PRIVACY POLICY

Effective date: July 17, 2026

Last updated: July 17, 2026

1. Overview

This Privacy Policy explains how CAPITAL FUNDS LLC, doing business as AI Operator Academy and, where applicable, ReturnMyTime (collectively, "AOA," "we," "us," or "our"), collects, uses, discloses, and protects personal information when you:

• visit aoa.community or related pages;

• apply for, purchase, access, or participate in the AI Operator Academy;

• use our private community, courses, resources, live office hours, workshops, recordings, or support channels;

• communicate with us by email, form, chat, phone, text message, social media, or another channel; or

• otherwise interact with services that link to this Privacy Policy.

This Privacy Policy applies to our handling of personal information. It does not apply to information that cannot reasonably identify or relate to an individual, or to third-party services that publish their own privacy policies.

2. Who controls your information

The business responsible for the personal information covered by this policy is:

CAPITAL FUNDS LLC

Doing business as AI Operator Academy

Charlotte, North Carolina, United States

Email: [email protected]

For individuals in the European Economic Area, United Kingdom, or Switzerland, this business is the controller of personal information unless a different role is stated at collection.

3. Personal information we collect

The information we collect depends on how you interact with us.

3.1 Information you provide directly

We may collect:

• Identity and contact information: name, email address, telephone number, mailing address, business name, job title, and social profile information.

• Account and membership information: username, profile, login and authentication details managed through our community platform, membership status, course progress, attendance, certifications, and account preferences.

• Transaction information: product selected, price, billing status, transaction identifier, renewal or cancellation status, refund history, and limited payment-related details. Payment card information is generally collected and processed by our payment processor, such as Stripe, rather than stored directly by us.

• Application and survey information: answers submitted through applications, assessments, questionnaires, intake forms, polls, feedback forms, and research activities.

• Community and course content: posts, comments, messages, files, images, audio, video, assignments, questions, feedback, testimonials, and other content you submit.

• Live event information: registration, attendance, chat, questions, participation, and audio or video when you join a recorded office hour, workshop, or other session.

• Support and communications: messages, requests, call notes, support history, and other correspondence.

• Business and workflow information: information you choose to share about your business, clients, processes, tools, goals, results, or service offerings.

Please do not submit client confidential information, personal information about another person, account credentials, regulated health information, payment card data, government identifiers, or other sensitive information unless we specifically request it and you have lawful authority to provide it.

3.2 Information collected automatically

When you use our website or services, we and our service providers may automatically collect:

• IP address and approximate location;

• browser, device, operating system, language, and network information;

• referring and exit pages;

• pages viewed, links clicked, video interactions, form activity, timestamps, and session duration;

• cookie identifiers, advertising identifiers, and similar online identifiers;

• diagnostic, security, fraud-prevention, and performance data; and

• information about how you use course, community, and support features.

We may collect this information through cookies, pixels, tags, local storage, log files, software development kits, and similar technologies.

3.3 Information from other sources

We may receive information from:

• community and course platforms, including Skool;

• website, form, customer relationship management, and automation providers, including GoHighLevel and LeadConnector;

• payment processors, including Stripe;

• video hosting and analytics providers, including Vidalytics;

• security, content-delivery, and website analytics providers, including Cloudflare;

• email, calendar, webinar, scheduling, and communications providers;

• social networks and public sources;

• referral partners and affiliates;

• event partners and guest instructors; and

• other users who invite, mention, or refer you.

Third-party services control their own collection and use of information under their privacy policies.

4. How we use personal information

We may use personal information to:

1. Provide the services: create and administer accounts, process enrollment, deliver courses and resources, operate the community, host live sessions, provide support, and maintain member records.

1. Process payments and membership administration: process purchases, confirm payments, administer renewals, cancellations, refunds, and the 90-day guarantee, prevent fraud, and maintain financial records.

1. Communicate: send service messages, account notices, event reminders, updates, support responses, and information you request.

1. Market our offerings: send promotional email or text messages when permitted, personalize offers, measure campaign effectiveness, and manage preferences and opt-outs.

1. Improve and develop: analyze site, video, community, and course use; troubleshoot; conduct surveys and research; develop curriculum, resources, offers, and features; and create aggregated insights.

1. Protect AOA and others: secure accounts and systems, verify identity, detect abuse, enforce our Terms and community standards, investigate disputes, and protect rights, safety, and property.

1. Comply with law: meet tax, accounting, recordkeeping, consumer-protection, privacy, and other legal obligations; respond to lawful requests; and establish or defend legal claims.

1. Complete business transactions: evaluate or carry out a financing, merger, acquisition, restructuring, sale, or transfer involving some or all of the business or assets.

1. Use with consent: carry out another purpose disclosed when information is collected or that you authorize.

We may create deidentified or aggregated information and use it for lawful purposes. We will not attempt to reidentify information that applicable law requires us to maintain in deidentified form.

5. Legal bases for processing

Where a law requires a legal basis, we rely on one or more of the following:

• Contract: processing needed to provide a membership, product, event, or service you requested.

• Legitimate interests: operating, securing, analyzing, improving, and marketing the business in a manner that does not override your rights.

• Consent: where you give consent, including for certain marketing, cookies, recordings, or optional uses.

• Legal obligation: complying with applicable law, tax, accounting, and lawful requests.

• Legal claims and vital interests: protecting rights, preventing harm, and establishing or defending claims where permitted.

You may withdraw consent at any time, but withdrawal does not affect processing that occurred before withdrawal.

6. How we disclose personal information

We may disclose personal information to:

• Vendors and service providers that host websites, forms, CRM systems, communities, courses, payments, video, email, SMS, scheduling, webinars, analytics, cloud infrastructure, customer support, security, accounting, and professional services.

• Instructors, moderators, contractors, and business partners who need information to deliver the Academy or a related event or service.

• Other community members when you post, comment, message, attend an event, or otherwise make information visible within the community. Your profile and submissions may be visible according to platform settings.

• Referral, affiliate, or promotional partners when you request an introduction, use a partner offer, or consent to the disclosure.

• Professional advisers such as lawyers, accountants, auditors, insurers, and financial advisers.

• Authorities and other parties for legal reasons when reasonably necessary to comply with law, enforce agreements, detect or prevent fraud or security incidents, or protect rights, safety, and property.

• Parties to a business transaction in connection with due diligence, negotiation, or completion of a merger, acquisition, financing, reorganization, bankruptcy, or transfer of assets.

• Others at your direction or with your consent.

Sale, sharing, and targeted advertising

We do not sell personal information for money. We may use advertising pixels, cookies, tags, software development kits, hashed identifiers, and similar technologies to measure campaigns, build or reach advertising audiences, personalize ads, and conduct cross-context behavioral or targeted advertising. Under some U.S. state privacy laws, disclosures to advertising and analytics partners for these purposes may be considered a "sale," "sharing," or "targeted advertising," even when no money changes hands.

Where applicable, you may opt out through the Your Privacy Choices link or cookie-preferences control on our website, or by emailing [email protected] with the subject "Targeted Advertising Opt-Out." We honor legally recognized browser-based opt-out preference signals, including Global Privacy Control, as required by applicable law. An opt-out applies to the browser or device from which it is submitted unless we can associate it with your account. You may need to renew your choice after clearing cookies, changing browsers, or using another device.

Where prior consent is required, including for non-essential advertising cookies in certain jurisdictions, we will not activate those technologies until you opt in. You may withdraw consent at any time through the same preference control. Rejecting advertising technologies will not prevent access to essential website functions or change the price of the Academy.

We do not knowingly sell, share, or use for targeted advertising the personal information of anyone under 18. The Academy is limited to adults age 18 or older.

7. Cookies and similar technologies

Our website, checkout, and community services use or may use cookies, pixels, tags, local storage, software development kits, and similar technologies supplied by website and CRM infrastructure, Skool, Stripe, Vidalytics, Cloudflare, analytics providers, advertising networks, and other vendors. We group these technologies as follows:

• Strictly necessary: site operation, security, authentication, payment, fraud prevention, load balancing, and privacy-choice storage.

• Functional: preferences, enhanced features, and media playback.

• Analytics: traffic, campaign measurement, video engagement, performance, and error diagnosis.

• Advertising: campaign attribution, audience measurement, ad personalization, retargeting, cross-context behavioral advertising, and targeted advertising.

Strictly necessary technologies operate because they are needed to provide the requested service or protect it. Where law requires consent, functional, analytics, and advertising technologies remain off until you make an affirmative choice. The consent interface must offer comparably prominent accept and reject options, allow category-level choices, avoid preselected non-essential categories, and make withdrawal as easy as acceptance.

You can change your choices through the cookie-preferences or Your Privacy Choices link on the website. You may also block or delete cookies in your browser, but some features may not work correctly. We will maintain a current cookie inventory that identifies the provider, purpose, category, and duration of each technology.

8. Marketing communications

You may opt out of marketing emails by using the unsubscribe link in the message or contacting us. You may opt out of marketing text messages by replying STOP or following the instructions in the message. Opting out of marketing does not stop non-promotional messages about your purchase, account, events, security, or support requests.

We will send commercial email and text messages only as permitted by applicable law. Message and data rates may apply to text messages. Consent to marketing texts is not a condition of purchase unless clearly and lawfully disclosed otherwise.

9. Payment information

Payments are processed through third-party payment providers, currently including Stripe. The payment provider may collect payment card, bank, billing, device, and fraud-prevention information under its own privacy terms. We typically receive transaction status, payment method type, and limited billing information rather than complete payment credentials.

10. Community visibility and member responsibilities

The Academy is a community service. Information you place in your profile or post in community spaces may be visible to other members, administrators, moderators, instructors, and platform providers. Other members may copy or retain information you share. Do not post anything you do not want other authorized community participants to see.

If you submit information about another person or a client, you represent that you have a lawful basis and any necessary permission to do so. Use anonymized examples whenever practical.

11. Live sessions, recordings, and testimonials

AOA may record live office hours, workshops, and other member sessions. Recordings will be posted and retained within the private Skool community for authorized member access. We will provide notice in the event invitation, session page, or at the start of the session when recording is active. A recording may capture a member's display name, profile image, voice, video, chat, screen share, questions, and other participation.

By voluntarily speaking, enabling video, posting in the recorded chat, or sharing a screen after receiving notice, you authorize AOA to capture that contribution and make it available within the Skool member archive as part of the Services. If you do not want to be captured, keep your camera and microphone off, do not post identifying information in the recorded chat, and contact the host before participating. Where local law requires additional consent, AOA will request it before recording.

Internal member-archive permission does not authorize public advertising use. AOA will obtain separate, clear permission before using a member's name, image, voice, testimonial, or identifiable results in public advertising, social media, or other promotional materials where required. Participation in the Academy alone does not grant an unlimited promotional-use right.

12. AI tools and member submissions

AOA teaches and may use artificial intelligence tools. If you submit information into an AOA-provided AI feature or ask us to process information with a third-party AI service, that information may be transmitted to the applicable provider. Do not submit confidential client data, personal data, trade secrets, regulated data, or credentials unless the specific workflow has been approved for that information.

AI-generated output may be inaccurate or incomplete. Human review remains required. We may use aggregated or deidentified usage patterns to improve training and resources, but we will not use member confidential content to train a public model without clear notice and any consent required by law.

13. Data retention

We retain personal information only as long as reasonably necessary for the purposes described in this policy, including to provide services, maintain business and transaction records, comply with law, resolve disputes, enforce agreements, and protect security.

Retention periods vary by data type. Relevant factors include the membership relationship, legal limitation periods, tax and accounting duties, guarantee and refund administration, security needs, platform settings, and whether information is contained in backups. When information is no longer needed, we delete, anonymize, or securely isolate it as appropriate.

Before publication, AOA should approve a retention schedule for leads, members, recordings, community content, support communications, marketing records, financial records, and privacy requests.

14. Data security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No system, transmission, or storage method is completely secure. You are responsible for using a unique password, protecting access to your account, and notifying us promptly of suspected unauthorized access.

15. International transfers

We and our providers may process information in the United States and other countries whose data-protection laws may differ from those where you live. Where required, we use an approved transfer mechanism, such as standard contractual clauses, adequacy decisions, or another lawful safeguard.

16. Your privacy rights

Depending on where you live and subject to legal exceptions, you may have the right to:

• know or access personal information we process;

• obtain a portable copy;

• correct inaccurate information;

• delete information;

• restrict or object to certain processing;

• withdraw consent;

• opt out of sale, sharing, targeted advertising, or certain profiling;

• limit certain uses of sensitive personal information;

• appeal a denied privacy request; and

• complain to a regulator or supervisory authority.

To exercise a right, contact [email protected] with the subject "Privacy Request." Describe the right you want to exercise and the email address associated with your relationship with AOA. We may verify your identity and authority before acting. An authorized agent may submit a request where permitted, but we may require proof of authorization and identity.

We will not discriminate against you for exercising an applicable privacy right. We will respond within the period required by applicable law. If we deny a request, we will explain the basis and any available appeal process.

California and other U.S. state notices

Residents of states with comprehensive privacy laws may have rights described above. The categories of information we collect and disclose are described in Sections 3 and 6. Our purposes are described in Section 4. Our retention approach is described in Section 13.

If our advertising activities constitute a sale, sharing, or targeted advertising under applicable law, eligible residents may opt out through the Your Privacy Choices link, a recognized opt-out preference signal such as Global Privacy Control, or an email to [email protected]. Eligible residents may also request access, correction, deletion, portability, limitation of certain sensitive-information uses, and an appeal of a denied request. We will not retaliate or unlawfully discriminate against anyone for exercising a privacy right.

Authorized agents may submit requests where law permits. We may require proof that the agent is authorized and may verify the consumer directly. We will publish any additional jurisdiction-specific metrics, appeal instructions, financial-incentive notices, or sensitive-data disclosures required by law.

EEA, UK, and Switzerland

Where consent is the legal basis for advertising cookies or similar technologies, those technologies will remain inactive until you affirmatively consent. You may withdraw consent at any time without affecting earlier lawful processing. You may contact the competent data-protection authority in your country and may ask us about safeguards used for international transfers.

17. Children's privacy

The website and Academy are intended for adults and are not directed to children. You must be at least 18 years old to purchase or participate. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, contact us so we can investigate and take appropriate action.

18. Third-party links and services

Our services may link to or integrate with third-party websites, software, communities, payment tools, social networks, or AI providers. We do not control their privacy or security practices. Review the privacy policies and terms of each third party before providing information.

19. Changes to this Privacy Policy

We may update this policy to reflect changes in our services, vendors, practices, or legal obligations. We will post the updated policy with a new "Last updated" date. If a change is material, we will provide additional notice when required.

20. Contact us

Questions or privacy requests may be sent to:

CAPITAL FUNDS LLC

Doing business as AI Operator Academy

Charlotte, North Carolina, United States

Email: [email protected]