Privacy Policy

This privacy policy (the “Privacy Policy“) describes the types of Personal Information that MVI Marketing, LLC dba LattiSpec (“LattiSpec,” “we,” “us,” or “our“) may collect from all visitors and users of our Platform (“user,” “you,” or “your“) or that you may provide to us when accessing and using the LattiSpec Platform. It also describes our policies and procedures for the collection, use, maintenance, protection, and disclosure of your Personal Information when you access and use the Platform, and explains your privacy rights and the choices you may have regarding your Personal Information.

Please read this Privacy Policy carefully before accessing and using the Platform to understand our policies and procedures regarding your Personal Information and how we will treat it.

Capitalized terms not defined below have the meaning given to them in our Terms of Service.

Acceptance

By accessing and using our Platform, you agree to the collection and use of your Personal Information in accordance with this Privacy Policy. If you do not agree with our policies and procedures, please do not access or use the Platform.

Updates

We reserve the right to modify this Privacy Policy at any time by posting an updated Privacy Policy on the Platform. If we make changes, we will notify you by revising the date at the top of the policy. If we make any material changes, we may provide you with a notice on the Platform and, at our sole discretion, we may provide registered users with an email notification of those changes. You are responsible for regularly reviewing this Privacy Policy, and your continued use of the Platform after we make changes constitutes acceptance of the updated Privacy Policy. If any modification is unacceptable to you, you shall cease using the Platform. If you have any questions about this Privacy Policy or if you wish to exercise any of your rights under this Privacy Policy, you may contact us at compliance@lattispec.com.

1. Information We Collect

“Personal Information” means any information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, email address, records of products or services you have purchased, internet browsing history, geolocation data, and inferences from other Personal Information that could create a profile of your preferences and characteristics.

We collect Personal Information necessary to provide, operate, and improve the Platform. The types of information we collect depend on how you interact with the Platform and include information you provide, information collected automatically, and information received from third parties.

LattiSpec provides a platform that facilitates interactions between Buyers and Sellers. Personal Information shared between users through the Platform is provided directly by users and is controlled by the receiving party. LattiSpec does not control how users independently collect, use, store, or disclose Personal Information obtained through the Platform. Users act as independent controllers of such information and are solely responsible for ensuring their use complies with applicable laws.

Personal Information We Collect Directly From You

We may ask you to provide certain Personal Information necessary to provide the Platform, and you may also choose to provide additional Personal Information. We limit the Personal Information we collect to what is reasonably necessary to provide the Platform.

You may also provide us with information about you at the time of creating an account, providing Feedback, or requesting customer support, which may include the following:

• Contact Information: First and last name, email address, billing address, mailing address, profile picture, and telephone number.
• Business Information: Business name, address, telephone number, email address, website address, and profile information.
• Payment Information: If you purchase a Seller Subscription or another paid service from LattiSpec, our third-party Payment Processor may collect your payment card, bank account, billing, and related payment information. We may receive limited information concerning the payment, including your name, billing information, amount paid, payment status, and the date and time of the Subscription payment. LattiSpec does not receive or store complete payment card or bank account numbers.
• Account Information: Username and password, display name, account activity, and other files you record or upload to your account.
• Communication Information: Any content of any communications you send and/or receive through the Platform or through other communication, such as email, to or from us or with Buyers or Sellers through the Platform.
• Product Information and Content: Information, data, text, images, videos, files, comments, feedback, or other content uploaded, created, or made available through the Platform, including content you provide on behalf of others. Users are responsible for ensuring that any Personal Information collected through Product Information is collected and used in compliance with applicable laws and does not violate the rights of any third party.
• Promotional and Publicity Content: Information, interviews, testimonials, recordings, statements, images, videos, marketing materials, or other content submitted or created in connection with Promotional Services, featured content, spotlight articles, interviews, events, or other promotional activities.
• Customer Testimonials: Any customer testimonials and comments on our Platform, which you provide us with consent.
• Feedback and Support: Information you provide through our customer service helpdesk, including subjects, descriptions, request type, and attachments.

No Sensitive Personal Information: We do not intentionally collect sensitive Personal Information unless required to provide the Platform. Users should not upload or submit sensitive Personal Information unless necessary. Sensitive information includes information related to your finances, health, marital status, or any other information not required to provide the Platform. We will not ask for, and you should not provide us with, information regarding protected classifications, including: race, color, religion, national origin, gender identity, sexual orientation, marital status, medical condition, and disability information (as described under the appropriate state or federal law). Users should not provide sensitive Personal Information in Buyer Requests, Listings, communications, or Promotional Services unless reasonably necessary.

Information We Automatically Collect From You

When you access or use the Platform, we may automatically collect certain information, including:

• Usage and Interaction Information: Pages viewed, Listings accessed, features used, actions taken, timestamps, and related interaction data.
• Device and Technical Information: IP address, browser type, operating system, device identifiers, and network information.
• Geolocation Data: The approximate location determined from your IP address.
• Metadata: Information associated with Listings, Product Information, or other content, including access logs, versioning data, and interaction metadata.

This information helps us operate, secure, and improve the Platform and is not used for targeted advertising.

The information we automatically collect from you is statistical data and does not include Personal Information; however, we may retain it or associate it with Personal Information we collect in other ways to help us improve our Platform and deliver a better, more personalized service. We use these technologies for a number of purposes, including enabling you to use the Platform, facilitating the functioning of and your access to the Platform, better understanding how you navigate through the Platform, and detecting and preventing fraud.

Cookies

Cookies are small text files placed on your device that help us recognize your browser or device and support functionality such as account authentication, security, preferences, and analytics. We use Cookies for the following purposes:

• Strictly Necessary Cookies: Required to operate the Platform, maintain security, and enable core features.
• Functional Cookies: Used to remember settings and preferences to improve your experience.
• Analytics Cookies: Used to understand how users interact with the Platform so we can improve performance and usability.

You can control Cookies through your browser settings. Please note that disabling Cookies may affect the availability or functionality of certain features of the Platform.

Website Analytics

We use Google Analytics, a web analytics service provided by Google LLC, to help us understand how users use the Platform. Google Analytics uses Cookies and similar technologies to collect information such as pages visited, features used, interaction patterns, device information, and approximate location (based on IP address). We use Google Analytics solely for analytics and performance measurement, not for targeted advertising. Where required by law, we configure Google Analytics to anonymize IP addresses or apply other safeguards to limit the collection of Personal Information. You can access Google Analytics’ privacy policy here.

Marketplace Analytics and Related Data

We may use aggregated, anonymized, statistical, or de-identified information and Related Data (as defined in our Terms of Service) for purposes of operating, maintaining, improving, developing, supporting, marketing, and commercializing the Platform and related services, including creating analytics, benchmarking tools, pricing trends, market insights, industry reports, marketplace intelligence products, statistical analyses, and other commercial or business materials. Related Data does not include Personal Information and is not intended to reasonably identify any specific individual, company, transaction, or confidential business relationship. We may publish, distribute, license, disclose, or otherwise commercialize Related Data as described in our Terms of Service.

Advertising

We may use limited remarketing, but do not engage in cross-context behavioral advertising as defined under applicable law. Our third-party vendors and we use cookies to inform, optimize, and serve ads based on your past visits to our Platform. Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page. Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Personal Information We Collect from Third Parties

Some content or applications on the Platform are served by third parties, including our Payment Processor and content and application providers. These third parties may use cookies, web beacons, or other tracking technologies to collect information about you when you access or use our Platform. The information they collect may be associated with your Personal Information, and/or they may collect information related to your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-party tracking technologies or how they may be used. You should contact the responsible provider directly if you have questions about an advertisement or other targeted content. For more information about how to opt out of receiving targeted advertising from many providers, see the Network Advertising Initiative’s opt-out page and Google Ads setting page.

If you are a Buyer who contacts a Seller or submits an inquiry regarding a Listing through or responds to Listings on the Platform, your contact information is shared with the applicable Seller via the Platform. Sellers may receive your Personal Information contained in your Buyer profile and other information about you that you choose to share with them. The Personal Information you share with a Seller through the Platform is entirely between you and the applicable Seller, and you recognize that Sellers act as independent controllers of Personal Information they receive, and that we cannot control what the Seller does with any Personal Information you provide.

We may collect publicly available business information from company websites, business directories, trade publications, public records, social media profiles, and other public or third-party sources to create and maintain informational company listings. This information may include company names, business locations, websites, general business contact information, descriptions of products or services, and information publicly associated with company representatives. An informational listing does not indicate that the listed company or any representative has registered with, approved, endorsed, or otherwise affiliated itself with LattiSpec.

We may collect Personal Information about you from other sources, including: (i) Third-Party Services that you use to link or connect with our Platform, such as Facebook and Google; and (ii) service providers, advertising networks, and other third parties that, to the extent permitted by applicable law, who provide us with additional information about you.

The information we collect from Third-Party Services may include your username, account name, email address, phone number, business name, physical address, and other information used to connect such Third-Party Services with our Platform, in accordance with the authorization procedures determined by such Third-Party Services.

2. Uploading and Posting Personal Information on the Platform

You may provide Personal Information to be displayed in public areas or transmitted to other users or third parties, including through message boards, article comments, Promotional Services, featured content, interviews, and public marketplace activity. This Personal Information is posted and transmitted to others at your own risk. Once shared, it may be accessed, copied, or used by others beyond our control. While all users must abide by our Terms of Service, we cannot guarantee that their use of Personal Information that you provide directly to them or through the Platform will be handled in accordance with this Privacy Policy. Comments may be moderated by LattiSpec administrators and may be subject to approval before appearing on the Platform. We may remove a comment at any time at our discretion. You need to contact us if you want the Personal Information posted to the comments section removed.

3. How We Use Your Personal Information

We use Personal Information for the following purposes, depending on how you interact with the Platform:

• Platform Operations and Functionality: We use Personal Information to create and manage user accounts, provide access to the Platform and its features, enable creation, hosting, sharing, and management of Listings and Product Information, authenticate users and maintain account security, and personalize user preferences and settings.
• Communications: We may use Personal Information to respond to inquiries, support requests, and customer service communications, send transactional or service-related notices, such as account confirmations, updates, security alerts, and changes to our terms or policies, and communicate about features or functionality related to your use of the Platform.
• Promotional Services and Publicity: We may use Personal Information, testimonials, interviews, recordings, statements, profile information, company information, and other content provided in connection with Promotional Services to create, publish, distribute, promote, and archive marketing materials, featured content, interviews, spotlight articles, and related promotional materials.
• Informational Company Listings: We may use lawfully obtained public or third-party information to create, maintain, verify, update, and display informational listings for companies that have not registered with the Platform and to allow those companies to claim, correct, or request removal of their listings.
• Analytics and Platform Improvement: We use Personal Information to analyze usage trends and performance, monitor and improve the reliability, security, and functionality of the Platform, and develop new features and enhancements.
• Legal, Compliance, and Safety Purposes: We may use Personal Information to comply with applicable laws, regulations, and legal processes, enforce our Terms of Service and other applicable agreements, and detect, prevent, and respond to fraud, misuse, security incidents, or other harmful activity.
• Marketing Communications: Where permitted by law and subject to your preferences, we may use Personal Information to send communications about LattiSpec products, features, or updates. You may opt out of marketing communications at any time using the unsubscribe mechanism provided or by contacting us.

4. How We Share Your Personal Information

We may share Personal Information in the following circumstances, and only to the extent necessary to operate, provide, and support the Platform, and related features. Sellers and Buyers may independently determine how they use Personal Information obtained through the Platform and may act as independent controllers of such information.

• Service Providers: We may share Personal Information with third-party service providers that perform services on our behalf, such as hosting, infrastructure, analytics, customer support, payment processing, security, and communications. These service providers are authorized to use Personal Information only as necessary to perform services for us and are contractually obligated to protect the information that they receive or have access to.
• Sellers: If you submit a request to a Seller on the Platform, we may share relevant Personal Information with the applicable Seller as necessary to facilitate and complete the request. Such sharing is limited to what is reasonably necessary for the Seller to evaluate your request, and is subject to applicable confidentiality and security obligations.
• Buyers: If you post a Listing on the Platform, we may share relevant Personal Information with the applicable Buyer as necessary to facilitate communication with the Buyer. This may include contact information and other information associated with your account or the Listing. Such sharing is limited to what is reasonably necessary for the Buyer to communicate with you and is subject to applicable confidentiality and security obligations.
• Subscription Payments: We share limited Personal Information with our third-party Payment Processor (Stripe) to process subscription payments. Our Payment Processor acts as an independent service provider, and their collection and use of Personal Information is governed by its own privacy policies. LattiSpec does not control and is not responsible for the privacy practices of our Payment Processor, which are governed by their own privacy policies.
• Legal Requirements and Protection of Rights: We may disclose Personal Information if required to do so by law or if we believe in good faith that disclosure is necessary to comply with a legal obligation or lawful request, protect the rights, property, or safety of LattiSpec, our users, or others, investigate or prevent fraud, security issues, or misuse of the Platform, and enforce our Terms of Service or other applicable agreements.
• Business Transfers: If LattiSpec is involved in a merger, acquisition, reorganization, sale of assets, or similar transaction. Personal Information may be transferred as part of that transaction, subject to applicable confidentiality protections.
• With Your Consent: We may disclose your Personal Information for any other purpose with your consent.
• As Aggregated Information: We may disclose aggregated information about our users and information that does not identify any individual to our advertisers, business partners, or any other third party.

5. How We Secure Your Personal Information

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. These safeguards are appropriate to the nature of the information and the risks associated with its processing.

Access to Personal Information is limited to authorized personnel, service providers, and partners who require such access to perform their duties and who are subject to confidentiality and security obligations. We use industry-standard security technologies and procedures to help protect Personal Information and maintain the security of the Platform.

You are responsible for maintaining the confidentiality of any account credentials associated with your use of the Platform and for taking appropriate steps to protect your devices and accounts from unauthorized access.

Despite our efforts, no method of transmission over the Internet or method of electronic storage is completely secure. Accordingly, while we strive to protect Personal Information, we cannot guarantee its absolute security.

In the event of a security incident involving Personal Information, we will take reasonable steps to investigate and, where required, notify affected users and authorities.

If you have questions about the security of the Platform, please contact us at compliance@lattispec.com.

6. Retention of Your Personal Information

We retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide and operate the Platform, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods may vary depending on the nature of the information, how it is used, and applicable legal or contractual requirements. We may retain Personal Information as necessary to comply with legal obligations, including tax, accounting, and dispute resolution requirements. For example:

• Account information is retained while an account remains active and for a reasonable period thereafter;
• Information related to payments or other financial information may be retained as required for accounting, tax, and legal compliance.

When Personal Information is no longer needed for these purposes, we take reasonable steps to delete, anonymize, or securely dispose of it, unless retention is required or permitted by law.

Requests to delete Personal Information are handled in accordance with the Your Privacy Rights and Choices section of this Privacy Policy.

7. International Data Transfers

LattiSpec is based in the United States, and the Personal Information we collect may be processed, stored, and transferred in the United States or in other countries where LattiSpec or its service providers operate. Data protection and privacy laws in these jurisdictions may differ from those in your country of residence.

Where required by applicable law, we rely on appropriate safeguards to transfer Personal Information across borders, such as standard contractual clauses approved by relevant authorities or other lawful transfer mechanisms. We take reasonable measures to protect Personal Information and to ensure that it is treated securely and in accordance with this Privacy Policy, regardless of where it is processed.

By using the Platform, you acknowledge that your Personal Information may be transferred to and processed in jurisdictions outside your country of residence as described in this Privacy Policy.

8. Opting Out of Marketing Communications and Cookies

You may opt out of receiving marketing emails or newsletters from us at any time by clicking the “unsubscribe” link included in such emails, following the instructions provided in the communication, or by contacting us at compliance@lattispec.com. Please note that you may continue to receive transactional or service-related communications, such as account notifications, security alerts, or updates related to your use of the Platform.

You may control cookies through your browser settings, including by deleting existing cookies, setting your browser to refuse cookies, or alerting you when cookies are being sent. Please note that disabling or refusing cookies may limit the availability or functionality of certain Platform features.

For additional information about how we use cookies and analytics technologies, please see the Cookies and Analytics section above.

9. Third-Party Websites

We may provide links to third parties’ websites within the Platform, but this Privacy Policy does not apply when you access third-party websites directly from the Platform. Please note that we have no control or responsibility over their data collection, use, or disclosure practices. When you click on links that take you to external websites, you will be subject to their privacy policies. If you access and transmit information to third-party websites, you do so at your own risk. You should carefully review the privacy policy of any third-party website you visit before using it or disclosing your Personal Information to its provider.

10. Collection of Payment Information

Sellers who purchase a Subscription must pay the applicable Subscription Fees through our third-party Payment Processor. Payment information is collected and processed directly by the Payment Processor. LattiSpec does not receive or store complete payment card numbers or bank account details. We may receive limited information from the Payment Processor, including the Seller’s name, billing information, amount paid, payment status, payment method type, transaction identifier, and confirmation of successful or failed payments. We use this information to administer Subscriptions, maintain billing and accounting records, provide customer support, prevent fraud, and comply with applicable legal and tax obligations. The Payment Processor’s collection, use, and retention of Personal Information are governed by its own privacy policy and terms. LattiSpec does not process payments between Buyers and Sellers and does not receive information concerning payments independently exchanged between them.

11. Personal Information of Children Under 13

The Platform is not directed to children, and children under 13 are not permitted to create an account or otherwise use the Platform. If a user indicates during registration that they are under 13 years old, account creation will be blocked.

12. Supplemental Notice to California Residents

Californian users of the Platform may have additional rights afforded to them under California Privacy Laws (defined below).

Additional Definitions Applicable to California Privacy Laws:

“CCPA” or “California Consumer Privacy Act” means California Civil Code § 1798.100 et seq.

“Consumer,” “Business,” “Sell,” and “Service Provider” will have the meanings given to them in the CCPA.

California Consumer Privacy Act (CCPA)

Your Rights

If the processing of your Personal Information is subject to the CCPA, you have the right to:

• Request us to disclose the categories and specific pieces of Personal Information we collect, use, disclose, and sell;
• Know the categories of Personal Information that we collect and the purposes for which we collected or used such Personal Information and whether that information is sold or shared;
• Know the categories of sources from which the Personal Information was collected;
• Know the categories of third parties with whom we shared or to whom we sell your Personal Information;
• Know whether we collected or sold your Personal Information for business or commercial purposes;
• Request deletion of Personal Information we collected from you, subject to certain exceptions;
• Opt-out of the sale of their Personal Information; and
• Not receive discriminatory treatment by us for exercising their rights set out in the CCPA.

Categories of Personal Information Collected by Us

For information about the categories of Personal Information we may have collected from Platform visitors, users, and subscribers during the 12 months preceding the date this Privacy Policy was last updated, including the sources of such information, the purposes for collecting and using it, and the categories of third parties with whom it may be shared, please refer to the following sections of this Privacy Policy:

• Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information

For information about your rights with respect to your Personal Information, including how to access, correct, or delete such information, please see the section titled Your Privacy Rights and Choices.

Categories of Personal Information Disclosed for a Business Purpose

The following is a summary of the categories of Personal Information we have disclosed for a business or commercial purpose in the 12 months preceding the date this Privacy Policy was last modified.

Such categories of Personal Information may be collected, used, or disclosed for business and commercial purposes, including the following examples:

• To operate and improve our Platform;
• To provide you with our Platform, respond to your inquiries, and give you the necessary support;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA;
• For internal administrative and auditing purposes; and
• To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Do Not Sell My Personal Information

As a California consumer, you have the right to opt out of the sale of your Personal Information. To make such a request please contact us by email at compliance@lattispec.com.

In the past 12 months, we have not sold your Personal Information in exchange for monetary consideration as traditionally understood. However, we may use and disclose aggregated, anonymized, statistical, or de-identified information as described in this Privacy Policy.

California Minors

If you are a California resident under the age of 18, you may have the right under California Business and Professions Code Section 22581 to request the removal of content or information that you have publicly posted on the Platform.

Please note that this right applies only to content you personally posted and does not guarantee the complete or comprehensive removal of such content, as the law does not require removal in certain circumstances, including where the content is retained for legal, safety, or operational purposes.

Requests to remove content may be submitted using the contact information provided below. In some cases, we may require verification of your identity or may direct the request through a parent, legal guardian, or the applicable account holder, depending on how the Platform is accessed.

Do not Track Features

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. However, at this stage, there is no uniform technology standard for recognizing and implementing DNT signals. As such, we do not currently respond to or support DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

California’s Shine the Light Law

Under California’s Shine the Light Law, California Consumers may request the type of Personal Information we disclosed to third parties for their direct marketing purposes and a list of those third parties (if any). We have not disclosed Personal Information to third parties for direct marketing purposes.

To make any requests regarding your California Privacy Rights, please contact us by email at compliance@lattispec.com.

13. Supplemental Notice To Individuals That Reside In the European Economic Area

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, this section provides additional information about how we process Personal Information in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

Making a request in relation to your Personal Information

The GDPR gives EEA consumers various rights with respect to the Personal Information we collect, including the right to (subject to certain limitations):

Subject to applicable law, you may have the right to:

• access your Personal Information;
• request correction or deletion of your Personal Information;
• object to or restrict certain processing;
• request data portability; and
• withdraw consent where processing is based on consent.

You also have the right to lodge a complaint with your local data protection authority. To exercise your rights, please contact us using the information provided in this Privacy Policy.

Please note that we may ask you to verify your identity before responding to such requests. You will not have to pay a fee to access your Personal Information or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

Legal Bases for Processing

We process Personal Information only where we have a valid legal basis to do so. Depending on the context, our legal bases may include:

• Performance of a Contract: to provide the Platform and related features, including account management, providing and administering accounts and Platform features, processing Seller Subscription payments, and facilitating inquiries and communications between Buyers and Sellers.
• Legitimate Interests: to operate, secure, and improve the Platform; communicate with users; analyze usage; prevent fraud and misuse; and support our business operations, provided that such interests are not overridden by your rights and interests.
• Legal Obligations: to comply with applicable laws, regulations, lawful requests, and enforcement obligations.
• Consent: where required by law, such as for certain optional communications or features. Where we rely on consent, you may withdraw it at any time.

International Data Transfers

Personal Information may be transferred to and processed in countries outside the EEA or UK, including the United States. Where required, we rely on appropriate safeguards, such as standard contractual clauses or other lawful transfer mechanisms, to protect Personal Information transferred internationally.

Contact Information

If you have any questions or complaints about this Privacy Policy or our handling of your Personal Information, please contact us at compliance@lattispec.com.