Adpool Privacy Policy

Effective April 27, 2026

1. Introduction

Adpool ("Adpool", "we", "us", "our") respects your privacy and is committed to protecting it through compliance with this Policy. Adpool is operated by Mulet Productions LLC, a limited liability company organized under the laws of the State of New Mexico, United States.

This Policy describes how we collect, use, and share personal information when you use the Adpool platform at app.adpoolsystem.com. It applies to organizations that use Adpool to manage their campaigns ("Hosts") and to the authorized users within those organizations ("Members").

When Hosts use Adpool to process information about their own commercial contacts ("leads"), Adpool acts as a data processor on behalf of the Host. The privacy policy applicable to those contacts is the Host's own.

2. Information We Collect

We collect the following information:

Account information. Name, email address, phone number, and organization at the time of registration or invitation.

Payment information. When a Host purchases an Adpool subscription, we receive transaction identifiers from Stripe. We do not store card numbers.

Configuration information. Pool data, member rosters, multipliers, third-party integrations, and notification preferences set by the Host.

Usage information. Login records, pages visited, actions performed, IP address, browser, and operating system.

Lead information (processed on behalf of the Host). Contact data generated by the Host's campaigns (name, email, phone, and other form fields).

Integration information. OAuth access tokens and data synced from third-party services authorized by the Host (e.g., GoHighLevel).

3. How We Use Information

We use information to:

• Operate and maintain the platform
• Assign and distribute leads within pools according to the Host's configuration
• Notify Members of newly assigned leads
• Process subscriptions and bill Hosts
• Detect and prevent fraud, abuse, or violations of our terms
• Improve the platform through aggregated analytics
• Comply with legal obligations

We do not use personal information for off-platform targeted advertising.

4. How We Protect Information

We apply reasonable technical and organizational measures, including encryption in transit (TLS), tenant isolation through Row-Level Security, session-based authentication, audit logs, and periodic rotation of integration tokens.

No technology can guarantee absolute security. In the event of an incident affecting your personal data, we will notify you in accordance with applicable law.

5. When We Share Information

We share information with the following providers that perform services necessary to operate the platform:

We may also share information when:

• You expressly authorize us to do so
• Required by law, subpoena, court order, or competent authority
• Necessary to enforce our terms or protect Adpool's, our users', or the public's rights
• A merger, acquisition, or asset sale occurs, in which case we will provide timely notice

Adpool does not process direct payments between the Host and its Members. Those payments flow through the Host's payment processor and are subject to the Host's and processor's policies.

When a lead is assigned to a Member, we communicate the assigned Member's identity (name and contact phone) to the lead as a transparency measure toward the data subject.

6. Data Retention

We retain information for as long as the account is active or as necessary to provide the service. When an account is deactivated, associated data is retained for a reasonable period for audit, compliance, and dispute resolution purposes, after which it is deleted or anonymized.

Upon the Host's request, we will export or delete lead data under their control within a reasonable timeframe.

7. Children's Information

Adpool is not directed to individuals under 18, and we do not knowingly collect information from minors. If we learn we have received information from a minor, we will delete it.

8. International Data Transfers

Adpool processes information in the United States. By using the platform from another jurisdiction, you consent to the transfer and processing of your information in the United States. We apply contractual clauses and other reasonable safeguards with our providers.

9. Your Privacy Rights

Depending on your jurisdiction, you may exercise the following rights regarding your personal data:

9.1 European Economic Area and United Kingdom (GDPR)

Access, rectification, erasure, restriction of processing, portability, objection, withdrawal of consent, and the right to file complaints with your supervisory authority.

9.2 California (CCPA / CPRA)

The right to know what information we collect, to delete it, to correct it, to opt out of sale or sharing (Adpool does not sell personal information), and not to be discriminated against for exercising these rights.

9.3 Mexico (LFPDPPP)

ARCO rights: Access, Rectification, Cancellation, and Opposition. Requests may be filed before INAI.

9.4 Peru (Law 29733)

Access, rectification, cancellation, opposition, and the right to file complaints before the Peruvian Data Protection Authority.

To exercise any of these rights, write to privacy@adpoolsystem.com from the address registered in your account. We will respond within the timeframes provided by applicable law, generally 30 days.

10. Updates to This Policy

We may update this Policy periodically. We will notify material changes via email to active accounts at least 14 days in advance. The current version will always be available at app.adpoolsystem.com/legal/privacy with the last updated date.

11. How to Contact Us

Mulet Productions LLC 1209 Mountain Road Place NE Albuquerque, NM 87110, USA

Email: privacy@adpoolsystem.com

The Spanish version is the controlling version. This English version is provided for reference only.