Last Updated: June 20, 2025

This Privacy Policy applies to your use of the S.O.B.E.R. Method Website (sobermethod.com) and any Services or Systems provided by Rigotti Press, Inc., the owner and provider of this Website. It describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service and informs you about your privacy rights and how the law protects you.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

"Account": means collectively the personal information, Payment Information, and credentials used by Users to access Material and/or any communications System on the Web Site.

"Partner": An entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more equity interest or other securities entitled to vote for election of directors or other managing authority.

"Company": (referred to as "the Company", "We", "Us", or "Our"): Rigotti Press, Inc., 5100 Van Dorn St, Unit 6745, Lincoln, NE 68506, US.

"Content": means any text, graphics, images, audio, video, software, data compilations, and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site.

"Cookies": Small files placed on your computer, mobile device, or any other device by a website, containing details of your browsing history on that website among its many uses.

"Data": means collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems.

"Device": Any device that can access the Service, such as a computer, cellphone, or digital tablet.

"Personal Data": Any information that relates to an identified or identifiable individual.

"Service": means collectively any online facilities, tools, services, or information that Rigotti Press, Inc. makes available through the Web Site either now or in the future.

"Service Provider": Any natural or legal person who processes data on behalf of the Company.

"System": means any online communications infrastructure that Rigotti Press, Inc. makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities, and email links.

"Usage Data": Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).

"User" / "Users": means any third party that accesses the Web Site and is not employed by Rigotti Press, Inc. and acting in the course of their employment.

"Website": means the website that you are currently using (sobermethod.com) and any sub-domains of this site (e.g., learn.sobermethod.com) unless expressly excluded by their own terms and conditions.

2. Data Collected

Without limitation, any of the following Data may be collected:

Personal Data: included but not limited to:

• name;

• job title & profession;

• contact information such as email addresses and telephone numbers (including mobile numbers for SMS communications);

• demographic information such as address, state, province, ZIP/postal code, city, preferences, and interests;

• financial information such as credit/debit card numbers;

Automatically Collected Data: Including but not limited to:

• IP address (automatically collected);

• web browser type and version (automatically collected);

• operating system (automatically collected);

• a list of URLs starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected);

Usage Data: Data collected automatically when using the Service, which may include your Device’s Internet Protocol address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Mobile Data: When you provide your mobile number for SMS or A2P communications, we collect and store this information along with your opt-in consent. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes unless explicitly authorized by you. Information sharing with subcontractors in support services, such as customer service or SMS delivery providers, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

3. Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track activity on our Service and store certain information. The technologies we use may include:

Cookies or Browser Cookies: Small files placed on your Device. You can instruct your browser to refuse all Cookies or indicate when a Cookie is being sent. However, refusing Cookies may limit your ability to use some parts of our Service.

Web Beacons: Small electronic files in our Service and emails that permit the Company to count users who have visited certain pages or opened emails, and for other related website statistics.

Types of Cookies We Use:

Necessary / Essential Cookies: Session Cookies administered by Us to provide services and enable features like user authentication.

Cookies Policy / Notice Acceptance Cookies: Persistent Cookies administered by Us to identify if users have accepted the use of cookies.

Functionality Cookies: Persistent Cookies administered by Us to remember choices you make, such as login details or language preferences.

Tracking and Performance Cookies: Persistent Cookies administered by Third-Parties to track traffic and user behavior to improve the Service.

For more information, please visit our Cookies Policy.

4. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including monitoring usage.

• To manage Your Account and provide access to Service functionalities.

• To perform contracts, such as processing purchases or other agreements.

• To contact You via email, telephone, SMS, or other electronic communications regarding updates, security, or informative communications.

• To provide news, special offers, and general information about goods, services, and events, unless you opt not to receive such information.

• To manage Your requests and attend to Your inquiries.

• To deliver targeted advertising tailored to your interests.

• For business transfers, such as mergers or acquisitions.

• For other purposes, including data analysis, identifying usage trends, and improving our Service, products, services, marketing, and your experience.

Specifically, Data may be used for:

• Internal record keeping

• Improvement of our products/services

• Transmission by email or SMS of promotional materials

• Contact for market research purposes via multiple channels, including SMS

Any personal Data you submit will be retained by Rigotti Press, Inc. for as long as you use the Services and Systems provided on the Website, or longer if required by law.

5. Retention of Your Personal Data

We will retain Your Personal Data only for as long as necessary for the purposes set out in this Policy, or as required by law. Usage Data is retained for internal analysis and may be kept for shorter periods unless needed for security or functionality improvements. Data submitted through communications Systems, including SMS opt-in records, may be retained for up to one year or as required by applicable regulations.

6. Transfer of Your Personal Data

Your information may be processed in locations outside your jurisdiction. We ensure that adequate controls are in place to protect your data during such transfers, in accordance with this Policy and applicable SMS and telecommunications regulations.

7. Delete Your Personal Data

You have the right to delete or request deletion of Your Personal Data. You can manage your information through Your Account settings or by contacting Us. For SMS-related data, you may opt out at any time as outlined in Section 18. We may retain certain information as required by law.

8. Disclosure of Your Personal Data

We may disclose Your Personal Data in the following situations:

Business Transactions: If involved in a merger, acquisition, or asset sale, you will be notified in advance and given the choice to have your Data deleted or withheld.

Law Enforcement: If required by law or in response to valid requests by public authorities.

Other Legal Requirements: To comply with legal obligations, protect rights, prevent wrongdoing, ensure safety, or protect against liability.

Unless obliged or permitted by law, and subject to third-party service provisions, your Data will not be disclosed to third parties, including our affiliates.

9. Security of Your Personal Data

Data security is of great importance to Us. We use commercially acceptable means to protect Your Personal Data with suitable physical, electronic, and managerial procedures, including encryption for SMS-related data where applicable. However, no method is 100% secure, and we cannot guarantee absolute security.

10. Third-Party Services

We may employ third-party Service Providers for matters including payment handling, delivery, search engine facilities, advertising, analytics, and SMS delivery. These providers use Data only to the extent required to perform requested services, within the terms of this Policy. Examples include:

• Google Analytics: Tracks and reports website traffic. Opt-out via the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout).

• Matomo: A web analytics service (https://matomo.org/privacy-policy).

• SMS Providers: Third-party services used to send SMS messages, adhering to strict data protection standards.

11. Email Marketing

We may use Your Personal Data for newsletters and promotional materials. You can opt-out by following unsubscribe instructions in emails or contacting Us at [email protected].

12. Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

PayPal: Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

13. Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service

• Show advertisements for our products and/or services to You on third-party websites or apps

• Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below. The third-party vendors We use are:

Google Ads (AdWords):

Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the

Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser.

Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

14. Children's Policy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

15. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

16. Changes to this Privacy Policy

We may update this Policy as necessary or required by law. Changes will be posted on this page, and you will be notified via email, SMS (if applicable), or a prominent notice on our Service. You are deemed to accept the updated terms on your first use of the Website following the alterations.

17. Your Rights

You have the right to:

• Access, amend, or delete Your Personal Data via Your Account or by contacting Us.

• Restrict our use of Your Data for direct marketing purposes or sharing with third parties.

• Request a copy of Your Personal Data (a small fee may apply).

• Access certain areas of the Website without providing Data, though full Services may require Account information.

• Opt out of SMS communications as detailed in Section 18.

18. SMS and A2P Application Acceptance

SMS Messaging

We may use SMS to communicate with you for various purposes, including but not limited to:

• Sending appointment confirmations and reminders

• Providing account-related updates (e.g., password resets, account status)

• Delivering product or service updates

• Sending marketing and promotional messages (with your prior consent)

• Conducting surveys or market research

Consent: By providing your mobile number during registration, Account setup, or through a specific opt-in process (e.g., texting "JOIN" to our shortcode), you expressly consent to receive SMS messages from us. This consent is not a condition of purchase.

Opt-Out: You may opt out of SMS messages at any time by replying "STOP" to any message you receive or by contacting us at [email protected]. After opting out, you will receive a confirmation message, and no further SMS messages will be sent unless you re-opt in.

Message Frequency: Message frequency may vary depending on your interactions with the Service (e.g., account activity, promotional campaigns). We will not send excessive messages and aim to respect your preferences.

Costs: Message and data rates may apply as determined by your mobile carrier. Please check with your carrier for details.

Data Handling: Your mobile number and SMS opt-in status are stored securely and used solely for the purposes outlined in this Policy. We do not share SMS originator opt-in data or consent with third parties for marketing purposes, though we may use trusted SMS delivery providers to send messages on our behalf.

A2P (Application-to-Person) Communications

Our Service may use A2P messaging to deliver automated SMS messages from our applications to your mobile device. Examples include:

• Two-factor authentication codes

• Transactional notifications (e.g., order confirmations)

• Promotional offers (with your consent)

Consent Process: For A2P communications, we require your explicit opt-in consent, which may be obtained via:

A checkbox during Account creation or profile updatesTexting a keyword (e.g., "START" or "YES") to our designated shortcodeOther clear affirmative actions indicating your agreement

Revoking Consent: You may revoke consent for A2P messages at any time by texting "STOP" to the shortcode from which you received the message, updating your Account preferences, or contacting us directly. Upon revocation, you will no longer receive A2P messages unless you re-opt in.

Compliance: All SMS and A2P messaging complies with applicable laws and regulations, including the Telephone Consumer Protection Act (TCPA) and Cellular Telecommunications Industry Association (CTIA) guidelines.

Support: For assistance with SMS or A2P messaging, including opting in or out, please contact us at [email protected] or reply "HELP" to any message for more information.

19. Contact Us

For questions about this Privacy Policy, including SMS and A2P-related inquiries, contact us at [email protected].