A. Introduction

This Privacy Policy is effective as of March 10, 2025, and represents the Privacy Policy of Key2DebtFree (“Key2DebtFree,” “we,” “our,” or “us”).

This Privacy Policy addresses the privacy rights of individuals who:

▪️ visit our Website or use our Services;

▪️ interact with us on behalf of a Customer in connection with the provision of our Services;

▪️ interact with us on behalf of an Independent Insurance Agent marketing our Services;

▪️ interact with us on behalf of a Service Provider in connection with the products and services our Service Provider provides to us;

▪️ interact with us on behalf of a business partner in connection with our relationship with the business partner;

▪️ apply to work with us;

▪️ receive marketing communications from us; and/or

▪️ interact with us by registering for, attending and/or otherwise taking part in our trade events, webinars, or conferences or who communicate with us via email, phone, or in-person.

This Privacy Policy, which includes and incorporates our GDPR Privacy Policy, is designed to assist individuals and businesses that interact with us to understand the types of Personal Data we collect, how that Personal Data is Processed, and the practices we have adopted to protect Personal Data.

B. Definitions

“Controller” means a person or organization that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

“Customer” means a business or individual that has, formerly had, or is contemplating purchasing or using our Services, or any party that is employed by such business and accesses Services pursuant to such business purchasing or using our Services.

“GDPR” means the EU General Data Protection Regulation 2016/679.

“Independent Insurance Agent(s)” A licensed insurance professional who is not an employee of Key2DebtFree but works independently to market and facilitate the Infinite Banking Concept and related financial services to consumers.

“NYDFS” means New York State Department of Financial Services.

“Personal Data” means any information relating to an identified or identifiable natural person.

“Privacy Policy” means this Privacy Policy.

“Process” and “Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

“Processor” means a person or organization that engages in Processing.

“Representative” means an individual who (i) acts on behalf of, or is employed by, a Customer, including, a Customer’s employees, agents, and representatives, (ii) acts on behalf of a Service Provider, including, a Service Provider’s employees, agents, and representatives, (iii) acts on behalf of a business partner, including a business partner’s employees, agents, and representatives or (iv) otherwise interacts with us in any manner, for example through our Website or uses our Services, in any manner whatsoever.

“Service Provider” means a supplier, subcontractor, vendor, or other third party who provides services to us, including but not limited to the sell and commercialization of our Services to Customers.

“Services” means the products and services provided by us, including, but not limited to, financial education and coaching, insurance advisory services, marketing of the “Infinite Banking Concept”, online and in person courses, webinars, and any other educational or consulting services we may make available from time to time.

“Website” means all of the websites and applications maintained by us that display a link to the Privacy Policy.

“Website Visitor” means an individual who visits the Website.

C. Personal Data Collected

For our Customers, we may collect the Personal Data of you or your Representatives (e.g., name, job title, business contact details, final information, and any other necessary information for policy applications) when you or your Representatives inquire about, negotiate, purchase, or use any of our Services.

For our Service Providers, we may collect the Personal Data of your Representatives when we inquire about or purchase services from you to support our business operations.

For our business partners, we may collect the Personal Data of your Representatives in connection with our interactions with you.

For prospective employees, we may collect your Personal Data when you visit, browse, or register on our Websites, when you submit an application for employment, when you provide additional Personal Data during the application and interview process, when you speak to our employees during your interview process, and when you otherwise provide or authorize us to collect your Personal Data during the application and interview process.

For our Independent Insurance Agents, we collect information from agents to monitor their use of our platforms, marketing practices, and compliance with regulations.

For our Website Visitors, we may collect certain Personal Data from you when you visit, browse, register on our Websites, complete a form on our Websites, or engage in online support received through our Websites. We may also collect certain information about your session when you visit our Websites, including internet protocol (IP) addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and clickstream data, as further outlined below.

We may also collect the Personal Data of Representatives if they (i) register for a trade event, webinar, or conference hosted by us, (ii) download or request content and information regarding our Services, (iii) complete a survey or form, (iv) request online support through our Websites, or (v) receive marketing communications from us.

D. Purpose of Personal Data Collection and Processing

We collect and Process Personal Data for the following purposes:

▪️ To provide, assess, and improve our customer support and customer service;

▪️ To personalize your experience using our Services or Websites;

▪️ To fulfill a legal obligation or to protect our rights;

▪️ To comply with applicable laws and regulations, including the NYDFS regulations;

▪️ To advise you of additional or new Services that may be of interest to you;

▪️ To administer and manage Service Providers;

▪️ To work with business partners;

▪️ To improve and protect the integrity and security of our Services and our Websites;

▪️ To facilitate the insurance process for consumers who engage with Independent Insurance Agents;

▪️ To consider job applicants for employment;

▪️ To send periodic communications (the contact information that you provide may be used to send you information, including marketing, respond to inquiries, and/or other requests or questions); and

▪️ For any other purpose for which you have been notified, and if legally required where appropriate consent has been obtained.

If you receive marketing communications from us by email, and you no longer want to receive marketing-related emails from us, you may opt out of receiving such emails by clicking the “unsubscribe” link at the bottom of any marketing email you receive from us. If you are having difficulty unsubscribing from our marketing emails using the above methods, please contact us directly at the email info@Key2DebtFree.com

E. Security

We implement a variety of security measures to maintain the safety of your Personal Data when you enter, submit, or access your Personal Data, or when it is otherwise collected or Processed by us. We take reasonable and appropriate measures to secure your Personal Data. These include:

▪️ Secure storage and processing of Personal Data with encryption measures;

▪️ Role-based access controls to limit internal access to Personal Data;

▪️ Multi-factor authentication (MFA) for accessing sensitive systems;

▪️ Incident response protocols for unauthorized access or data breaches.

F. Cookies and Other Technologies

We automatically collect information about your use of our Site through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information.

Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website and Services. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website and Services who disable cookies will be able to browse certain areas of the Website, but some features may not function.

We use third-party browser and mobile analytics services like Google Analytics in connection with the Services. These services use data collection tools to help us analyze use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.

G. Collection of Personal Data from Children

Our Websites and Services are intended for individuals 18 years of age and older. They are not directed at, marketed to, nor intended for, children under 18 years of age. We do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at info@Key2DebtFree.com and we will take immediate steps to delete it.

H. Changes to Privacy Policy

We will provide adequate notice of any material changes and obtain your consent when legally required when making such changes to this Privacy Policy.

I. Inquiries/Contact Us

You may have rights regarding your Personal Data depending on where you are and where your Personal Data is Processed. Please contact us at info@Key2DebtFree.com if you have questions in this regard or if you wish to update your Personal Data.

J. Governing Law; Venue; Waiver of Jury Trial and Class Actions

Unless applicable data protection or data privacy laws expressly provide otherwise, (a) this Privacy Policy is governed by the laws of the State of Florida, U.S.A, (b) you hereby agree that any dispute or claim raised or made by you against us relating to the Privacy Policy shall be subject to arbitration before a single arbitrator in Volusia County, Florida, in accordance with the Commercial Arbitration Rules of the American Arbitration Association and (c) you hereby waive all rights to bring or maintain any court action, jury trial or any class claim, class action, class arbitration, or other representative action, claim or proceeding against us in a court of law.

K. Compliance with NYDFS Regulations

As a company operating under New York Insurance Law, we comply with applicable regulations, including:

▪️ Maintaining cybersecurity policies;

▪️ Implementing multi-factor authentication as required for access to sensitive data;

▪️ Conducting periodic security risk assessments;

▪️ Ensuring secure data retention practices;

▪️ Complying with NYDFS’s 72-hour breach notification requirement in the event of a data breach.

L. California Consumer Privacy Act Notice

This section addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (“CCPA”). It applies to personal information about California residents using our Site and Services. For purposes of the CCPA, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

In the event of a conflict between this CCPA Notice and any of our other privacy notices, this CCPA Notice shall control only with respect to the personal information of California residents.

M. Personal Information Categories

Our Privacy Notice covers our personal information collection and usage more fully. Below we describe the categories of personal information we collect and the sources from which we collect the personal information, organized into the categories specified by the CCPA.

M.1 Personal information

Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history, credit card or debit card number).

Sources: Information you provide directly or through your interactions with our Services.

Information provided by your current or former employer.

M.2 Identifiers

Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers).

Sources: Information you provide to us directly or through your interactions with our Site and Services.

Information provided by your current or former employer.

M.3 Characteristics

Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”).

Sources: Information you provide to us directly.

M.4 Commercial Information

Commercial information (e.g., information regarding products or services purchased, obtained, or considered)

Sources: Information you provide to us directly. Your interactions with our Site and Services.

M.5 Internet or Other Electronic Network Activity Information

Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services).

Sources: Your interactions with our Site and Services.

M.6 Geolocation Data

Sources: Information provided by your employer.

M.7 Professional or Employment-Related Information

Sources: Information you provide to us directly. Information from your employer.

M.8 Inferences

Sources: Information you provide to us directly or through your interactions with our Site and Services.

Information from your employer

M.9 Audio, electronic, visual or similar information

Sources: Information you provide directly or through your interactions with our Services.

We use this personal information for the purposes outlined in the “Purpose of Personal Data Collection and Processing” set forth above. We do not sell your personal information and we do not have actual knowledge that we sell the personal information of minors under 16 years of age.

N. California Residents' Privacy Rights

California residents have rights to request access to or deletion of their personal information and may not be discriminated against because they exercise any of their rights under the California Consumer Privacy Act in violation of Cal. Civ. Code §1798.125. You can make requests by sending an email to info@Key2DebtFree.com with details of your specific request. We may ask that you provide certain information to verify your identity, and the information we request from you will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

You may designate an authorized agent to make a request under the CCPA on your behalf if: (1) the authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (2) you sign a written declaration that you authorize the authorized agent to act on your behalf. We may ask that you provide certain information to verify your identity and that you authorized the authorized agent to act on your behalf. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

California residents also have the right to opt out of the sale of their personal information; we do not provide this option as we do not sell your personal information.

If you have any questions or concerns regarding this CCPA Notice, please email info@Key2DebtFree.com.

O. GDPR Privacy Policy

This GDPR Privacy Policy section of our Privacy Policy (this “**GDPR Privacy Policy**”) applies to the Processing of Personal Data by Key2DebtFree in its role as a Controller, or as otherwise covered by the GDPR, when individuals:

▪️ visit or use our Website;

▪️ interact with us either on your own behalf or on behalf of a Customer in connection with the provision of our Services;

▪️ interact with us on behalf of a Service Provider in connection with the products and services our Service Provider provides to us;

▪️ interact with us on behalf of a business partner in connection with our relationship with the business partner;

▪️ apply to work with us;

▪️ receive marketing communications from us; and/or

▪️ interact with us by registering for, attending and/or otherwise taking part in our trade events, webinars, or conferences or communicate with us via email, phone, or in-person interactions.

This GDPR Privacy Policy does not apply to any Personal Data Processed, stored, or hosted by Customers using any of our Services or to the extent that we Process Personal Data in the role of a Processor on behalf of our Customers. Where we act as Processors on behalf of our Customers, that Processing is subject to the protections contained in our data processing agreements with Customers. We have no control over, and are not responsible for, any Personal Data that our Customers may store or host on their equipment or otherwise process while using our Services. We are not responsible for the privacy or data security practices of our Customers, which may differ from those set forth in this GDPR Privacy Policy. For information related to how our Customers Process Personal Data, please contact the respective Customer directly.

Furthermore, this GDPR Privacy Policy does not apply to any third-party website or service that may be linked to the Websites or the Services unless that website or service is controlled by us and displays this GDPR Privacy Policy. We have no control over, and are not responsible for, the data collection and/or handling practices of these third-party websites or services outside our Websites or Services. We encourage you to read the privacy statements of any third-party websites or services linking to (or linked to via) the Website or Services. In the event of a conflict between this GDPR Privacy Policy and the remainder of the Privacy Policy this GDPR Privacy Policy will prevail.

P. Our Contact Details

If you have any questions or concerns as to how your Personal Data is Processed, please write to us at info@Key2DebtFree.com.

Q. Key2DebtFree’s Data Collection Practices

Key2DebtFree collects and processes the following categories of Personal Data from Customers, Service Providers, business partners, Representatives, Website Visitors, prospective employees, individuals that receive marketing communications from Key2DebtFree and individuals that interact with Key2DebtFree by registering for, attending and/or otherwise taking part in Key2DebtFree webinars or conferences or who communicate with Key2DebtFree via email, phone or in person, in each case to operate its business for the specific purposes identified below.

▪️ Personal Details include data such as names, titles, company names, departments, email addresses, physical street addresses, telephone numbers, and social media usernames of individuals.

▪️ Login Credentials include data such as usernames and passwords of individuals needed to access our Services.

▪️ Unique IDs include data such as IP addresses and geolocation data that we obtain from (a) prospective employees, (b) Website Visitors, or (c) other individuals that interact with us.

▪️ Customer Support Records include data such as call details and other similar data regarding customer support communications and chat sessions with Representatives.

▪️ Website and Service Records include data related your interactions with our Websites and Services and other online content such as log data (i.e., preferences and settings, IP addresses, technical information about the device used to visit the Websites or use the Services, and geolocation information) and traffic data (i.e., pages viewed, date stamps, time spent on a page, click through and clickstream data, queries made, search history, search results selected, comments made, type of service requested, and purchases made).

▪️ Employment Information includes details such as descriptions of roles performed and locations of employment.

Why Does Key2DebtFree Collect Personal Data, What are the Sources of Personal Data, What are the Purposes for Processing, and What is the Lawful Basis?

The information below sets out the types of Personal Data Key2DebtFree Processes, the purposes of Processing such Personal Data, and Key2DebtFree’s lawful basis for doing so. The lawful basis will vary with the type of Processing involved and will typically include Processing (i) necessary for Key2DebtFree to pursue its legitimate business interests, (ii) based on your consent, where this is required by data protection laws, and (iii) necessary for Key2DebtFree to comply with its legal obligations. Where we rely on our legitimate business interests, we have explained what the grounds are for that reliance.

Q.1 Key2DebtFree’s Purpose of Processing Personal Data

Q.1.1

To interact with Customers, Service Providers and business partners. When a Customer places an order for our Services, Key2DebtFree Processes the following Categories of Personal Data necessary to deliver and provide Services to its Customer. Key2DebtFree also collects and Processes such Personal Data when engaging with and purchasing products and services from Service Providers or business partners.• Personal Details• Login Credentials• Unique IDs.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legitimate business interest in processing Personal Data in order to engage in transactions with its Customers, Service Providers and business partners and efficiently run its business.

Q.1.2

To aggregate data provided by users of the Services for Customers. As part of the Services provided to Customers, Key2DebtFree aggregates and anonymizes Data provided by Customers and creates reports using such Data, Personal Details, Login Credentials, & Unique IDs.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legitimate business interest in processing Personal Data in order to engage in transactions with its Customers and efficiently run its business.

Q.1.3

To manage the security of our systems or Services. In order to grant a Customer, Service Provider, business partner or prospective employee access rights to our systems or Services and to monitor applicable security thereof, Key2DebtFree collects and Processes the following categories of Personal Data from the Representatives of such Customer, Service Provider or business partner or the prospective employee:• Personal Details• Unique IDs• Access Credentials and Visitation Records.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legitimate business interest in protecting the security of its systems and Services.

Q.1.4

To provide customer and technical support. Key2DebtFree collects and Processes the following categories of Personal Data to provide Customers and their Representatives with technical and general support: Personal Details, Login Credentials, Unique IDs, & Customer Support Records.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legitimate business interest in being able to provide its Customers with customer and technical support.

Q.1.5

To communicate and respond to requests and inquiries. When a Customer, Service Provider, business partner or other person or entity contacts us by email, phone, text or by submitting a contact form on our Website, Key2DebtFree collects and Processes the following Categories of Personal Data from the Representatives or other individuals in order to communicate with Customer, Service Provider, business partner or such other person or entity, as applicable, and respond to their requests and inquiries. Key2DebtFree also collects and Processes the following Personal Data from Representatives who register for a trade event, webinar, conference: Personal Details, Unique IDs, Website Records, Marketing and Event Records.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legitimate business interest in being able to communicate with its Customers, Service Providers, business partners and other persons or entities and respond to their inquiries and requests.

Q.1.6

To market our Services and tailor our marketing and sales activities. Key2DebtFree may Process the following categories of Personal Data when marketing new and existing Services and features to its Customers and other persons and entities and in an effort to personalize such experience. Key2DebtFree also collects and Processes the following Personal Data from Representatives who register for a trade event, webinar, or conference: Personal Details, Unique IDs, Website Records, Marketing and Event Records.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Except in cases where opt-in consent is required by law for the processing of email addresses, IP addresses or other unique identifiers to send or process electronic communications (emails, texts, cookies, etc.), Key2DebtFree processes this data for marketing purposes on the basis of its legitimate interests.

Q.1.7

To analyze, improve, and optimize the use, function and performance of our Website and Services. Key2DebtFree may Process the following categories of Personal Data in order to analyze, improve, and optimize the use, function and performance of its Website and Services, including for quality assurance and training purposes, as well as for marketing and sales campaigns. Personal Details, Unique IDs, Website Records, Marketing and Event Records.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legitimate business interest in improving and optimizing the use of its Website and Services.

Q.1.8

To comply with applicable laws, regulations and internal policies, practices, and procedures. Key2DebtFree may be required to disclose certain categories of Personal Data to comply with applicable laws and regulations, for example, to respond to a request from a government agency or to defend a legal claim. Additionally, Key2DebtFree may also be required to Process certain categories of Personal Data when conducting internal audits and investigations to ensure compliance with internal and external policies, practices, and procedures.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legitimate business interest in complying with all applicable laws, regulations, and internal policies.

Q.1.9

To receive applications for employment. Key2DebtFree may Process the following categories of Personal Data when receiving, reviewing, using, and storing applications for employment, including from prospective employees who visit the Website or other online locations where jobs may be posted and applications may be submitted: Personal Details, Login Credentials, Unique IDs, Education and Work History.

Key2DebtFree’s Lawful Basis for Collecting Personal Data: Key2DebtFree has a legal obligation to collect certain information to confirm your right to work in the country to which you have applied.

Otherwise, Key2DebtFree has a legitimate business interest in Processing the Personal Data of job applicants who seek to join the company to assess them as candidates for employment.

R. Key2DebtFree’s Data Collection Practices

Key2DebtFree collects and processes the following categories of Personal Data from Customers, Service Providers, business partners, Representatives, Website Visitors, prospective employees, individuals that receive marketing communications from Key2DebtFree and individuals that interact with Key2DebtFree by registering for, attending and/or otherwise taking part in Key2DebtFree webinars or conferences or who communicate with Key2DebtFree via email, phone or in person, in each case to operate its business for the specific purposes identified below.

▪️ Personal Details include data such as names, titles, company names, departments, email addresses, physical street addresses, telephone numbers, and social media usernames of individuals.

▪️ Login Credentials include data such as usernames and passwords of individuals needed to access our Services.

▪️ Unique IDs include data such as IP addresses and geolocation data that we obtain from (a) prospective employees, (b) Website Visitors, or (c) other individuals that interact with us.

▪️ Customer Support Records include data such as call details and other similar data regarding customer support communications and chat sessions with Representatives.

▪️ Website and Service Records include data related to your interactions with our Websites and Services and other online content such as log data (i.e., preferences and settings, IP addresses, technical information about the device used to visit the Websites or use the Services, and geolocation information) and traffic data (i.e., pages viewed, date stamps, time spent on a page, click through and clickstream data, queries made, search history, search results selected, comments made, type of service requested, and purchases made).

▪️ Employment Information includes details such as descriptions of roles performed and locations of employment.

S. Sharing with Third Parties

Except as described below, we will not share or disclose Personal Data with or to outside third parties (meaning entities outside of the Group). The Group may share Personal Data between each other. Any and all Personal Data provided to us by a Customer, Website Visitor, Business Partner, or other third party is transferred only on a “need to know” basis in keeping with the purposes outlined in this Privacy Policy.

Service Providers. We may share Personal Data with our Service Providers in connection with advertising, hosting, data analytics, information technology and infrastructure, order management and fulfillment, billing, contract management, email delivery, auditing, events, and other related activities. We provide such Personal Data or authorize the processing of such Personal Data only as necessary to enable our Service Providers to perform their designated functions. Our contracts with them (1) require them to act only under our instruction and for the purpose(s) directed by us with respect to such Personal Data; and (2) prohibit them from sharing such Personal Data with any third parties without our authorization.

Business Partners. We may also share your Personal Data with trusted business partners pursuant to our contractual arrangements with them, which will include appropriate safeguards to protect any Personal Data that we share with these partners. These may include, but are not limited to, third parties that organize tradeshows, third party consultants and experts, and auditors.

Affiliated Entities. We share Personal Data with our Affiliates. Subject to local requirements, this Personal Data may be used to provide Services offered by our Affiliates, for the Affiliates to provide support to the Affiliated entity that is sharing the Personal Data or for any other purposes described in this Privacy Policy. For example, Affiliates may share Personal Data about our Customers, Service Providers, business partners, Representatives, prospective employees, and Website Visitors for direct marketing purposes.

Fraud Prevention and Protection of Legal Rights. We may use and disclose Personal Data to the appropriate legal, judicial or law enforcement authorities and our advisors and investigators: (i) when we believe, in our sole discretion, that such disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of the Group and of our Customers, Service Providers, business partners, Representatives, Website Visitors, prospective employees, or others; (ii) when we suspect abuse of the Website or Services or unauthorized access to any system, spamming, denial of service attacks, or similar attacks; (iii) to exercise or protect legal rights or defend against legal claims; or (iv) to allow us to pursue available remedies or limit the damages that we may sustain. We may disclose personal information to our partners, service providers, and law enforcement to secure our Website and Services, including to detect, prevent, and investigate security incidents or violations of our Terms of Use or applicable laws.

Law Enforcement. We may have to disclose the Personal Data of our Customers, Service Providers, business partners, Representatives, applicants, Website Visitors or others if a court, law enforcement or other public or government authority with appropriate competency requests that we provide that Personal Data and we believe, in our reasonable discretion, that such request was made in compliance with applicable law.

Corporate Reorganization. We may transfer the Personal Data of our Customers, Service Providers, business partners, Representatives, Website Visitors or others to a third party in the case of the reorganization, sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, asset or stocks, including in the event of bankruptcy or corporate restructuring. Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to compliance with applicable data protection laws. Any Personal Data that an individual submits or that is collected after the reorganization may be subject to a new privacy policy adopted by the successor entity, of which we will inform, where required.

Service Improvements. We may disclose personal information to our service providers in order to improve our Website and Services, such as to identify bugs, repair errors, or ensure that services function as intended, or conduct internal research and analysis to improve our technology.

In addition to the above, we also may disclose personal information to third parties at your direction.

T. Data Retention

We will retain Personal Data that we collect and Process where we have a justifiable business need to do so and/or for as long as it is needed to fulfill the purposes outlined in this Privacy Policy. We may retain Personal Data as required by law, such as for tax, legal, or accounting purposes. When, in our reasonable discretion, we have no justifiable business need to Process your Personal Data (for example, after all of our necessary interactions have ended, our internal record keeping policies no longer require us to continue to Process your Personal Data, and we have no other legal obligations to retain your Personal Data), we will either delete it or anonymize it.

U. Data Subject Rights under the GDPR

The GDPR grants individuals who are in the EU/EEA/UK the following rights, with some limitations. Individuals may contact us, at our contact information as set forth herein to exercise any of those rights and we will respond with the requested action or information, or will let you know why such rights do not apply to you. These rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. In some cases, the exercise of these rights (for example, erasure, objection, restriction or the withholding or withdrawing of consent to processing) may make it impossible for us to provide services.

Right Not to Provide Consent or to Withdraw Consent. We may seek to rely on your consent in order to Process certain Personal Data. Where we do so, you have the right not to provide your consent, and the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of the Processing conducted based on consent before its withdrawal.

Right of Access. You have the right to obtain confirmation as to whether or not we collect or Process Personal Data concerning you and, if this is the case, you have the right to request a copy of such Personal Data in digital format.

Right of Rectification. You have the right to require that we correct any inaccurate Personal Data concerning you, and that we complete incomplete Personal Data.

Right of Erasure. In certain circumstances, you have the right to request that we erase Personal Data concerning you; for example, if it is no longer necessary for the purposes for which it was originally collected and we do not otherwise have a legitimate reason to retain it. We may need to retain certain Personal Data when legally required, for internal, record keeping purposes, and/or in order to complete any transactions initiated prior to an individual’s request to remove or delete their Personal Data. Where we are unable to delete data from our systems, we will anonymize it so it will no longer be tied to your identity.

Right to Restrict Processing. In certain circumstances, you have the right to request that we restrict the Processing of the Personal Data that we have collected about you; for example, where you believe that the Personal Data that we hold about you is not accurate or lawfully held.

Right to Data Portability. In certain circumstances, you have the right to receive the Personal Data concerning you that you have provided to us in a structured, commonly used, machine readable format, and for us to transmit the data to another entity where technically feasible.

Right to Object to the Processing. In certain circumstances, you have the right to request that we stop Processing your Personal Data, including where we rely on legitimate interests as legal basis in the tables on the details of Processing provided above. If you receive commercial electronic communications from us, you can unsubscribe from the receipt of future commercial electronic communications from us by clicking on the “unsubscribe” link provided in such communications. Please also note that if you do opt out of receiving commercial electronic communications from us, we may still send you important administrative messages (such as updates about your account or changes in the Services), and you cannot opt out from receiving these messages, unless you stop receiving our Services.

Right Not to be Subject to Decisions Based Solely on Automated Processing that Produce Legal Effects. We do not make decisions based solely on automated processing - including profiling - that produces legal effects or similarly affects you.

Right to Complain to a Supervisory Authority. You have the right to lodge a complaint with a Supervisory Authority if you believe that our Processing of Personal Data relating to you is inconsistent with our obligations under the GDPR. In this situation, we ask you please consider contacting us first, so that we can try and assist with your query or address your concern.

To exercise any of your rights as set forth herein, please contact us in writing, via email or postal mail as indicated above, so that we may consider your request under applicable law. We may ask that you provide the following Personal Data for us to address your request speedily:

▪️ The name, User ID, pseudonym, email address, or other identifier you have provided to us or if you have not otherwise previously interacted with us, your first and last name and an address where we can correspond with you;

▪️ The country in which you are located;

▪️ A clear description of the Personal Data or content you wish to receive or to be deleted or corrected, or the action you wish to be taken; and

▪️ Sufficient information to allow us to locate the content or Personal Data to be deleted, removed, or corrected.

For your protection, we may only implement requests with respect to the Personal Data that are associated with the particular email address that you use to send us your request. In addition, please note that, depending on the nature of your inquiry, request, or complaint, we may need to verify your identity before implementing your request and may require proof of identity, such as in the form of a government issued ID and proof of your physical address. We will try to comply with your request as soon as reasonably practicable and in any case within the timelines prescribed by applicable laws. However, we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or, in some cases, to charge a fee that takes into account the administrative costs for providing the information or the communication or taking the action requested.

Last updated: 5/10/2025

Please read these terms and conditions carefully before using Our Service.

A. Interpretation and Definitions

A.1 Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

A.2 Definitions

For the purposes of these Terms and Conditions:

▪️ Country refers to: United States

▪️ Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement).

▪️ Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

▪️ Service refers to the Website.

▪️ Terms and Conditions (also referred as "Terms") mean these Terms and Conditions that form the entire agreement between You and the Company regarding the use of the Service. This Terms and Conditions agreement has been created with the help of the Terms and Conditions Generator.

▪️ Third-party Social Media Service means any services or content (including data, information, products or services) provided by a third-party that may be displayed, included or made available by the Service.

▪️ Website refers to Key2DebtFree, accessible from https://key2debtfree.com/

▪️ You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

B. Acknowledgment

These are the Terms and Conditions governing the use of this Service and the agreement that operates between You and the Company. These Terms and Conditions set out the rights and obligations of all users regarding the use of the Service.

Your access to and use of the Service is conditioned on Your acceptance of and compliance with these Terms and Conditions. These Terms and Conditions apply to all visitors, users and others who access or use the Service.

By accessing or using the Service You agree to be bound by these Terms and Conditions. If You disagree with any part of these Terms and Conditions then You may not access the Service.

You represent that you are over the age of 18. The Company does not permit those under 18 to use the Service.

Your access to and use of the Service is also conditioned on Your acceptance of and compliance with the Privacy Policy of the Company. Our Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your personal information when You use the Application or the Website and tells You about Your privacy rights and how the law protects You. Please read Our Privacy Policy carefully before using Our Service.

C. Links to Other Websites

Our Service may contain links to third-party web sites or services that are not owned or controlled by the Company.

The Company has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party web sites or services. You further acknowledge and agree that the Company shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods or services available on or through any such web sites or services.

We strongly advise You to read the terms and conditions and privacy policies of any third-party web sites or services that You visit.

D. Termination

We may terminate or suspend Your access immediately, without prior notice or liability, for any reason whatsoever, including without limitation if You breach these Terms and Conditions.

Upon termination, Your right to use the Service will cease immediately.

E. Limitation of Liability

Notwithstanding any damages that You might incur, the entire liability of the Company and any of its suppliers under any provision of this Terms and Your exclusive remedy for all of the foregoing shall be limited to the amount actually paid by You through the Service or 100 USD if You haven't purchased anything through the Service.

To the maximum extent permitted by applicable law, in no event shall the Company or its suppliers be liable for any special, incidental, indirect, or consequential damages whatsoever (including, but not limited to, damages for loss of profits, loss of data or other information, for business interruption, for personal injury, loss of privacy arising out of or in any way related to the use of or inability to use the Service, third-party software and/or third-party hardware used with the Service, or otherwise in connection with any provision of this Terms), even if the Company or any supplier has been advised of the possibility of such damages and even if the remedy fails of its essential purpose.

Some states do not allow the exclusion of implied warranties or limitation of liability for incidental or consequential damages, which means that some of the above limitations may not apply. In these states, each party's liability will be limited to the greatest extent permitted by law.

F. "AS IS" and "AS AVAILABLE" Disclaimer

The Service is provided to You "AS IS" and "AS AVAILABLE" and with all faults and defects without warranty of any kind. To the maximum extent permitted under applicable law, the Company, on its own behalf and on behalf of its Affiliates and its and their respective licensors and service providers, expressly disclaims all warranties, whether express, implied, statutory or otherwise, with respect to the Service, including all implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, and warranties that may arise out of course of dealing, course of performance, usage or trade practice. Without limitation to the foregoing, the Company provides no warranty or undertaking, and makes no representation of any kind that the Service will meet Your requirements, achieve any intended results, be compatible or work with any other software, applications, systems or services, operate without interruption, meet any performance or reliability standards or be error free or that any errors or defects can or will be corrected.

Without limiting the foregoing, neither the Company nor any of the company's provider makes any representation or warranty of any kind, express or implied: (i) as to the operation or availability of the Service, or the information, content, and materials or products included thereon; (ii) that the Service will be uninterrupted or error-free; (iii) as to the accuracy, reliability, or currency of any information or content provided through the Service; or (iv) that the Service, its servers, the content, or e-mails sent from or on behalf of the Company are free of viruses, scripts, trojan horses, worms, malware, timebombs or other harmful components.

Some jurisdictions do not allow the exclusion of certain types of warranties or limitations on applicable statutory rights of a consumer, so some or all of the above exclusions and limitations may not apply to You. But in such a case the exclusions and limitations set forth in this section shall be applied to the greatest extent enforceable under applicable law.

G. Governing Law

The laws of the Country, excluding its conflicts of law rules, shall govern this Terms and Your use of the Service. Your use of the Application may also be subject to other local, state, national, or international laws.

H. Disputes Resolution

If You have any concern or dispute about the Service, You agree to first try to resolve the dispute informally by contacting the Company.

I. For European Union (EU) Users

If You are a European Union consumer, you will benefit from any mandatory provisions of the law of the country in which you are resident in.

J. United States Legal Compliance

You represent and warrant that (i) You are not located in a country that is subject to the United States government embargo, or that has been designated by the United States government as a "terrorist supporting" country, and (ii) You are not listed on any United States government list of prohibited or restricted parties.

K. Severability and Waiver

Severability

If any provision of these Terms is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will continue in full force and effect.

Waiver

Except as provided herein, the failure to exercise a right or to require performance of an obligation under these Terms shall not effect a party's ability to exercise such right or require such performance at any time thereafter nor shall the waiver of a breach constitute a waiver of any subsequent breach.

L. Translation Interpretation

These Terms and Conditions may have been translated if We have made them available to You on our Service. You agree that the original English text shall prevail in the case of a dispute.

M. Changes to These Terms and Conditions

We reserve the right, at Our sole discretion, to modify or replace these Terms at any time. If a revision is material We will make reasonable efforts to provide at least 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at Our sole discretion.

By continuing to access or use Our Service after those revisions become effective, You agree to be bound by the revised terms. If You do not agree to the new terms, in whole or in part, please stop using the website and the Service.

N. Contact Us

If you have any questions about these Terms and Conditions, You can contact us:

By info@Key2DebtFree.com.