Effective Date: June 1, 2025

Lucky 38 INC. dba Portfolio Builders Network (“PBN”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and protect your information.

1. Information We Collect

We may collect:

* Contact information (e.g., name, email, phone number)

* Payment information (via secure third-party processors)

* Investment-related information (e.g., accreditation status, suitability questionnaires)

* Site usage data (e.g., IP address, pages viewed)

2. How We Use Your Information

We use your information to:

* Provide and improve our services and communications

* Comply with legal and regulatory obligations

* Evaluate eligibility for specific investment opportunities

* Notify you of community updates and opportunities

3. Disclosure of Information

We may share your information with:

* Third-party service providers (e.g., payment processors, CRM platforms)

* Legal and regulatory authorities when required

* Investment sponsors for suitability/verification purposes (506(c))

We do not sell your personal information.

"No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties."

4. Data Security

We take reasonable technical and organizational measures to protect your data. However, no system is completely secure. Use of the Services is at your own risk.

5. Cookies & Tracking

Our website may use cookies and other tracking technologies to enhance your experience and analyze site traffic.

6. Your Rights

You may request to review, correct, or delete your personal information at any time by contacting us. You may also opt out of promotional emails via the unsubscribe link.

7. Third-Party Sites

Our platform may link to third-party websites. We are not responsible for the privacy practices of those sites.

8. Policy Updates

This policy may be updated from time to time. Continued use of the Services after changes constitutes acceptance of the revised policy.

9. Contact Us

10.

10 . SMS Messaging Consent

By registering for an account on Portfolio Builders Network, you expressly consent to receive SMS (text) messages from us to the mobile number provided during registration. These messages may include account alerts, welcome messages, security notifications, service updates, and event reminders.

Messaging frequency varies. Message and data rates may apply. You may opt out of receiving SMS messages at any time by replying STOP to any message.

Your phone number and messaging preferences are securely stored and managed in accordance with our Privacy Policy. We do not share your phone number with third parties for marketing purposes.

Email: [[email protected]](mailto:[email protected])

Phone: 832-628-4793