PART ONE — PRIMARY PRIVACY POLICY

1. INTRODUCTION AND SCOPE

This Privacy Policy explains how Freezbone Inc., doing business as Freezbone Club ("Freezbone," "we," "us," or "our"), collects, uses, shares, and protects personal information when you visit or use the Freezbone Club website and related online services (the "Site"), purchase our products, create an account, or enroll in the Freezbone Club membership program (the "Membership Program"). This document is the "Primary Privacy Policy" referred to in our Messaging Service Privacy Policy, which is set out in Part Two below and governs our SMS/MMS text messaging program. By using the Site, you acknowledge that you have read and understood this Privacy Policy.

2. PERSONAL INFORMATION WE COLLECT

We collect the following categories of personal information:

• Identity and contact information. Name, email address, phone number, and billing and shipping addresses.

• Order information. Products purchased, order history, order value, delivery details, and communications about your orders.

• Payment information. Payments are processed by our third-party payment processors (such as Shopify Payments and PayPal). We do not collect or store full payment card numbers on our own systems; we receive limited payment details such as card type, last four digits, and confirmation of payment.

• Account information. Username, password (stored in hashed form by our platform provider), account settings, and preferences.

• Membership information. Your Membership plan (quarterly or annual), enrollment date, renewal dates, billing history, Membership status, benefit usage, and cancellation or pause history.

• Communications. The contents of emails, texts, chat messages, reviews, survey responses, and customer service interactions, along with related metadata.

• Usage and device information. IP address, browser and device type, operating system, pages viewed, links clicked, referring pages, approximate location derived from IP address, and similar analytics data collected automatically through cookies and similar technologies.

• Marketing information. Your marketing preferences, engagement with our emails and texts, and information you provide when participating in contests, sweepstakes, quizzes, surveys, or promotions.

• Inferences. Preferences and characteristics inferred from the information above, used to personalize your experience and our marketing.

3. HOW WE USE PERSONAL INFORMATION

We use personal information to:

• Process, fulfill, and deliver your orders, and provide order confirmations and shipping updates;

• Operate the Membership Program, including enrolling you, delivering Membership benefits, processing recurring Membership charges, sending renewal reminders and billing notices, and processing cancellations;

• Create and maintain your account and authenticate you;

• Provide customer support and respond to your requests;

• Send marketing communications (email and, where you have opted in, SMS), and personalize the content and offers you see;

• Operate, analyze, maintain, secure, and improve the Site, our products, and the Membership Program;

• Detect and prevent fraud, abuse, and security incidents, and enforce our Terms and Conditions;

• Comply with legal obligations, including tax, accounting, and consumer protection requirements; and

• Generate aggregated or de-identified data, which is no longer personal information and which we may use and share for any lawful purpose.

4. HOW WE SHARE PERSONAL INFORMATION

We share personal information with the following categories of recipients:

• E-commerce platform. Our Site and store are hosted on Shopify, which processes order, account, and payment data on our behalf.

• Payment processors. Third-party payment processors that handle your payment transactions and recurring Membership billing.

• Marketing and communications providers. Email and SMS marketing platforms (such as Klaviyo and our SMS platform providers) that send communications on our behalf and measure engagement.

• Advertising partners. Advertising and analytics partners (such as Meta, Google, and TikTok) that use cookies, pixels, and similar technologies on the Site to measure ad performance and show you ads for our products on other sites and apps. This activity may constitute "sharing" or a "sale" of personal information under certain state privacy laws — see Section 6 for your opt-out rights.

• Shipping and fulfillment providers. Carriers (such as USPS, DHL, and FedEx) and fulfillment partners that deliver your orders.

• Service providers. Vendors that provide customer support tools, website analytics, fraud prevention, security, data hosting, and similar services under contractual confidentiality obligations.

• Professional advisors. Lawyers, accountants, auditors, and insurers where reasonably necessary.

• Legal and safety. Government authorities or other parties where required by law, subpoena, or legal process, or where disclosure is necessary to protect our rights, our customers, or others, or to detect and prevent fraud.

• Business transfers. A buyer or successor in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, in which case personal information may be transferred as a business asset.

We do not sell personal information in exchange for money. We do not knowingly sell or share the personal information of consumers under sixteen (16) years of age.

5. COOKIES AND ADVERTISING TECHNOLOGIES

We and our partners use cookies, pixels, tags, and similar technologies on the Site. These fall into four general categories: (a) strictly necessary cookies required for the Site and checkout to function; (b) functional cookies that remember your preferences; (c) analytics cookies that help us understand how the Site is used; and (d) advertising cookies and pixels that enable interest-based advertising as described in Section 4. You can control cookies through your browser settings, and you can opt out of interest-based advertising as described in Section 6. Blocking some cookies may affect Site functionality, including checkout.

6. YOUR PRIVACY CHOICES

• Opt out of "sale"/"sharing" for targeted advertising. You may opt out of the disclosure of your personal information to advertising partners for cross-context behavioral (targeted) advertising by using the "Your Privacy Choices" (or "Do Not Sell or Share My Personal Information") link in the footer of the Site, or by contacting us at team@freezbone.com. We also honor opt-out preference signals, such as the Global Privacy Control (GPC), transmitted by your browser, as required by applicable law.

• Email marketing. You may unsubscribe from marketing emails at any time using the unsubscribe link in any marketing email. We will still send transactional emails, such as order confirmations and Membership billing and renewal notices.

• Text messages. You may opt out of marketing text messages at any time by replying STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any message, as described in the Messaging Service Privacy Policy in Part Two.

• Cookies. You can manage cookies through your browser settings and, where offered, our cookie preferences tools.

• Account information. You can review and update your account and Membership information at any time by logging into your account or contacting us.

7. U.S. STATE PRIVACY RIGHTS

Depending on where you live, state privacy laws — including those of California, Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and other states — may give you some or all of the following rights with respect to your personal information:

• Right to know / access. To confirm whether we process your personal information and to access it, including the categories collected, the purposes, and the categories of third parties to whom it is disclosed.

• Right to deletion. To request deletion of your personal information, subject to legal exceptions (for example, records we must keep for tax, accounting, order fulfillment, or fraud prevention purposes).

• Right to correction. To request correction of inaccurate personal information.

• Right to portability. To obtain a copy of personal information you provided to us in a portable format.

• Right to opt out. To opt out of the "sale" or "sharing" of personal information and of targeted advertising, as described in Section 6. We do not use personal information for profiling in furtherance of decisions that produce legal or similarly significant effects.

• Right to non-discrimination. We will not discriminate against you for exercising any of these rights.

To exercise any of these rights, contact us at team@freezbone.com or (833) 272-6080. We will verify your request using information associated with your account or orders, such as your email address or phone number; we may request additional information where necessary to verify your identity. You may designate an authorized agent to submit a request on your behalf; we will require proof of the agent’s authority and may still verify your identity directly. If we decline to act on your request, you may appeal by replying to our decision with the word "Appeal," and residents of certain states may contact their state attorney general if the appeal is denied. We will respond within the time required by applicable law.

Supplemental Notice for California Residents

In the preceding twelve (12) months, we have collected the categories of personal information described in Section 2, from the sources and for the purposes described in Sections 2 and 3, and disclosed them as described in the table below. The "advertising partners" disclosures may constitute "sharing" (and, under some interpretations, a "sale") under the California Consumer Privacy Act, as amended ("CCPA"). California residents may exercise the rights described above, including the right to opt out of sale/sharing and the right to limit the use of sensitive personal information (we do not collect sensitive personal information as defined by the CCPA beyond account log-in credentials maintained by our platform provider).

Category of Personal Information	Disclosed To
Identifiers (name, email, phone, address, IP address)	Service providers; advertising partners (sharing)
Customer records (Cal. Civ. Code § 1798.80(e)) — contact and limited payment details	Service providers (including payment processors)
Commercial information (orders, Membership plan and billing history)	Service providers; advertising partners (sharing)
Internet or other electronic network activity (Site usage, engagement)	Service providers; advertising partners (sharing)
Approximate geolocation (from IP address)	Service providers; advertising partners (sharing)
Inferences (preferences and characteristics)	Service providers

8. MEMBERSHIP AND ACCOUNT DATA

If you enroll in the Membership Program, we process your Membership information (plan, renewal dates, billing history, and status) for as long as your Membership is active in order to provide benefits, process recurring charges, and send required billing and renewal notices. When you cancel your Membership or close your account: recurring billing authorizations are deactivated with our payment processors; we stop sending marketing communications upon request; and we retain order, billing, and Membership records as needed for tax, accounting, dispute resolution, fraud prevention, and other legal purposes, after which they are deleted or de-identified in accordance with Section 9.

9. DATA RETENTION

We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy. In determining retention periods, we consider: the duration of our relationship with you (including active accounts and Memberships); our legal obligations (such as tax and accounting record-keeping requirements); the need to maintain records for warranty, dispute, and fraud prevention purposes; and applicable statutes of limitation. When personal information is no longer needed, we delete it or de-identify it.

10. SECURITY

We implement and maintain reasonable technical and organizational measures designed to protect personal information from unauthorized access, alteration, disclosure, or destruction, including transport-layer encryption on the Site and reliance on PCI-compliant payment processors for payment card data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

11. CHILDREN’S PRIVACY

The Site is intended for general audiences and is not directed to children under thirteen (13) years of age. We do not knowingly collect personal information from children under thirteen (13). If we learn that we have collected personal information from a child under thirteen (13), we will delete it. We do not knowingly sell or share the personal information of consumers under sixteen (16) years of age.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we do, we will post the updated policy on the Site and revise the "Last Updated" date above, and we will provide additional notice of material changes as required by applicable law. Your continued use of the Site after an updated policy takes effect constitutes your acknowledgment of the updated policy.

13. CONTACT US

If you have questions about this Privacy Policy or our data practices, or wish to exercise your privacy rights, contact us at: Freezbone Inc. d/b/a Freezbone Club.· Email: team@freezbone.com · Phone: (833) 272-6080. (SMS ONLY)

PART TWO — MESSAGING SERVICE PRIVACY POLICY

The following Messaging Service Privacy Policy is preserved in full as previously published. It is strictly limited to the text messaging service and supplements the Primary Privacy Policy in Part One.

Freezbone Messaging Service Privacy Policy

This Messaging Service Privacy Policy explains how Freezbone (hereinafter, "Freezbone," "We," "Us," "Our") collects, uses, and shares personal information about you in relation to Our text message marketing program (the "Messaging Service"). This Messaging Service Privacy Policy supplements Our Primary Privacy Policy. For more details, see the section titled "Primary Privacy Policy" below.

Changes to the Messaging Service Privacy Policy

We may revise this Messaging Service Privacy Policy from time to time in our sole discretion. If there are any material changes to this Messaging Service Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Messaging Service Privacy Policy if you continue to use the Messaging Service after the new Messaging Service Privacy Policy takes effect.

Personal Information We Collect

When you sign up for the Messaging Service, We collect personal information such as your name, phone number, and email address. When you use the Messaging Service to send or receive messages, We collect communications metadata (e.g., the time/date a message was sent or received) and the contents of any communications you send or receive via the Messaging Service.

We may also collect information about you using cookies or similar technologies on Our website or other digital properties. Cookies are small text files placed on device browsers that store preferences and facilitate and enhance your experience. Cookies enable personalization of your experience via the Messaging Service (e.g., sending you personalized text messages such as shopping cart reminders).

If you participate in a contest, sweepstakes, research study, or email survey associated with the Messaging Service, We will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your personal information if you contact Us with questions about the Messaging Service or for customer service.

Use of Personal Information

We use your information to deliver, analyze, maintain and support the Messaging Service. We may also use your information to enhance the Messaging Service features and customize and personalize your experiences on the Messaging Service.

We may use your personal information to generate aggregated and/or de-identified information. Aggregated and/or de-identified information is not personal information and may be shared with any third party, including advertisers, promotional partners, and sponsors.

Accurate Information

When you complete forms online or otherwise provide Us information in connection with the Messaging Service, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in Our sole discretion, We believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Messaging Service for an ulterior purpose, We may refuse you access to the Messaging Service and pursue any appropriate legal remedies.

Choices and Controls

Text messages may be sent via an automatic telephone dialing system. Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of Our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. For additional opt-out information, please review Our Terms of Service.

Customer Care

If you are experiencing any problems with the Messaging Service, please visit https://www.freezbone.com and submit the form with details about your problem or your request for support, or email team@freezbone.com

Supplemental California Privacy Notice

This Supplemental California Privacy Notice only applies to Our processing of personal information via the Messaging Service that is subject to the California Consumer Privacy Act of 2018 ("CCPA"). The CCPA provides California residents with the right to know what categories of personal information We have collected about them and whether We have disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by Us	Categories of Third Parties Personal Information is Disclosed to for a Business Purpose
Identifiers	• Service providers
Personal information categories listed in Cal. Civ. Code § 1798.80(e)	• Service providers
Commercial information	• Service providers
Internet or other electronic network activity	• Service providers
Inferences drawn from other personal information to create a profile about a consumer	• Service providers

The categories of sources from which We collect personal information and Our business and commercial purposes for using personal information are set forth above and in Our primary privacy policy.

Additional Privacy Rights for California Residents

Individual Rights under the CCPA. The CCPA provides California residents with the right to request:

• Access to Personal Information, including obtaining access to or a copy of your personal information.

• Deletion of Personal Information

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact Us at team@freezbone.com. We will process such requests in accordance with applicable laws.

"Sales" of Personal Information under the CCPA. For purposes of the CCPA, unless otherwise stated in Our primary privacy policy, We do not "sell" personal information, nor do we have actual knowledge of any "sale" of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by Us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact Us at team@freezbone.com.

Verification. When you make a request, We will ask you to provide sufficient information that allows Us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address or phone number associated with any personal information We have about you.

Primary Privacy Policy

By signing up to receive text messages from us, you also agree to Our Primary Privacy Policy. This Messaging Service Privacy Policy is strictly limited to the Messaging Service and does not limit or restrict any other privacy policy(ies) that may govern the relationship between you and Us in other contexts. The Primary Privacy Policy is set out in Part One of this document.

Sharing of Personal Information

We may share your personal information as outlined in our primary privacy policy and with your explicit consent. Specifically, personal information collected during your opt-in to our messaging service (such as your phone number, name, or email address) may be shared under the following circumstances:

Third Parties That Help Provide the Messaging Service. We may share your personal information with third-party vendors that assist us in providing our messaging services, including SMS platform providers, phone companies, fraud prevention services, security providers, and other vendors who help us deliver messages, maintain service security, and verify your device and contact information.

Legal Requirements, Disclosures to Protect Us or Others. We may disclose personal information if required by law or to protect our rights and the rights of others.