PRIVACY POLICY

Elements Tech Solutions

A business unit of 4 Elements Hospitality, LLC

Effective Date: October 1, 2026

Last Updated: October 1, 2026

1. WHO WE ARE AND WHAT THIS POLICY COVERS

1.1About Us. Elements Tech Solutions is a business unit of 4 Elements Hospitality, LLC (together, "Elements Tech Solutions," "we," "us," or "our"). We design and build automation, agentic AI systems, growth and content engines, custom software, and systems audits for businesses.

1.2Services Covered. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you (a) visit www.elementstechsolutions.com or any of its subdomains (the "Website"); (b) create an account for or use Lumen, our AI news digest and community board (the "Lumen Service"); (c) submit an inquiry or booking request through the Website; or (d) receive our newsletters and marketing emails. We refer to all of these together as the "Services."

1.3What This Policy Does Not Cover. This Privacy Policy does not govern personal information that our clients provide to us, or that we process on a client's behalf, while we perform paid services under a written services agreement ("Client Data"). Client Data is governed by the services agreement with that client, and the client's own privacy notice governs its relationship with the individuals whose data it shares with us. This Privacy Policy also does not cover third-party websites or services that link to or from the Services.

1.4Controller. For purposes of the European Union General Data Protection Regulation ("GDPR"), the GDPR as retained in the law of the United Kingdom ("UK GDPR"), and similar laws, 4 Elements Hospitality, LLC is the controller of the personal information described in this Privacy Policy. You may contact us at any time using the details in Section 16.

2. INFORMATION WE COLLECT

2.1Information You Provide to Us.

1. (a)Inquiry and booking form. When you contact us or request a consultation through the Website, we collect your name, email address, company name, phone number, the service you are interested in, and the contents of your message.
2. (b)Lumen account. When you create a Lumen account, we collect your name, email address, and password. You may also choose to add profile information. When you use the community board, we collect the posts, comments, replies, and other content you submit ("Community Content").
3. (c)Newsletters and marketing emails. When you subscribe to our newsletter or marketing emails, we collect your email address and, if you provide it, your name.
4. (d)Communications. When you email us or otherwise communicate with us, we collect the contents of those communications and any information you choose to include.

2.2Information We Collect Automatically. When you use the Services, we and our service providers automatically collect certain information about your device and your use of the Services, including your IP address, browser type and version, operating system, device type, referring website, pages viewed, links clicked, the date and time of your visit, and approximate location derived from your IP address (city, region, and country, not precise location). We collect this information through server logs, cookies, and similar technologies as described in Section 6. When you open or click our marketing emails, our email provider records whether and when you opened the email and which links you clicked.

2.3Information We Obtain From Other Sources. We supplement the information described above with business contact and company information that we obtain from publicly available sources, including company websites, professional networking profiles, business directories, and public filings, and from commercial business data providers. We gather and organize this information using our own proprietary research tools. This information may include your job title, employer, company size, industry, business location, business email address, business phone number, and links to your professional social media profiles. We also use these sources to identify business contacts who have not yet interacted with us, so that we may contact them about services that may be relevant to their business.

2.4Sensitive Information. We do not ask for, and you should not submit through the Services, any government identification numbers, financial account numbers, health information, or other sensitive personal information. The only sensitive personal information we collect, as that term is defined under California law, is your Lumen login email and password, which we use solely to provide and secure your account.

3. HOW WE USE INFORMATION

3.1Purposes. We use personal information for the following purposes:

1. (a)to respond to your inquiries, schedule consultations, and prepare proposals for services you request;
2. (b)to create and maintain your Lumen account, deliver the Lumen digest, operate the community board, and send you service-related messages about your account;
3. (c)to send newsletters, marketing emails, and information about our services, subject to your right to opt out under Section 7;
4. (d)to research, qualify, and prioritize business leads, including by combining information you provide with information from the sources described in Section 2.3;
5. (e)to measure and analyze how visitors use the Services, and to improve the Website, the Lumen Service, and our offerings;
6. (f)to protect the security and integrity of the Services, detect and prevent fraud, spam, and abuse, and enforce our Terms of Use;
7. (g)to comply with applicable law, respond to lawful requests, and establish, exercise, or defend legal claims;
8. (h)to create de-identified or aggregated information as described in Section 3.3; and
9. (i)for any other purpose we describe to you at the time we collect the information, or with your consent.

3.2Use of AI Tools. We use artificial intelligence tools provided by third-party service providers to help operate the Services, including to research companies, summarize and route inquiries, draft responses that a person at Elements Tech Solutions reviews, and generate the Lumen digest. If we offer an AI chat assistant on the Website, messages you send to that assistant will be processed by these providers to generate responses, and we will identify the assistant as an AI tool when you use it. We engage these providers to process personal information on our behalf and not for their own independent purposes. We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

3.3De-identified and Aggregated Information. We may de-identify or aggregate personal information so that it no longer reasonably identifies you, and use that information for any lawful business purpose, including analyzing trends, benchmarking, and developing and improving our tools, models, and services. We maintain and use de-identified information in de-identified form and do not attempt to re-identify it, except as permitted by law to test our de-identification processes.

4. LEGAL BASES FOR PROCESSING (EEA, UK, AND SWITZERLAND)

4.1If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases:

1. (a)Contract. To provide the Lumen Service to you under our Terms of Use, and to take steps you request before entering into a services agreement, such as responding to a consultation request.
2. (b)Legitimate interests. To operate, secure, and improve the Services; to research and contact business prospects; to send business-to-business marketing where consent is not required; and to establish, exercise, or defend legal claims. We rely on legitimate interests only where those interests are not overridden by your interests and fundamental rights. You may object to this processing at any time under Section 12.4.
3. (c)Consent. To set non-essential cookies, including analytics cookies, and to send marketing emails where applicable law requires consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
4. (d)Legal obligation. To comply with laws that apply to us.

5. HOW WE DISCLOSE INFORMATION

5.1Service Providers. We disclose personal information to service providers that perform services on our behalf and are contractually restricted from using it for any other purpose. These include:

1. (a)Netlify, Inc., which hosts the Website;
2. (b)Google LLC, which provides Google Analytics;
3. (c)Ahrefs Pte. Ltd., which provides Ahrefs Web Analytics;
4. (d)Constant Contact, Inc., which provides our email marketing and contact management platform, where inquiry and lead information is stored;
5. (e)form processing, cloud hosting, database, and authentication providers that process Website form submissions and host and operate the Lumen Service;
6. (f)providers of AI models and related tools described in Section 3.2; and
7. (g)email, file storage, and productivity software providers we use to run our business.

5.2Other Lumen Members. Your name, profile information, and Community Content are visible to other registered members of the Lumen Service. Please do not post anything to the community board that you want to keep private.

5.3Professional Advisors. We disclose personal information to our lawyers, accountants, and other professional advisors as needed for them to advise us, subject to duties of confidentiality.

5.4Legal Requirements and Protection. We disclose personal information when we believe in good faith that disclosure is necessary to comply with law, a court order, or a lawful request by public authorities; to enforce our Terms of Use; or to protect the rights, property, or safety of Elements Tech Solutions, our users, or others.

5.5Business Transfers. If we are involved in a merger, acquisition, financing, reorganization, sale of assets, or a similar transaction, or in preparation for any of these, personal information may be disclosed to or transferred to the other party, subject to this Privacy Policy or protections at least as protective.

5.6With Your Consent. We disclose personal information for any other purpose with your consent or at your direction.

5.7No Sale or Sharing. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising, as those terms are defined under applicable U.S. state privacy laws. We have not done so in the 12 months before the Last Updated date of this Privacy Policy. We do not disclose personal information to third parties for their own direct marketing purposes. We have no actual knowledge of selling or sharing the personal information of anyone under 16 years of age.

6. COOKIES, ANALYTICS, AND SIMILAR TECHNOLOGIES

6.1What We Use. Cookies are small data files stored on your device. We use the following technologies:

1. (a)Essential technologies. Cookies and local storage that are necessary to operate the Website and keep you logged in to the Lumen Service. These cannot be turned off without affecting how the Services work.
2. (b)Google Analytics. Google Analytics uses cookies to collect information about how visitors use the Website, such as pages visited and time spent, and reports that information to us in aggregate form. We configure Google Analytics to retain user-level and event-level data for no longer than 14 months, and we do not enable Google Analytics advertising features. You can learn how Google uses this information at https://policies.google.com/technologies/partner-sites and opt out of Google Analytics by installing the browser add-on at https://tools.google.com/dlpage/gaoptout.
3. (c)Ahrefs Web Analytics. Ahrefs Web Analytics measures Website traffic without placing cookies on your device.
4. (d)Email tracking. Our marketing emails contain small tracking images and tracked links that tell us whether an email was opened and which links were clicked.

6.2Consent. Where required by law, including for visitors in the European Economic Area and the United Kingdom, we ask for your consent before placing non-essential cookies, and you may change your choice at any time through the cookie settings link on the Website.

6.3Your Controls. Most browsers allow you to block or delete cookies through their settings. Blocking essential cookies may prevent parts of the Services from working.

6.4Do Not Track and Global Privacy Control. Some browsers send "Do Not Track" signals. Because there is no common industry standard for these signals, the Services do not respond to them. We honor Global Privacy Control signals as a request to opt out of the sale or sharing of personal information where required by law. Because we do not sell or share personal information, honoring the signal does not change how we process your information today.

6.5Advertising Technologies. We do not currently use advertising cookies, advertising pixels, or similar technologies for targeted advertising. Before we begin using them, we will update this Privacy Policy and provide any notice, consent mechanism, and opt-out tools that applicable law requires.

7. MARKETING COMMUNICATIONS

7.1Opting Out. You may unsubscribe from our newsletters and marketing emails at any time by clicking the unsubscribe link in any marketing email or by emailing us at nicole@elementstechsolutions.com. We will process your request within the time required by law. After you unsubscribe, we keep your email address on a suppression list so that we can honor your choice.

7.2Service Messages. If you have a Lumen account, we will continue to send you service-related messages about your account, including security notices and changes to our terms, even after you opt out of marketing emails. You may stop receiving the Lumen digest by changing your email preferences or deleting your account.

7.3Consent Where Required. Where the law of your location requires your consent before we send commercial electronic messages, including in Canada, the European Economic Area, and the United Kingdom, we send those messages only with your consent or under an exception that applicable law permits.

8. THE LUMEN COMMUNITY BOARD

8.1Visibility. The Lumen community board is open to anyone who creates a Lumen account. Community Content you post, together with your name and profile information, can be viewed by all registered members. Other members may copy or share what you post, and we cannot control what they do with it.

8.2Removing Content. You may delete your own Community Content through the Lumen Service. If you delete your account, we will delete your Community Content or de-identify it by removing your name and profile information, as described in Section 9.1(b). Copies may remain where other members have quoted or reshared your content.

9. HOW LONG WE KEEP INFORMATION

9.1Retention Periods. We retain personal information for as long as needed for the purposes described in this Privacy Policy, and then delete or de-identify it, as follows:

1. (a)Inquiries and leads. Information from inquiries and leads who do not become clients is kept for three years from our last contact with you. If you become a client, your information is governed by your services agreement.
2. (b)Lumen accounts. Account information and Community Content are kept for as long as your account is active. After you delete your account, we delete or de-identify this information within 90 days, except for copies held in routine backups, which are overwritten in the ordinary course.
3. (c)Email subscribers. Subscriber information is kept for as long as you remain subscribed. After you unsubscribe, we keep only the information needed to maintain our suppression list.
4. (d)Analytics. Google Analytics user-level and event-level data is retained for no longer than 14 months.

9.2Exceptions. We may keep information longer where required by law, to resolve disputes, to enforce our agreements, or to preserve evidence related to a legal claim.

10. SECURITY

10.1We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, and disclosure. These include encryption of data in transit and access controls that limit who can view personal information. No method of transmission over the internet or of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your Lumen password confidential. If we learn of a security breach affecting your personal information, we will notify you and the relevant authorities as required by applicable law.

11. INTERNATIONAL DATA TRANSFERS

11.1We are based in the United States, and we and our service providers process personal information in the United States and other countries. Those countries may have data protection laws that differ from the laws of your country. When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to a country that has not been found to provide an adequate level of protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or the recipient's certification under the EU-U.S. Data Privacy Framework, the UK Extension, or the Swiss-U.S. Data Privacy Framework, as applicable. You may request information about these safeguards by contacting us.

12. YOUR PRIVACY RIGHTS

12.1Choices Available to Everyone. Wherever you are located, you may update your Lumen profile at any time, unsubscribe from marketing emails under Section 7, delete your Lumen account, and ask us to delete inquiry information you submitted through the Website.

12.2United States Residents. Depending on the state where you live, including California, Colorado, Connecticut, Oregon, Texas, Utah, Virginia, and other states with comprehensive consumer privacy laws, you may have some or all of the following rights, subject to exceptions under applicable law:

1. (a)to know whether we process your personal information and to access the personal information we hold about you, including the categories and specific pieces of personal information collected;
2. (b)to correct inaccurate personal information;
3. (c)to delete personal information we collected from or about you;
4. (d)to receive a copy of your personal information in a portable format;
5. (e)to opt out of the sale or sharing of personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects (we do not engage in any of these activities);
6. (f)to limit the use of sensitive personal information (we use sensitive personal information only for purposes that do not give rise to this right); and
7. (g)not to receive discriminatory treatment for exercising any of these rights.

If we deny your request, you may appeal our decision by replying to our response or emailing us with the subject line "Privacy Appeal." We will respond to your appeal within the time required by law. If your appeal is denied, you may contact the attorney general of your state.

12.3Additional Information for California Residents. The table below describes the categories of personal information we have collected in the 12 months before the Last Updated date, as defined in the California Consumer Privacy Act, as amended. We collect this information from the sources described in Section 2, use it for the purposes described in Section 3, and retain it for the periods described in Section 9. We have disclosed each category for a business purpose to the recipients listed below. We have not sold or shared any category.

California residents may also designate an authorized agent to submit a request on their behalf, as described in Section 12.6. We do not disclose personal information to third parties for their direct marketing purposes, as described in California Civil Code Section 1798.83.

12.4EEA, UK, and Swiss Residents. You have the right to access, correct, and erase your personal information; to restrict or object to our processing of it; to data portability; and to withdraw consent at any time where we rely on consent. You have an absolute right to object to our use of your personal information for direct marketing. You also have the right to lodge a complaint with the data protection supervisory authority in the country where you live or work or where an alleged infringement occurred.

12.5Canadian Residents. You have the right to access and correct the personal information we hold about you and to withdraw your consent to our collection, use, or disclosure of it, subject to legal and contractual restrictions. You may file a complaint with the Office of the Privacy Commissioner of Canada.

12.6How to Exercise Your Rights. To exercise any of these rights, email us at nicole@elementstechsolutions.com with the subject line "Privacy Request." We will verify your identity before responding, typically by confirming that you control the email address associated with your information or your Lumen account. You may use an authorized agent to submit a request on your behalf. We will require the agent to provide your signed written permission, and we may ask you to verify your identity directly. We will respond within the time required by applicable law, which is generally 45 days under U.S. state laws and one month under the GDPR and UK GDPR, subject to extensions that the law permits.

13. CHILDREN

13.1The Services are intended for business professionals and are not directed to children. The Website is not directed to children under 13, and the Lumen Service is available only to individuals who are at least 18 years old. We do not knowingly collect personal information from anyone under 18 through the Lumen Service or from any child under 13 through the Website. If we learn that we have collected personal information in violation of this Section 13, we will delete it. If you believe a child has provided us with personal information, please contact us at nicole@elementstechsolutions.com.

14. THIRD-PARTY LINKS AND CONTENT

14.1The Services, including the Lumen digest, contain links to third-party websites, articles, and services. We are not responsible for the privacy practices of those third parties. We encourage you to read the privacy policy of every website you visit.

15. CHANGES TO THIS PRIVACY POLICY

15.1We may update this Privacy Policy from time to time. When we do, we will post the updated version on the Website and change the Last Updated date at the top of this Privacy Policy. If we make material changes, we will notify Lumen members by email and post a notice on the Website before the changes take effect. Where applicable law requires your consent to a change, we will ask for it.

16. CONTACT US

16.1If you have questions about this Privacy Policy or our privacy practices, or wish to exercise your rights, contact us at:

Elements Tech Solutions, a business unit of 4 Elements Hospitality, LLC

Email: nicole@elementstechsolutions.com

Website: www.elementstechsolutions.com