Introduction

This Privacy Policy (“Policy”) explains how your personal information is collected, used, shared, and processed when you use or access www.PublicSquare.com (“Site”) or the PublicSquare mobile app (“App”), or use other services provided by PSQ Holdings, Inc. or by its corporate affiliates, including any written, electronic, and oral communications, online or offline, and any orders or purchases performed (collectively, the “Services”) as well as certain rights and choices you have associated with such information. This Policy also describes your rights regarding your personal data and explains how you can contact us to learn more about our data practices or exercise your rights.

We refer to the Site and App collectively and/or interchangeably herein as “PublicSquare” PublicSquare is provided by PSQ Holdings, Inc. (hereinafter “PSQ Holdings”). PSQ Holdings is responsible for collecting, processing, and protecting your personal data. In this Privacy Policy, the terms “PublicSquare,” “Company,” “we,” “us,” and “our” refer to PSQ Holdings.

Please read the PublicSquare and this Policy before accessing or using PublicSquare or our Services. If you cannot agree with this Policy or our Terms and Conditions, then please do not access or use PublicSquare or our Services.

Policy Modification: We may change this Policy from time to time, to reflect how we process your data, and if we make changes, we will revise the effective date or last modified date at the top of this Policy. If we make changes that materially affect your privacy rights, we will attempt to provide advanced notice (in nearly contemporaneous disclosures) or otherwise via PublicSquare, or by some other means of contact so that you have a reasonable opportunity to review the changes before you continue to use PublicSquare or our Services. If you do not agree with a future, modified version of this Policy, then please stop using PublicSquare and our Services at such future time.

1. How We Collect and Use Your Personal Data

We respect the privacy of visitors to PublicSquare and the users of our Services; we strive to protect it through our compliance with this Policy. We collect certain personal information when you use our Services.

Personal information is any information that identifies an individual or renders an individual identifiable. The definition of personal information (used interchangeably in this Policy with the term "personal data") depends on where you reside.

Personal Information does not include data that has been effectively irreversibly anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information or otherwise, to identify an individual.

Your personal data is collected and used by us to support a range of different business purposes. The purposes and types of information we collect are listed in the chart below and should be understood to include uses of your personal data that are compatible with the purposes listed.

Purpose

Personal Data We Collect

To create and manage your PublicSquare account or profile with us, and to provide you with our Services

• Contact information, including email address and password, to register with PublicSquare
• Profile data, including, for example, your order history and payment method(s).

To fulfill or process orders

• Identity and contact information such as name, phone number, and shipping address, as well as financial information or payment account information, for delivery, returns, refund, sales tax determinations, and payment operations.
• Transaction details, such as return and refund details, any gift card number, and order history, to fulfill basic functions.
• We may collect location data, at an IP address-based level.

To provide customer service or support, or for Service-related communications

• Your communication history with us via various channels, such as email, phone, text messaging, social media, regular mail, instant chat, PublicSquare, or other customer service platform, to respond to your requests, as well as to keep you updated about your account and the Services.

Marketing, advertising, or promotional activities

• Contact information, such as mailing address, phone number and email address, for marketing and email marketing purposes.
• Non-directly identifiable device identifiers, operating system information, and cookie information, to direct and measure the effectiveness of our advertising.
• Data about how you engage with our Services, such as browsing, adding to your shopping cart, saving items, placing an order, and returns for market research or statistical analysis, based on your activity on our Site and inferred interests.
• Contact and identity information, such as name, mailing address, email address, and phone number, when you voluntarily enter into a promotion or contest, market survey, event, or other marketing campaign organized by us.
• To share your personal data with third-party service providers to advertise Services and/or products.

To improve or personalize our products or Services

• Collect your device information, and usage data on PublicSquare for fault analysis, troubleshooting, and system maintenance.
• To share your personal data within and across our corporate organization for our business needs and personalization.

To prevent or investigate fraud and other unlawful activities

• Information automatically collected through the Services, such as browser type, device information, operating system, and account setting information for fraud prevention and detection and credit risk reduction.
• Log-in data for risk control and fraud reporting.
• Billing address and other payment-method data, such as credit or debit card information, to verify payment information.

To comply with any applicable legal requirements

• Transaction history and certain identifying information to handle and resolve disputes, for regulatory investigations purposes, and to comply with lawful requests from a competent law enforcement agency or court.

Other purposes

• We may use your information for any other purpose disclosed to you prior to you providing us your personal information, or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.

Please note: When communicating with us (whether by text message, email, or through PublicSquare or other means), please do not send us any sensitive information pertaining to yourself or others. We do not intend to collect or store sensitive information or special categories of information.

2. Sharing Your Personal Information

We may disclose and share your personal information with other parties as described below.

A. Within Our Corporate Organization. PSQ Holdings is a part of a corporate organization comprised of multiple legal entities, business processes, management structures, and technical systems. We may share your personal information within our related group of companies and, in some cases, other affiliates of our corporate group for business maintenance and personalization purposes, for instance, so that you may enjoy a personalized user experience across our digital properties, to provide you with the Services, or to take actions based on your requests or preferences.

B. Third-Party Sellers. Where a third-party Seller ships products to you directly, we may share your personal data (for example, name, address, and telephone number) with them so that they may fulfill your order and provide your personal data to a shipping logistics provider in order to ship the products to you.

C. Service Providers. We may provide access to or share your personal information with the following types of third-party service providers as set out in the table below.

Supplier/Service Provider/Processor

Services Offered

IT system and software providers

• Website hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, email service providers, or system maintenance services

Payment service providers

• Third-party payment processors

Analytics, Marketing, and Advertising Services

Assistance in reaching potential new customers across multiple communications channels or sharing with affiliated companies that promote our products on their own website or app

• Google Analytics. We use Google Analytics on our Site to help us analyze traffic and improve services. For more information on Google Analytics’ processing of personal information, please see . You may opt out of the use of Google Analytics here: .
• Google AdWords. Our Site also use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. That could mean that we advertise to previous visitors who haven’t completed a task on our site, such as registering for an account. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to our sites. Any data we collect will be used in accordance with this Privacy Policy, and Google is responsible to abide by its own privacy policy. You can set your preferences for how Google advertises to you using the Google Ad Preferences page:
• Meta Pixel. We use Meta Pixel Tags to better measure, optimize, and retarget our marketing campaigns. This allows user specific behavior to be tracked after they have been redirected to the advertiser’s website by clicking on a Meta ad. This enables us to measure the effectiveness of Meta ads for statistical and market research purposes. The data collected in this way is anonymous to us, in other words, we do not see the personal information of individual users. This data is stored and processed by Meta. Meta may link this information to your Meta account and also use it for its own promotional purposes, in accordance with Meta’s Data Usage Policy https://www.facebook.com/about/privacy/. For more information on opt-out options, please visit:
• Data Dog. We use Datadog to obtain analytics, service application, and infrastructure logs. Please see the  and Datadog Cookie Policy for additional information.

Order fulfillment service providers

• Manufacturing, logistics, warehousing, and distribution services, return and exchange services, and order status notification services for your ordered products or services

Customer service providers

• Assistance with customer support functions

Fraud prevention and info security providers

• Identity verification, fraud prevention, or credit-risk reduction services

D. To Maintain Legal or Regulatory Compliance. We have the right to disclose your personal information as required by law, or when we believe that disclosure is reasonably necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us. We also may disclose your information where we reasonably believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that disclosure will help us protect the rights, property, or safety of PublicSquare or our customers.

E. With Consent. We may disclose your personal information to any person, for any purpose, with your consent.

F. Corporate Transactions. We may disclose personal information to a buyer, prospective buyer, corporate affiliate, or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding in which personal information held by us about our users is among the assets transferred. You acknowledge and agree to our assignment or transfer of rights to your personal information.

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3. Cookies and Other Tracking Technologies

We may use cookies, tags, web pixels, and similar technologies to automatically collect information on our Services. Cookies or tags are bits of code that allow our technology partners to collect information that usually does not directly identify you. We will request your consent before using cookies or other tracking technologies. Information within this section describes our use of cookies and your ability to control the use of cookies for advertising-related purposes.

A. Cookies. Cookies are small web files that a website or its provider transfers to your device’s hard drive, through your web browser, that enables the site’s or provider’s system to recognize your browser and remember certain information. “First-party cookies” are cookies set by us on PublicSquare “Third-party cookies” are cookies set by other companies whose functionality is embedded into our site (for example, those set by Google). Generally, we may use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience. We use the following types of cookies on our Services:

• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access certain areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work, and they cannot be disabled.
• Functional Cookies. We may use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.‍
• Performance or Analytics Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We may use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.
• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.

B. Your Choices. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies on our Services by taking steps outlined below.

• First-Party Cookies. You can use the browser with which you are viewing the Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings). Please note, if you set your browser to disable cookies, you may not be able to access certain secure areas of the Site. Also, if you disable cookies, other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at  .
• Third-Party Cookies. If you wish to opt-in or opt-out of third-party advertising networks and similar entities that use advertising cookies, then please visit  . For more information about third-party advertising networks and similar entities that use these technologies, please see  .
• Mobile Applications. To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the Digital Advertising Alliance’s AppChoices mobile application opt-out offering here:  .

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences.

C. Web Pixels. To see how successful our marketing campaigns or other goals of the Services are performing, we may use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We may also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.

D. Analytics. We may use third-party service providers to monitor and analyze the use of our Services, such as Google Analytics. Such service providers often have their own separate privacy practices.

E. Behavioral Remarketing. We may also use remarketing services to advertise on third-party websites to you after you visited our Services. For this purpose, visitors are grouped by certain actions on our Services, e.g., by duration of a visit. This enables us to understand your preferences and to show you personalized advertising even if you are currently surfing on another website that also participates in the same advertising network. We may utilize Google Ads, Bing Ads, and similar ad networks.

F. Java Script. Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or "cached" within your browser to store and retrieve data in HTML5 pages when the website is revisited.

G. Other Tracking Technologies. We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, pages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.

H. Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit "Do Not Track" or "DNT" signals, which you may employ at your discretion.

I. Location Information. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information, by changing the relevant preferences and permissions in your device or browser settings.

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4. Security Precautions

We maintain reasonable physical, electronic, and procedural safeguards designed to guard your personal data from unauthorized processing, use or disclosure. Our security measures aim to prevent unauthorized access to or disclosure of your personal information.

However, the Internet is not an absolutely secure environment, and we cannot guarantee that your personal data will be secure. We therefore strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account. We also strongly advise that you neither share your password with others, nor re-use passwords on our Services that you use on other sites or apps, as doing so increases the likelihood of your being the victim of a credential-stuffing attack or other malicious cyber behavior. If you feel that the security of your account or personal data has been compromised, please immediately contact us via the "Contact Us" link on our Site.

5. Certain Rights You May Exercise

5.1 Access, Correction, and Deletion of your Personal Information. You have the right to access, correct, or delete the personal information that we collect. To protect the privacy and the security of your personal information, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. To exercise your rights, you may contact us as described below. We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

5.2 Unsubscribing from Marketing Communications. If you do not want us to use your email account to send you marketing emails or non-transactional promotional materials, please directly click on the unsubscribe link at the bottom of any of our email messages to you.

5.3 Lodging Complaints. If you believe we have infringed or violated your privacy rights, please contact us, as required by the PublicSquare  regarding dispute resolution, so that we may attempt to resolve any issues informally to your satisfaction.

5.4 Right to Opt-Out of Selling. Residents of certain states, such as California and Virginia, have the right to opt-out of having their personal information sold. We do not sell your personal information, as that term is generally understood, but certain privacy laws may define “sale” or "personal information" in such a way that: making identifiers linked to you available to limited third parties, for a benefit, may be considered a "sale." We may share identifiers and inferences about you with our partners, third parties, and affiliates in such a way that, under such privacy laws, could be interpreted as “selling.” If your state allows you to opt-out from such “sales,” then you may exercise your opt-out right by contacting us via the “Contact Us” link on our Site.

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6. Retention

We may retain your personal data, including any correspondence you have with us, only for as long as is necessary for the purposes set out in this Policy, including retaining Personal Data to comply with our legal obligations, to resolve disputes, for information security purposes, and to enforce our legal rights, terms, or policies.

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7. Third-Party Websites

PublicSquare may contain links to third-party sites or apps, or vice versa. This Policy does not apply to those third-party sites or apps. We recommend that you read the privacy statements of any other sites or apps that you visit, as we are not responsible for the privacy practices of those sites or apps.

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8. Children

PublicSquare and our other Services are not directed to, and we do not knowingly collect personal information from, children under the age of 18 or minors (as defined by applicable laws). If you are a minor, please do not attempt to fill out our forms or send any personal information about yourself to us. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us immediately to remove the relevant personal information and unsubscribe the minor. If we become aware that a minor has provided us with personal information, we will take steps to promptly delete such information from our files.

9. Extraterritorial Transfers of Personal Data

This Privacy Policy only applies to residents of the United States. Please also note that if you are a U.S. resident and you use our Services, your personal data may be accessed or transferred outside of the United States. Foreign jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. For such data transfers, we rely on appropriate safeguards as permitted under various applicable laws and standards. If you do not want your information transferred to, processed, accessed, or maintained outside of the United States, then you should immediately cease accessing PublicSquare and using our Services.

10. California Privacy Rights

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, as amended and pursuant to its regulations and successors (together, “CCPA”), below is a summary for the last twelve (12) months of the personal information categories, as identified and defined by the CCPA (see California Civil Code § 1798.140(o)), that we collect, the reason we collect the personal information, where we obtain the personal information, and the third parties with whom we may share the personal information.

We may collect the following categories of personal information when you use our Services:

• Identifiers such as a name, address, unique personal identifier, email, phone number, payment method(s), your device’s IP address, and non-directly identifiable alphanumerical numbers associated with your devices;
• Commercial information such as records of products or services purchased, obtained, or considered by you;
• Internet or other electronic information regarding your browsing activity, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with various transactions, and system configuration information; and
• Audio recordings of your voice to the extent you call us, if permitted under applicable law.

We generally do not collect protected classifications about our users, biometric information, or education-related information. For more information about the personal information we collect and the purposes for which we use it, please refer to Section 1 herein. The categories of third parties with whom we may share your personal information are listed above in Section 2.

If you are a California resident, you have rights in relation to your personal information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of our network systems. To assert your right to know or your right to delete your personal information, please see the "Contact Us" section below. To confirm your identity, we may ask you to verify personal information we already have on file for you or other documentation that verifies that you are whom you claim to be. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

• Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
• Right to Know. You have the right to request in writing a list of the information we have collected or disclosed about you, the business purposes involved, and the sources of such information. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request.
• Right to Delete. You have the right to request that we delete any personal information we have collected from you or maintain about you, subject to certain exceptions.
• CCPA Right to Opt-Out of Selling. You have the right to opt-out of having your personal information sold. To exercise this right, please see the "Cookies and Other Tracking Technologies" section above for a description of opting out of cookies and controlling browser settings.
• Use of an Authorized Agent to Submit a Request. Only you or a person you formally authorize to act on your behalf may make a consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

In addition, California's Shine The Light law permits customers who are residents of California to request information regarding our disclosure of certain personal information to third parties for their own direct marketing purposes (see California Civil Code § 1798.83 (e)(7) for a list of personal data categories). You can submit a disclosure request using the contact information provided below, once per year, free of charge.

11. Other States’ Privacy Laws

Nevada. This paragraph applies only to Nevada residents. We could be deemed to "sell" "covered information" of Nevada "consumers," as those terms are defined by Chapter 603A of the Nevada Revised Statutes. If you are a Nevada consumer, please inform us via email that you would like us to provide you notice, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. You may contact us as described below. It is your responsibility to keep your notice contact information current.

Colorado, Connecticut, Virginia and Utah. Each of these States provides their residents with rights to:

• confirm whether we process their personal information;
• access and delete certain personal information;
• data portability;
• opt-out of personal data processing for targeted advertising and sales.

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Colorado, Connecticut, and Virginia also afford their residents rights to:

• correct inaccuracies in their personal information; and
• opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Based on our own knowledge and reasonable belief, our opinion is that we do not currently use, share, or sell data in a manner that would trigger these statutes’ opt-out requirements. Nevertheless, to exercise any of these rights, please contact us through the “Contact Us” link on our Site.

12. Contact Us

If you have any questions or concerns regarding any privacy-related information included in, or omitted from, this Privacy Policy, then please contact us. You may submit any privacy-related inquiries or complaints to us through the “Contact Us” link on our Site, or by regular mail to the following postal address.

PSQ Holdings, Inc.

ATTN: Privacy

250 S. Australian Avenue, Suite 1300

West Palm Beach, Florida 33401

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