Privacy Policy

Version 1.1

Effective Date: August 17, 2026

1. INTRODUCTION

The Shepherd Network LLC ("Company," "we," "us," or "our") respects the privacy of individuals who access, use, participate in, subscribe to, purchase from, communicate with, or otherwise interact with our Services.

This Privacy Policy describes how information may be collected, used, disclosed, stored, retained, protected, and otherwise processed in connection with:

TheShepherdNetwork.org

The Shepherd Network

The Fold

The Well

The Upper Room

VerseKey

Shepherd Apparels

newsletters

devotionals

prayer request systems

praise report systems

testimonial systems

ecommerce systems

media channels

future Services

This Privacy Policy should be read together with the Terms of Service, Cookie Policy, Community Rules, Arbitration Procedures Appendix, and other applicable policies.

2. CHILDREN AND MINORS

2.1 Children Under 13

The Services are not intended for children under thirteen (13) years of age.

The Company does not knowingly permit children under thirteen (13) years of age to:

• create accounts

• participate in Communities

• subscribe to Services

• purchase products

• access VerseKey memberships

• submit User Content

utilize restricted Services.

If the Company becomes aware that information relating to a child under thirteen (13) years of age has been collected contrary to Company policy or applicable law, the Company reserves the right to:

• suspend access

• terminate accounts

• remove content

• preserve records where appropriate

take corrective action permitted by law.

2.1.1 COPPA Compliance

If the Company knowingly operates an online service directed to children under 13 or knowingly collects personal information directly from a child in a manner covered by COPPA, the Company will implement a COPPA-compliant parental notice, verifiable parental consent process, data-minimization, security, and retention program before that feature is launched.

This does not prohibit a parent, guardian, church, or authorized ministry from providing child information to ShepherdChek or another adult-managed service for legitimate registration, check-in, safety, or ministry-administration purposes. In those contexts, the adult or participating organization is responsible for having appropriate authority to provide the information, and the Company will use the information only for the disclosed service purpose.

2.2 Minors Ages 13 Through 17

Individuals between thirteen (13) and seventeen (17) years of age may only participate after successful completion of the Company's Dual Authorization Process.

The Company may require:

• SMS authorization

• email authorization

• confirmation codes

• identity verification

• parental acknowledgements

additional verification measures.

The Company reserves discretion concerning verification procedures.

3. INFORMATION WE MAY COLLECT

The Company may collect information including:

Account Information

• first name

• last name

• display name

• username

• pseudonym

• email address

• login credentials

authentication information.

Subscription Information

• subscription status

• membership records

• billing records

• transaction identifiers

payment metadata.

Community Information

• prayer requests

• praise reports

• testimonials

• comments

• discussions

community submissions.

VerseKey Information

• gameplay activity

• scores

• achievements

• leaderboard participation

• account activity

authentication records.

Technical Information

• IP address

• browser information

• operating system information

• device information

• log information

• session information

security records.

Communication Information

• newsletter enrollment

• devotional enrollment

• communication preferences

• SMS consent records

• email consent records

parental authorization records.

ShepherdSync Information

• volunteer role

• availability

• assignments

• confirmations

• scheduling communications

participation records.

ShepherdChek Information

• parent/guardian contact data

• child registration data including name, age, grade/group, authorized pickup/security information

health or allergy information supplied by an authorized adult.

4. HOW INFORMATION MAY BE USED

Information may be used to:

• provide Services

• authenticate users

• administer subscriptions

• process transactions

• operate VerseKey

• administer Communities

• provide support

• provide newsletters

• provide devotionals

• provide ministry updates

• improve Services

• conduct analytics

• provide security

• investigate abuse

• investigate fraud

• comply with legal obligations

protect rights and property.

5. RELIGIOUS AND MINISTRY INFORMATION

Users may voluntarily submit:

• prayer requests

• praise reports

• testimonials

• ministry participation requests

• devotional subscriptions

community participation information.

Such information may contain:

• faith-related information

• religious beliefs

• ministry participation information

spiritual experiences.

Users voluntarily choose whether to disclose such information.

The Company cannot guarantee absolute confidentiality for information voluntarily disclosed within community-accessible environments.

6. COMMUNICATIONS

Users may voluntarily subscribe to:

• newsletters

• devotionals

• announcements

• Shepherd Apparels updates

• VerseKey updates

ministry communications.

The Company may also send:

• operational notices

• authentication messages

• security notices

• account notifications

• subscription notices

transaction communications.

Operational communications may be sent regardless of marketing communication preferences where legally permitted.

7. SMS COMMUNICATIONS

Where SMS communications are utilized:

• message frequency may vary

• carrier charges may apply

• consent is not a condition of purchase unless expressly stated

users may opt out where applicable.

The Company reserves the right to send security, authentication, and account-related messages where legally permitted.

7.1 Mobile Information and SMS Consent — Required Non-Sharing Rule

The Shepherd Network LLC does not share, sell, rent, or otherwise provide a user's mobile telephone number, SMS/text-messaging opt-in data, or messaging consent information to third parties or affiliates for their marketing or promotional purposes.

Mobile information and messaging-consent data may be disclosed only to service providers, carriers, messaging platforms, aggregators, security providers, legal advisers, or other processors as reasonably necessary to deliver and secure the messaging service, comply with law, or protect rights.

Such disclosures do not authorize those recipients to use the data for their own marketing or promotional purposes.

8. THIRD-PARTY PROVIDERS

The Company may utilize independent service providers including, but not limited to:

• Printify

• Amazon

• Stripe

• PayPal

• Shopify

• YouTube

• Meta platforms

• Facebook

• Instagram

• LinkedIn

• TikTok

• HeyGen

• Make

• Dlvr.it

• hosting providers

• analytics providers

future vendors.

Such providers maintain their own policies and practices.

The Company is not responsible for independent third-party privacy practices.

8.1 Churches and Organizational Customers

When the Company processes volunteer, parent, guardian, or child information on behalf of a church or other organizational customer, that organization may determine the purposes of processing and the Company may act as a service provider or processor.

Appropriate service agreements should define responsibilities, permitted processing, security, retention, deletion, incident response, and user requests.

9. OUR COMMITMENT TO USER PERSONAL INFORMATION AND PRIVACY

No Sale of Personal Information

The Shepherd Network LLC respects the privacy of its users.

As a general business practice, The Shepherd Network LLC does not knowingly sell personal information to third parties for monetary compensation.

The Company may, however, share information with service providers, vendors, payment processors, hosting providers, communication providers, analytics providers, legal advisors, governmental authorities, and other parties as described in the Privacy Policy and as reasonably necessary to operate, secure, maintain, improve, and provide the Services.

Nothing in this section shall limit disclosures that are:

• authorized by the User

• necessary to provide requested Services

• necessary to process transactions

• necessary for security purposes

• required by law

• required to protect legal rights

• required to investigate fraud, abuse, or security incidents

otherwise permitted by applicable law.

The Company reserves the right to modify its information practices in the future, subject to applicable law and the Privacy Policy then in effect.

Our Commitment to User Privacy

The Shepherd Network LLC is committed to treating personal information with care, integrity, and respect.

While no privacy practice can guarantee absolute protection, the Company seeks to collect only information reasonably necessary to operate the Services, communicate with users, administer subscriptions, process requests, provide ministry resources, maintain security, and fulfill legitimate business purposes.

The Company does not operate its Services for the purpose of selling personal information and seeks to use personal information in a manner consistent with its mission, operational needs, and applicable law.

9.1 Consumer Privacy Rights

Where applicable law grants privacy rights, users may request access, correction, deletion, portability, or opt-out of covered targeted advertising, sale, or profiling.

Requests may be submitted to Support@TheShepherdNetwork.org.

The Company may authenticate requests and may deny or limit a request where permitted by law.

Where an appeal right is required, the Company will provide an appeal process and response instructions.

Kentucky's Consumer Data Protection Act applies only when statutory thresholds and other requirements are met. The Company nevertheless intends to use the rights framework in this section as a baseline practice where reasonably feasible, without representing that every statutory right applies to every user or service.

9.2 Sale, Targeted Advertising, and Profiling

The Company does not operate its Services for the purpose of selling personal data.

If the Company later engages in activity that constitutes a "sale," targeted advertising, or profiling under an applicable privacy law, the Company will provide any notices, opt-outs, and assessments required before or at the time that practice begins.

10. DATA RETENTION

The Company may retain information where reasonably necessary to:

• comply with law

• maintain business records

• maintain accounting records

• maintain tax records

• investigate fraud

• investigate abuse

• investigate security incidents

• preserve parental authorization records

• preserve subscription records

• preserve moderation records

• preserve intellectual property rights

• establish legal rights

• defend legal claims

• maintain publication archives

maintain ministry archives.

Retention periods may vary.

11. DELETION REQUESTS

Users may request deletion of information.

The Company will evaluate requests in good faith.

However, the Company reserves the right to retain information where reasonably necessary for:

• legal compliance

• fraud prevention

• dispute resolution

• security investigations

• business records

• payment records

• parental authorization records

• legal claims

• intellectual property protection

• archival purposes

protection of the Company, David Craig Cooper, users, and third parties.

12. SECURITY

The Company may implement commercially reasonable administrative, technical, organizational, and operational safeguards.

However, no system can guarantee:

• absolute security

• uninterrupted protection

• prevention of all cyberattacks

prevention of all unauthorized access.

Users acknowledge these risks.

12.1 Data Security and Breach Response

If a security breach triggers notice obligations under applicable law, the Company will provide legally required notices without unreasonable delay, subject to lawful law-enforcement delay and investigative needs.

The Company uses reasonable safeguards appropriate to its size, resources, systems, and data.

No security method is absolute, and the Company will respond to security incidents in accordance with applicable law and best practices.

13. INTERNATIONAL USERS

The Services are operated primarily from the United States.

Users outside the United States acknowledge that information may be transferred to, stored in, processed in, or administered from jurisdictions where the Company or its providers operate.

14. AI TECHNOLOGIES

The Company may utilize:

• artificial intelligence systems

• machine learning systems

• automated moderation systems

• recommendation systems

• customer support technologies

• analytics systems

future AI technologies.

Certain content, communications, moderation actions, recommendations, analytics, administrative functions, or support interactions may be generated, assisted, enhanced, summarized, reviewed, or processed through AI Technologies.

15. CHANGES TO THIS POLICY

The Company may revise this Privacy Policy from time to time.

Continued use of the Services following implementation of revised policies constitutes acceptance of such revisions to the extent permitted by law.

16. CONTACT INFORMATION

The Shepherd Network LLC

Lawrenceburg, Kentucky, USA

Official Contact Address:

Support@TheShepherdNetwork.org