THE HONOR FOUNDATION PRIVACY POLICY

This Privacy Policy explains the privacy practices of The Honor Foundation (“THF,” “we,” “us,” and “our”). Please read this Privacy Policy carefully to learn how we collect, use, and share information relating to individuals (“Personal Information”), and to learn about your rights and choices regarding your PersonalInformation.

This Privacy Policy applies any time that we collect Personal Information from or about individuals,whether online or offline, including information collected when you participate in our programming or utilize our services and resources through our website, applications that run on mobile devices or tablets,information collected when you communicate with us through phone, email or text messaging, information we collect at our events, and information we collect about you from third parties. THF offers a variety ofprograms, services and an account portal that are collectively referred to as our “Services.” By using any of our Services, visiting our website, applying for or accepting employment with us, or otherwise providingyour Personal Information to us, you understand and acknowledge that we will collect and use personal information as described in this Privacy Policy.

1. PERSONAL INFORMATION WE COLLECT

In conducting every aspect of our business, we may collect Personal Information. Such information may include, without limitation: your name, home and mailing addresses, email addresses, telephone numbers, military service history, history, driving history, criminal and legal history, insurance information, age, gender, billing information, social security number, and other types of Personal Information that you choose to provide to us or that we may obtain about you. We collect Personal Information, as well as non-personal information, in multiple ways:

1.1  Information You Provide to Us: We collect information you provide to us. This may include,
for example, when you use our Services, request information or materials from us, apply to be a mentor or coach, apply to be a faculty member, apply to participate in our programs as a Fellow, apply for or accept employment with us, donate to us, use any of the interactive portions of our website, register on the customer portal, communicate with us, or make purchase products from the THF Store.

1.2  Information We Collect from Other Sources: We may collect information about you from a variety of third parties. For example, we may obtain information about you from:

• • • companies that search for, provide, and/or aggregate information from public records, such as LexisNexis Risk Solutions and Accurint
    • companies that process donations, such as Classy, Inc.;
    • state and federal government agencies, such as the Department of Veteran Affairs, the Department of Defense, and the United States Special Operations Command;
    • social media networks when you grant permission to access your data on one or more networks, tag us in a post, or comment on our posts, videos or photographs;
    • partner organizations such as the Marine Raider Foundation, the Wounded Warrior Project, and the Navy Seal Foundation;
    • companies that provide content for posting on our website, such as ShootProof;
    • former or current participants in our programs, coaches, mentors or faculty; and
    • publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

The foregoing third parties are unaffiliated with us, and we are not responsible for their content or privacy practices. They may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you interact with these third parties.

1.3  Information We Collect Automatically: When you use our Services (i.e. visit our website or use
applications that run on mobile devices or tablets), we collect some information automatically. For example, when you visit our website, we may collect device, usage and log information such as your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, the search engine you used to locate the website, and the website you visited before or after our site. In addition, we gather certain navigational information about where you go on our website to help us determine which areas of the website are most frequently visited and helps us to tailor the sites to the needs and interests of our online visitors. If you use our mobile applications or use our Services on a mobile device or tablet, we may also collect your device type, mobile phone number, operating system type, wireless carrier, and device IDs, on our mobile applications.

We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather this information. When you visit our website, we, or an authorized third party, place or recognize a unique cookie on your browser (including through use of pixel tags). that collects information, including Personal Information, about your online activities over time and across different sites.

We also use web beacons and pixels in our emails to collect information about how you interact with our emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies and the information they collect to operate, evaluate the effectiveness of, and improve our marketing emails.

If you want to remove or block collection technology from your device at any time, you can update your browser settings (consult your browser’s “help” menu to learn how to remove or block cookies and similar technology). You can find instructions on how to manage collection technology on different types of web browsers at www.allaboutcookies.org.

From time to time our interactions with you will be conducted over the telephone or video conference, and such telephone calls and video conferences may be recorded.

2. HOW WE USE PERSONAL INFORMATION

We may use your Personal Information and other information to:

• • •  provide you with Services;
    • manage all aspects of an applicant or employee’s employment relationship, including, but not limited to the establishment, maintenance, and termination of employment relationships.
    • allow creation of an on-line account;
    • process transactions that you have requested;
    • verify your identity;
    • determine your eligibility to serve as a Coach, Mentor, or Instructor;
    • determine your eligibility to participate in our programs as a Fellow;
    • select our Fellows;
    • carry out the purposes for which you provided the information;
    • process any applications, forms, requests, inquiries, or other information you submit;
    • report to our partner organizations;
    • assist in securing post-program employment;
    • secure attendance at events and employer visits;
    • provide customer service;
    • personalize the Services according to your personal preferences;
    • update account information;
    • communicate with you;
    • inform you of events, programs, products or services that may be of interest to you;
    • process and provide a receipt for your donation;
    • conduct data analysis, audits, security and fraud monitoring and prevention;
    • enhance, improve or modify our Services;
    • for use in marketing and advertising;
    • identify usage trends;
    • determine the effectiveness of our marketing and promotional campaigns; and
    • operate and expand our business activities and Services.

We may also use Personal information we have collected and aggregated, or anonymized Personal Information received from third parties, to understand more about our users (for example, we may use aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, inferred commercial interests, and other information we may collect from you or from third parties.

Mobile Messaging: We may use your mobile number to send you service-related announcements when it is necessary (for example, if we must temporarily suspend our service for maintenance). Also, you may choose to receive promotional texts from us based on preferences that you indicate. Participation in mobile messaging is optional and not a condition of purchase. By providing your mobile number and opting in to receive these communications, you are consenting to receive autodialed or prerecorded marketing mobile messages at the phone number associated with your opt-in. The frequency and number of messages you will receive will vary. Message and data rates may apply. You must have a wireless device of your own, capable of two-way messaging, be using a participating wireless carrier, and be a wireless service subscriber with text messaging service. Not all cellular phone providers carry the necessary service to participate. Check your phone capabilities for specific text messaging instructions. While you consent to receive messages sent using an autodialer, the foregoing shall not be interpreted to suggest or imply that any or all of our mobile messages are sent using an automatic telephone dialing system (“ATDS” or “autodialer”). Please consult your mobile service carrier’s pricing plan to determine the charges for browsing data and sending and receiving mobile messages. When you opt-in to the service as noted above, we may send you an SMS message to confirm your signup. Text Messaging Opt-Out: You can cancel the SMS service at any time. Just text “STOP”. After you send the SMS message “STOP” to us, we may send you an SMS message to confirm that you have been unsubscribed. In some cases, you may continue to receive service-related notifications.

We rely on the following legal grounds to process your Personal Information:

• • • Consent. Some uses of your information as described in this Privacy Policy are subject to your consent, such as marketing email communications.
    • Performance of a contract. We may need to collect and use your information to enter into a contract with you and to perform Services that you request.
    • Legitimate Interests. We may use your information for our legitimate interests to provide our website and Services and to improve our Services and website and the content contained thereon. We may use technical information as described in this Privacy Policy and use Personal Information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.
    •  Compliance with Legal Obligations. We may use your Personal Information as necessary to comply with our legal obligations.

3. HOW WE SHARE PERSONAL INFORMATION

We may share your Personal Information as follows.

Service Providers. We may share your Personal Information with third parties who work on behalf of, or with, us such as vendors, processors, suppliers, agents, attorneys, and representatives (collectively, “Service Providers”). Service Providers assist us with a variety of functions including, but not limited to, sending marketing communications, assisting with advertising and related analytics, delivering packages, scheduling and performing maintenance on our websites and applications, processing donations, processing and fulfilling sales of products and merchandise, shipping products and merchandise; conducting research or surveys, sending regular mail and e-mail, maintaining databases, and providing customer service representatives or software.

Partner Organizations. We partner with for-profit and non-profit organizations to serve the special operator community (“Partner Organizations”). These Partner Organizations may share resources with us or provide funding to us. We may share your Personal Information with Partner Organizations so that they may assess our impact and the impact of our programs, our effectiveness, our employment statistics, and the impact of their donation or strategic partnership. They may also use your Personal Information as part of their marketing, advertising, or social impact campaigns. We may also share aggregated or anonymized information with our Partner Organizations. A list of our Partner Organizations is available at https://www.honor.org/our-partners/.

Potential Employers. If you are a Fellow, we may share your Personal Information, including a copy of your resume, with potential employers to assist you in finding employment after your transition out of the military and into the private sector. We may also share your Personal Information if you sign-up to visit the offices of a potential employer so that they may place you on their visitor list and otherwise prepare to
host you as part of our visit.

Coaches, Mentors and Faculty Members. If you are a Fellow, we may share your Personal Information with our coaches, mentors and faculty members so that they may support your participation in our programs.

Government Agencies. We may share your personal information with government agencies such as the Internal Revenue Service.

Disclosures Under Special Circumstances. We may disclose your Personal Information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) when we believe disclosure is necessary to protect or prevent harm, illegal activity, or financial loss; (iii) to detect, investigate and help prevent security, fraud or technical issues; and (iv) to cooperate with law enforcement, government, quasi-governmental and public agency requests or reporting requirements.

Corporate Transactions. We may transfer your Personal Information in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations.

At Your Request. We may share your Personal Information with any individual or entity that you request we share your Personal Information with.

Other than as described in this Privacy Policy, we do not sell your personal information for monetary
consideration.

4. PURCHASES FROM OUR STORE

When you purchase products or merchandise from us, you are directed to a third-party website – Shopify, Google Pay, or PayPal – to process your payment. By entering your Personal Information in the interactive form, you are providing your Personal Information, including your payment information, to the third party who will use that information to process your payment. We will also collect your Personal Information in order to fulfil the order. To do so, we will share your Personal Information with one of our Service Providers who will assist in fulfilling and shipping your order.

5. MAKING A DONATION

We use Classy Inc.’s donation processing services for online donations. When you click on the link on our website to make a donation online, you are directed to a website that is operated by Classy. By entering your Personal Information in the interactive form, you are providing your Personal Information, including your payment information, to Classy which will process your donation and will then provide your Personal Information to THF so that we may issue a receipt for your donation and keep a record of your donation for our files and tax purposes. Your submission of information to Classy is governed by Classy’s privacy policy which is available at: https://www.classy.org/terms/privacy/

6. LINKING TO OTHER SITES

Our website may contain links to other websites that we do not own or operate. We do not control, recommend, endorse or bear any responsibility for these websites or their content, products, services or privacy policies or practices. These other websites may place their own cookies on your device or browser. They may also independently collect information about you or from you and may or may not have their own published privacy policies. The collection and processing of your Personal Information by these third party websites is governed by their own information collection policies and practices and not this Privacy Policy. We are not responsible for the collection and use of your information by such third parties.

7. THIRD-PARTY APPLICATIONS

Third-party applications, such as Instagram, Facebook, Twitter, Pinterest, or Google, may be available on our Sites via buttons or icons. The owners or providers of those third-party applications may collect Personal Information from you. Your interactions with third-party applications on our website may also be shared with others within your social network. The collection of information by these third-party applications is governed by their own information collection policies and practices not this Privacy Policy. We are not responsible for the collection and use of your information by such third parties.

8. ANALYTICS

We partner with certain third parties (in particular, Google Analytics) to collect information about the use of our website and the use of other websites, apps and online resources. These third parties may use server logs, web beacons, tags, pixels, and similar technologies, and they may set and access cookies on your browser. We use the information collected by these third parties to engage in analytics, auditing, research, and reporting. You can read Google’s Privacy Policy, which applies to Google Analytics and the information collected by Google Analytics, at http://www.google.com/intl/en/policies/privacy/. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current browser https://tools.google.com/dlpage/gaoptout.

9. “DO NOT TRACK” DISCLOSURE

We do not collect or respond to Do Not Track signals, and our websites do not function differently based on any Do Not Track preferences that may be received. For more information on Do Not Track signals, please visit https://allaboutdnt.com

10. PROTECTION AND RETENTION OF PERSONAL INFORMATION

We store your information using reasonable physical, technical and administrative safeguards. Please be aware that the Services and data storage are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. In addition, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. We cannot ensure or warrant the security of any information you transmit to us over the internet.

We retain your information for so long as reasonably necessary to fulfill the purposes for which the information was collected and to perform our contractual and legal obligations. We will retain Personal Information to comply with privacy requests, to manage active accounts, as required by law, in order to resolve disputes, or to enforce our agreements. We will retain the Personal Information we process on behalf of our users as directed by them. We may also retain copies of your Personal Information for disaster recovery purposes, to prevent fraud or future abuse, or for our legitimate business purposes. Notwithstanding the generality of the foregoing, we store contact information (e.g., names, addresses, email addresses and phone numbers) until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.

11. CHILDREN

The Website is not designed to solicit information from individuals under the age of 18. We do not knowingly collect or store any personal information from anyone under the age of 18. If we become aware that we have collected or stored personal information from an individual under age 18, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to info@honor.org.

12. MARKETING COMMUNICATIONS

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by contacting us by email at info@honor.org or by following the instructions in any such email you receive from us. We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.

13. INTERNATIONAL DATA TRANSFER

The Services are hosted in the United States and are governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers and databases are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

14. TERMS OF USE

Your use of our Services, as well as any dispute over privacy, are subject to this Privacy Policy and our
Terms and Conditions, https://www.honor.org/terms-and-conditions/, including applicable limitations on
damages and the resolution of disputes.

15. YOUR PRIVACY RIGHTS AND CHOICES

(a) General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction and to which we are subject, which may include the right to request the correction, modification or deletion of your Personal Information, the right to opt out of processing (as applicable), and the right to data portability. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at info@honor.org. Section (b) below describes the rights of those individuals located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union’s General Data Protection Regulation (GDPR).

You may opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at info@honor.org. Some non-marketing ommunications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support related information. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your Personal Information, such as the right to complain to your local data protection authority.

You may be able to disable cookies through your browser settings, but if you delete or disable cookies, you may experience interruptions or limited functionality in certain areas of the website and Services.

(b) Your European Privacy Rights and Choices. If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union’s General Data Protection Regulation (GDPR), your privacy rights include the following:

• • • Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
    • Right of access, correction, restriction of processing, erasure. You may contact us to request information about the Personal Information we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations.
    • Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
    • Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial emails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.
    • Right to data portability. You have the right to data portability of your own Personal Information by contacting us.
    • Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your Personal Information that may negatively impact you.
    • Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to GDPR, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.

16. CHANGES TO THIS PRIVACY POLICY

The Privacy Policy may be revised from time to time. The “Last Updated” legend at the bottom of this page indicates when this Privacy Policy was last revised and became effective. Your use of the Services following these changes means that you accept the revised Privacy Policy.

17. CONTACT US

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at info@honor.org.

Last Updated: February 27, 2025