Global Privacy Policy

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Effective Date: 17 September 2025
Operator: Clearman Labs LLC dba Matador
Address: 1835 38th St. Unit A, Boulder, CO 80301, USA
Contact Email: privacy@matadorequipment.com

1. PURPOSE
This Global Privacy Policy (“Privacy Policy”) describes our data practices with regard to your Personal Information, including the kinds of information we collect, how we collect, use, disclose, and retain that information, and how you can exercise choice regarding that information. "Personal Information" means any information relating, or reasonably capable of being linked, to you.

This Privacy Policy applies globally. It covers users located in the United States, the European Economic Area (EEA), the United Kingdom (UK), Switzerland, and other jurisdictions where applicable. Your use of Matador’s websites, products, services, and related offerings (collectively, the “Services”) is also governed by our Terms and Conditions.

2. TYPES OF INFORMATION WE COLLECT AND HOW WE USE IT
The following table provides the categories of Personal Information we may collect, the categories of recipients, the business or commercial purposes for use, and our retention criteria. This serves as our “Notice at Collection” for California residents and applies globally to provide transparency.

Category of Personal Information	Examples & Sources	Purposes of Use / Disclosure	Retention
Identifiers	Name, email, phone, postal address, account login; collected directly from you during account creation, purchase, or communication.	Provide and manage Services; process transactions; ship orders; verify identity; customer service; marketing with consent; comply with legal obligations.	Retained as long as necessary to provide Services, fulfill legal/tax/accounting requirements (generally 7 years for transactions).
Commercial / Transactional Information	Records of products/services purchased or considered, order history, payment details (via secure processors).	Fulfill purchases; process returns; provide customer support; detect/prevent fraud; personalize Services; marketing with consent.	7 years minimum for financial/transaction records, longer if required by applicable law.
Internet / Electronic Network Activity	Browsing history, interactions with our site, IP address, cookie IDs, device/browser information, approximate geolocation (via IP).	Improve and personalize Services; analytics; targeted advertising; detect and prevent fraud/security incidents; legal compliance.	Typically retained for 24 months or shorter if anonymized/aggregated; longer if required by security needs.
Demographic Information	Age, gender, region (where provided voluntarily or inferred).	Personalize Services; ensure legal eligibility (e.g., age requirements); analytics.	Retained as long as associated with your account or until deletion request.
User-Generated Content	Product reviews, survey responses, customer support communications, uploaded media.	Display on Services; improve products; marketing with consent; enforce Terms of Service.	Retained until deleted by user or until no longer necessary for business/legal needs.
Inferences	Profiles drawn from other categories (e.g., purchasing tendencies, product preferences).	Improve Services; personalize marketing; research and development.	Retained as long as reasonably necessary for business purposes, typically not exceeding 2 years.
Sensitive Information	Payment card details (processed via third-party processors); government ID if required for prize fulfillment or fraud prevention.	Transaction processing; fraud prevention; legal compliance.	Sensitive identifiers are not stored by us directly, except limited information for compliance; retained only as long as required by law.

3. YOUR PRIVACY CHOICES
Depending on your location, you may have rights under laws such as the GDPR (EU/UK/Swiss), the California Consumer Privacy Act as amended by the CPRA (California), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act. These rights may include:

• Right to Know / Access: Information about what data we collect, use, or disclose.
• Right to Portability: Obtain a copy of your data in portable format.
• Right to Correct: Request correction of inaccurate information.
• Right to Delete: Request deletion of data, subject to exceptions.
• Right to Opt-Out: Prevent sales, sharing, or targeted advertising using your data.
• Right to Limit Sensitive Personal Information: Restrict certain uses of sensitive data.
• Right to Object / Restrict (GDPR): Object to or restrict certain processing.
• Right to Non-Discrimination: Exercise rights without discriminatory treatment.

To exercise rights: 

• Use our webform at https://www.matadorequipment.com/pages/cookie-preferences
• Email us at privacy@matadorequipment.com
• EU/UK/Swiss residents may also contact us to exercise GDPR rights.

We will verify requests as required by law. If we deny your request, you may appeal our decision by contacting us at privacy@matadorequipment.com within 30 days. We will respond in writing within 60 days with our decision.

You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent's permission to do so and may verify your identity directly.

4. COOKIES AND TRACKING TECHNOLOGIES
We and the third parties we work with use cookies and other tracking technologies in connection with the Services, as described below:

• Cookies. Cookies are small text files placed on your browser when you visit a website, open or click on an email, or interact with an advertisement. Our Services use session cookies (which expire when you close your browser) and persistent cookies (which expire at a set expiration date or when you manually delete them). We incorporate both first party cookies (which are cookies served directly by us) and third party cookies (which are cookies served by third parties we work with).
• Pixel. A pixel (also known as a web beacon) is a piece of code embedded within a service. There are various types of pixels, including image pixels (which are one-pixel transparent images) and JavaScript pixels (which contain JavaScript code). Pixels are often associated with cookies and are used for similar purposes. When you access a service that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser, or collect other information about your browser or device.

We use such tracking technologies for the following purposes:

• Strictly Necessary. These tracking technologies are necessary for the operation of our Services, such as making our websites work, identifying irregular website behavior, preventing fraudulent activity and assisting with security, saving searches, and filling out forms.
• Performance-Related. These tracking technologies allow us to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our websites, determine whether you have viewed an item or link, or improve our Services;
• Functionality-Related. These tracking technologies allow us to offer you enhanced functionality when accessing or using our Services, such as identifying you when you sign-in to our Services, keeping track of your specified preferences, interests, items in your cart (including abandoned cart reminders) or past items viewed, or helping us enhance the presentation of content on our Services.
• Targeting-Related. These tracking technologies may be set by us or our advertising partners and allow us to engage in advertising to you. They may be used by those third parties to build a profile of your interests and show you relevant adverts on other sites.
• Cookie Management. You may view cookies in use and make choices about which categories of cookies you accept beyond those that are strictly necessary from the Privacy Choices link in our website footer.

Visitors can manage cookie preferences and opt out of sale/sharing at any time via our Cookie Preference Center at https://www.matadorequipment.com/pages/cookie-preferences.

5. SECURITY
We take reasonable technical, administrative, and physical safeguards to protect Personal Information. However, no system is perfectly secure. If we experience a data breach, we will notify affected individuals and regulators as required by law.

5A. DATA BREACH NOTIFICATION

In the event of a data breach affecting your Personal Information, we will notify you and relevant regulatory authorities as required by applicable law. Our notification will include information about the breach, affected data categories, likely consequences, and steps we are taking to address the incident. For EU/UK/Swiss residents, notifications will be provided within 72 hours of breach discovery where feasible.

6. RETENTION
We retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy, including compliance with legal, tax, and accounting obligations. Criteria for retention vary by category of data, as reflected in the table above.

7. INTERNATIONAL DATA TRANSFERS
If you are located outside the United States, your Personal Information may be transferred to and processed in the U.S. and other jurisdictions where privacy laws may not provide equivalent protection. For transfers from the EEA, UK, or Switzerland, we rely on Standard Contractual Clauses and other lawful mechanisms as required by GDPR.

8. CHILDREN'S PRIVACY
We do not knowingly collect Personal Information from children under 16 (or the age of majority in their jurisdiction). If we become aware that we have collected such data, we will promptly delete it.

9. CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy in our sole discretion, so review it periodically. We will post any changes to this Privacy Policy on this web page, and the revised version will be effective immediately when it is posted. If the changes to this Privacy Policy are material, we may provide additional notice to you, such as by email or prominent notice of the Service. We will maintain an archive of previous privacy policies for your reference upon request

10. CONTACT US
If you have questions about this Privacy Policy or your rights, please contact us:
- By email: privacy@matadorequipment.com
- By mail: Clearman Labs LLC, 1835 38th St. Unit A, Boulder, CO 80301 USA

11. CALIFORNIA
If you are a California resident, please review these additional privacy disclosures, which are in addition to your privacy rights under applicable privacy law in the Your Privacy Choices section of this Privacy Policy. Terms have the meaning ascribed to them in the California Consumer Protection Act as amended by the California Privacy Rights Act ("CPRA"), unless otherwise stated.

NOTICE AT COLLECTION
At or before the time of collection of your personal information, you have a right to receive notice of our data practices. This serves as our notice of our data practices:

• For the categories of personal information we have collected in the past 12 months, see the Types of Personal Information We Collect and How We Collect It section above.
• For the categories of sources from which personal information is collected, see the Types of Personal Information We Collect and How We Collect It section above.
• For details on how long we retain each category of personal information, please see the retention periods set out in the table under Section 2.
• For the specific business and commercial purposes for collecting and using personal information, see the How We Use Your Personal Information section above.
• For the categories of third parties to whom information is disclosed, see the How We Disclose Your Personal Information section above.
• For the criteria used to determine the period of time information will be retained, see the Retention section above.

We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a "sale" or "share" as those terms are defined under the CPRA. A "sale" is broadly defined under the CPRA to include a disclosure for something of value, and a "share" is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: contact identifiers, characteristics or demographics, commercial or transactions information, device identifiers, device information, internet activity, non-precise geolocation data, and inferences drawn from any of the above. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. We do not knowingly sell or share other categories of personal information, including SMS opt-in data or consent status. In addition, we do not knowingly sell or share personal information about consumers under the age of 16. 
Some of the personal information we collect may be considered sensitive personal information under the CPRA. We collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

12. SHINE THE LIGHT
You also have the ability to ask us, once per year and free of charge, for a notice identifying the categories of personal information, as defined by California Civil Code Section 1798.83, we disclose with third parties for their direct marketing purposes and the contact information for such third parties. If you would like a copy of this notice, please email us at privacy@matadorequipment.com.