
• Affiliates and subsidiaries within the REACH Projects corporate family
• Service providers and contractors who assist in operating our Site and Services, subject to binding confidentiality and data processing obligations
• Payment processors and financial institutions as necessary to process compensation and fulfill tax reporting obligations
• Professional advisors such as attorneys, accountants, and auditors, subject to applicable professional duties of confidentiality
• Law enforcement or regulatory authorities where required by applicable law, court order, or valid legal process
• Successor entities in connection with a merger, acquisition, reorganization, or sale of assets, subject to comparable privacy protections

07.

Data Security

REACH Projects implements reasonable and appropriate technical and organizational security measures designed to protect the personal information we collect and process against unauthorized access, disclosure, alteration, or destruction. These measures include access controls, encryption of sensitive data in transit, and internal data handling protocols.

Notwithstanding the foregoing, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your information using commercially acceptable means, we cannot guarantee its absolute security. In the event of a data breach that is reasonably likely to result in risk to your rights or interests, we will notify affected individuals in accordance with applicable law.

08.

Data Retention and Deletion

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, contractual, or reporting obligations. The applicable retention period will vary depending on the nature of the information and the context in which it was collected.

Talent, creators, and other individuals whose data is held by REACH Projects may submit a written request to have their personal information deleted following the conclusion of their relationship with REACH, subject to our right to retain information as required by law or legitimate business necessity. Deletion requests may be submitted to the contact address in Section 15. We will respond to verified deletion requests within forty-five (45) days, as required by California law.

09.

California Privacy Rights (CCPA / CPRA)

REACH Projects, Inc. is a California-based company and is subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA"). California residents have the following rights with respect to their personal information:

• Right to Know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the purposes for which it is used, and the categories of third parties with whom it is shared.
• Right to Delete. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions permitted by law.
• Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Opt Out. You have the right to opt out of the sale or sharing of your personal information. REACH Projects does not sell or share personal information as those terms are defined under the CCPA.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.
• Right to Limit Use of Sensitive Personal Information. To the extent we collect sensitive personal information as defined under the CPRA (such as financial information or precise geolocation data), you have the right to limit our use and disclosure of such information to purposes authorized by law.

To exercise any of the above rights, please submit a verifiable consumer request to us using the contact information in Section 15. We will respond to verified requests within forty-five (45) days, with the option to extend by an additional forty-five (45) days where reasonably necessary with prior notice.

10.

California Shine the Light

California Civil Code Section 1798.83, known as the "Shine the Light" law, permits California residents to request and obtain once per year, free of charge, information about any personal information disclosed to third parties for direct marketing purposes during the preceding calendar year. If applicable, this information would include a list of the categories of personal information shared and the names and addresses of all third parties with which we shared such information in the immediately preceding calendar year.

To make such a request, please contact us using the information provided in Section 15 and indicate "California Shine the Light Request" in the subject line or body of your message.

11.

Third-Party Links and Services

Our Site may contain links to third-party websites, social media platforms, or services that are not operated or controlled by REACH Projects. This Privacy Policy does not apply to those third-party sites. We have no responsibility or liability for the content or privacy practices of any third-party service, and we encourage you to review the applicable privacy policies of any third-party platforms you access, including but not limited to TikTok, Instagram, YouTube, and Snapchat.

12.

Children's Privacy

Our Site and Services are not directed to individuals under the age of 13, and we do not knowingly collect personal information from children under 13 years of age. Our campus-based programs are limited to enrolled college students who are at least 18 years of age. If we become aware that we have inadvertently collected personal information from a child under the age of 13 without verifiable parental consent, we will take prompt steps to delete such information from our records. If you believe we may have collected information from a child under 13, please contact us immediately at the address in Section 15.

13.

Governing Law

REACH Projects, Inc. is incorporated under the laws of the State of Delaware and maintains its principal place of business in the State of California. This Privacy Policy and any disputes arising hereunder shall be governed by and construed in accordance with the laws of the State of California, without regard to its conflict of law principles, and subject to applicable federal law including the California Consumer Privacy Act.

14.

Changes to This Policy

REACH Projects reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page. Your continued use of our Site or Services following the posting of any changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to remain informed about how we protect your information.

15.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our handling of your personal information — including CCPA requests, deletion requests, or Shine the Light inquiries — please contact us at: