Privacy Policy

1. Introduction

Welcome to LEM ("Local Event Marketplace"). LEM is a connection platform that helps users discover local events and connect with others who are buying or selling items at those events. LEM does not process payments or facilitate financial transactions - all actual buying and selling occurs in-person, off-platform, directly between users.

This Privacy Policy explains how Rocky Stride LLC ("we," "us," or "our") collects, uses, shares, and protects your personal information when you use our mobile application and services.

By using LEM, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree with this policy, please do not use our app.

2. Information We Collect

2.1 Information You Provide Directly

Account Information:

• Email address
• Password (stored securely using industry-standard hashing)

Note: We do not collect phone numbers or dates of birth. This is a deliberate data minimization choice to reduce personal information exposure.

Profile Information:

• Username
• Profile photo (optional)
• Bio or description (optional)

Listing Content:

• Photos of items you post
• Item descriptions, asking prices, and categories
• Event or location where items are available

Note: We do not collect any payment, credit card, or banking information. All transactions occur in-person, off-platform.

Communications:

• Messages you send to and receive from other users
• Reports you submit about other users or listings
• Communications with our support team

2.2 Information Collected Automatically

Device Information:

• Device type and model
• Operating system version
• Unique device identifiers

Usage Information:

• Features you use and actions you take
• Time, date, and duration of your sessions
• Pages and screens you view

Location Information:

• Your device's location when you use the app (only while the app is actively in use)
• We do NOT collect location data when the app is in the background

Network Information:

• IP address
• Mobile network information

2.3 Future Services

We do not currently use third-party analytics or crash reporting services. We anticipate integrating analytics and crash reporting services in the future. Before implementing these services, we will update this Privacy Policy with specific disclosures and provide opt-out mechanisms where technically feasible.

3. How We Use Your Information

Provide Our Services:

• Create and manage your account
• Display your posted items to other users
• Facilitate the claim process (expressing interest in items)
• Enable messaging between users (when available)
• Show you nearby events and listings based on your location
• Track and display event attendance
• Process and display ratings and feedback after confirmed transactions

Note: We do not process payments. All actual transactions occur in-person, off-platform, between users.

Maintain Safety and Security:

• Verify your identity and prevent fraud
• Enforce our Terms of Service
• Investigate reports and violations
• Protect users from harmful or illegal activity

Improve Our Services:

• Understand how users interact with our app
• Fix bugs and technical issues
• Develop new features and functionality

Communicate With You:

• Send service-related notifications
• Respond to your support requests
• Send important updates about our services or policies

4. How We Share Your Information

4.1 With Other Users

• Your public profile information (username, profile photo, bio) is visible to other users
• Your listings (including photos, descriptions, and general location) are visible to other users
• Messages you send are shared with the recipients
• Feedback you leave is visible to other users

4.2 With Service Providers

We may share information with third-party service providers who help us operate our services, including cloud hosting providers. These providers are contractually obligated to protect your information.

4.3 For Legal Purposes

We may disclose your information if required by law or if we believe in good faith that such disclosure is necessary to comply with legal obligations, protect our rights, prevent fraud, or protect user safety.

4.4 Business Transfers

If Rocky Stride LLC is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will provide notice of any material change in ownership.

4.5 We Do Not Sell Your Data

WE DO NOT SELL YOUR PERSONAL INFORMATION. WE NEVER HAVE AND WE NEVER WILL.

Rocky Stride LLC makes the following commitments regarding your data:

• No Sales: We do not sell, rent, lease, or trade your personal information to any third party for any purpose.
• No Data Brokers: We do not share your information with data brokers or advertising networks.
• No Cross-Context Behavioral Advertising: We do not share your information for cross-context behavioral advertising purposes.
• Applies to All Users: This commitment applies equally to all users, including Minor Users (ages 13-17) and Adult Users (18+).

This is a core principle of how we operate. If we ever consider changing this policy, we will provide clear advance notice and obtain your explicit consent before any such change takes effect.

5. Data Retention

We retain your personal information only as long as necessary for the purposes described in this Privacy Policy.

Retention Periods:

• Account Information: Duration of account + 2 years after deletion
• Profile Information: Deleted within 30 days of account deletion
• Listing Content: Deleted within 30 days of removal or account deletion
• Messages: Retained until both users' accounts are deleted + 2 years
• Location Data: Not persistently stored; used in real-time only
• Device/Usage Information: 12 months rolling
• IP Addresses: 90 days
• Reports and Moderation Records: 5 years
• Claim/Confirmation History and Reviews: Duration of account + 3 years

Data may remain in encrypted backup systems for up to 90 days after deletion from active systems.

6. Your Rights and Choices

Access: View your profile, listings, and messages in the app, or request a copy of all personal information we hold about you.

Correction: Update your profile information through the app settings, or request correction of inaccurate information by contacting us.

Deletion: Delete your account through Menu > Delete Account, or request deletion of specific data by contacting us.

Data Portability: Request a copy of your data in a commonly used, machine-readable format. We will provide your data within 45 days.

Opt-Out Rights: Disable location tracking, push notifications, or unsubscribe from marketing communications at any time.

How to Exercise Rights:

Email: support@joinlem.com or privacy@joinlem.com

We will verify your identity before processing requests and respond within 45 days.

7. Data Security

We implement reasonable technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (HTTPS)
• Secure password storage using industry-standard hashing
• Access controls limiting who can access user data
• Regular security reviews

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8. Children's Privacy and Minor Users

8.1 Age Requirements and COPPA Compliance

LEM is not directed at or intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

If You Are Under 13: Please do not use LEM or provide any information to us.

If You Are a Parent or Guardian: If you believe your child under 13 has provided personal information to us without your consent, please contact us immediately at support@joinlem.com. We will promptly investigate, delete the information, and terminate any account created by the child.

8.2 Minor Users (Ages 13-17)

Users between the ages of 13 and 17 ("Minor Users") may create accounts and use LEM with limited functionality. Minor Users can browse events, search for items, view item listings, and indicate event attendance, but cannot post items, claim items, or access any messaging features.

Data We Collect from Minor Users:

• Account information (email, username, password)
• Device and usage information necessary to provide browsing functionality
• Location data (only while the app is actively in use, to show nearby events and items)
• Event attendance preferences

Data We Do NOT Collect from Minor Users:

• Phone numbers (we do not collect phone numbers from any user)
• Date of birth (we use a simple checkbox verification to minimize PII)
• Payment or financial information (we do not collect this from ANY user - all transactions occur off-platform)
• Claim or transaction history (Minor Users cannot claim items or participate in transactions)
• Messaging data (Minor Users are completely prohibited from sending or receiving messages through the platform)

8.3 Age Verification and Data Minimization

To protect user privacy, we do not collect or store dates of birth. During registration, users are asked to confirm whether they are 18 years or older via a checkbox. Users who do not check this box are classified as Minor Users with restricted access. This approach minimizes the collection of sensitive personal information while still enforcing age-appropriate access controls.

8.4 Parental Rights

Parents or guardians of Minor Users may:

• Request access to their child's account information
• Request deletion of their child's account and associated data
• Contact us at support@joinlem.com with any privacy concerns regarding their minor child's use of LEM

9. International Data Transfers

LEM is operated by Rocky Stride LLC from the United States. Your personal information will be transferred to, stored, and processed in the United States.

Safeguards We Implement:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments
• Contractual data protection requirements for service providers

By using LEM, you acknowledge that your data will be processed in the United States, where data protection laws may differ from your home jurisdiction.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights:

Right to Know: Request information about the categories and specific pieces of personal information we have collected.

Right to Delete: Request deletion of your personal information, subject to certain legal exceptions.

Right to Correct: Request correction of inaccurate personal information.

Right to Opt-Out of Sale/Sharing: We do not sell your personal information and we never will. We do not share your personal information for cross-context behavioral advertising. This applies to all users, including users ages 13-17. Because we never sell data, there is no need to opt out - but we honor this right regardless.

Right to Limit Use of Sensitive Personal Information: We collect precise geolocation only when the app is actively open. We do not collect phone numbers. You may limit location use by disabling location permissions in your device settings or contacting us.

Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at privacy@joinlem.com. We will respond within 45 days.

11. EEA, UK, and Switzerland Users (GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, the following additional provisions apply:

Legal Basis for Processing:

• Contract Performance: Processing necessary to provide our services
• Legitimate Interests: Processing for fraud prevention and security
• Consent: Where you have provided explicit consent

Your Rights Under GDPR:

• Access, rectification, erasure, restriction
• Data portability
• Object to processing
• Withdraw consent at any time
• Lodge complaint with your local data protection authority

To exercise these rights, contact us at privacy@joinlem.com. We will respond within 30 days.

12. Texas Residents

If you are a Texas resident, we comply with the Texas Business and Commerce Code regarding data security and breach notification.

Data Security: We implement and maintain reasonable procedures to protect your sensitive personal information.

Breach Notification: In the event of a data breach affecting your sensitive personal information, we will notify you within 60 days of discovery as required by Texas law.

13. Tracking Technologies

App Tracking Transparency (iOS): We currently do not track you across other companies' apps and websites. If we implement such tracking in the future, we will request your permission through Apple's App Tracking Transparency prompt.

Device Identifiers: We may collect device identifiers for security and fraud prevention. We do not currently use the Apple Identifier for Advertisers (IDFA) or engage in cross-app tracking.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

• Update the "Last Updated" date at the top
• Notify you through the app or by email for significant changes
• Post the updated policy in the app

Your continued use of LEM after changes become effective constitutes acceptance of the updated policy.

15. Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us:

Rocky Stride LLC

• General Support: support@joinlem.com
• Privacy Inquiries: privacy@joinlem.com
• Website: joinlem.com

This Privacy Policy is effective as of January 16, 2026.

Copyright 2026 Rocky Stride LLC. All rights reserved.