Privacy Policy

THE GEAR PROJECT

Privacy Policy

Effective Date: May 19, 2026 Available at: www.thegearproject.com/privacy

This Privacy Policy describes how The Gear Project LLC ("The Gear Project," "we," "us," or "our") collects, uses, and shares information about you when you access or use our website at www.thegearproject.com (the "Site") and the marketplace services we provide (collectively, the "Service"). This Privacy Policy is incorporated by reference into The Gear Project's Terms of Service. Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information as described here.

1. Interpretation and Definitions

1.1 Interpretation

Words with capitalized initial letters have the meanings defined below. These definitions apply whether the terms appear in singular or plural form.

1.2 Definitions

For the purposes of this Privacy Policy:

"Account" means a unique account created for you to access our Service.
"Affiliate Partner" means a third-party business, influencer, or content creator who participates in The Gear Project's affiliate or referral program and directs users to the Service in exchange for a commission on qualifying transactions.
"Company," "we," "us," or "our" refers to The Gear Project LLC, PO Box 4010, Sedona, AZ 86336.
"Consumer" refers to you, the individual using the Service.
"Cookies" are small files placed on your device by a website that store browsing data and preferences.
"Device" means any device that can access the Service, such as a computer, phone, or tablet.
"Personal Data" means any information that relates to or can identify you, directly or indirectly. For purposes of the CCPA, this includes information that identifies, relates to, or could reasonably be linked with you or your household.
"Sale" under the CCPA means selling, renting, disclosing, or otherwise transferring a consumer's personal information to a third party for monetary or other valuable consideration.
"Service" refers to the Site and the marketplace services provided by The Gear Project, including the mobile application.
"Service Provider" means a third party that processes data on our behalf to facilitate or support the Service.
"Usage Data" means data collected automatically when you use the Service, such as IP address, browser type, pages visited, and time on page.
"You" means the individual accessing or using the Service, or the entity on whose behalf that individual acts.

2. Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: team@thegearproject.com
By mail: The Gear Project LLC, PO Box 4010, Sedona, AZ 86336
By visiting our website: www.thegearproject.com

3. Collecting and Using Your Personal Data

3.1 Types of Data Collected

3.1.1 Personal Data

While using our Service, we may ask you to provide personally identifiable information. The categories of personal information The Gear Project collects and maintains include:

Name and email address
Mailing address, city, state, and ZIP code
Phone number (optional at account creation; may be required for account recovery or verification)
Account credentials (username and password)
Transaction history (items purchased, items sold, listing activity)
Shipping information submitted in connection with transactions
Usage Data

The Gear Project does not collect or store payment card numbers, bank account numbers, or other financial account details. All payment information is collected and processed directly by Stripe, Inc. See Section 4.1 for details.

3.1.2 Usage Data

Usage Data is collected automatically when you use the Service. It may include your device's IP address, browser type and version, pages visited, time and date of your visit, time spent on pages, unique device identifiers, and other diagnostic data. When you access the Service via a mobile device, we may collect information about your device type, operating system, and mobile browser.

3.1.3 Information from Third-Party Social Media Services

You may choose to register or log in through third-party social media services including Google, Facebook, Apple, and X (Twitter). If you do, we may collect the personal data already associated with that account, such as your name and email address. You may also choose to share additional information from your social media account, which you grant us permission to use consistent with this Privacy Policy.

3.1.4 Affiliate and Referral Tracking

If you arrive at the Service through a link from an Affiliate Partner — including through the RockPorch outdoor affiliate marketplace or the Avantlink affiliate network — a tracking cookie or similar technology may be set on your device to record the referral source. If you complete a purchase, transaction confirmation data (such as order ID and transaction amount) is shared with the applicable affiliate network solely for the purpose of calculating and paying commissions to Affiliate Partners. The Gear Project does not share your name, email address, payment information, or other personally identifying details with Affiliate Partners in connection with affiliate attribution. Affiliate tracking is governed by the Avantlink Privacy Policy, available at avantlink.com. See also Section 4.7 of this Policy.

3.1.5 Tracking Technologies and Cookies

We use cookies and similar tracking technologies (including beacons, tags, and scripts) to monitor activity on our Service and store certain information. Cookies may be:

Necessary / Essential Cookies — Session cookies required to provide the Service, authenticate users, and prevent fraudulent account use.
Cookies Policy / Notice Acceptance Cookies — Persistent cookies that record whether you have accepted our cookie notice.
Functionality Cookies — Persistent cookies that remember your login details and preferences to provide a more personalized experience.
Tracking and Performance Cookies — Persistent third-party cookies used to analyze traffic and how users interact with the Service. These may indirectly identify you via a pseudonymous device identifier.
Affiliate Attribution Cookies — Cookies set when you arrive via an Affiliate Partner link, used to track referral source for commission purposes. See Section 3.1.4.

You can configure your browser to refuse cookies, though doing so may limit some functionality.

3.2 How We Use Your Personal Data

We may use Personal Data for the following purposes:

To provide and maintain the Service, including monitoring its usage.
To manage your Account and enable registered user features.
To process transactions, including purchase and sale of gear, payment collection, and seller payouts.
To calculate, collect, and remit applicable sales tax through our third-party tax compliance provider (Avalara).
To generate shipping labels and coordinate delivery through our shipping integration (Shippo).
To track and attribute transactions to Affiliate Partners through the Avantlink/RockPorch affiliate network for commission calculation.
To contact you by email, SMS, or push notification regarding your account, orders, and Service updates.
To send you newsletters, promotional materials, or curated listings — you may opt out at any time.
To manage your requests and respond to your inquiries.
To deliver targeted advertising and measure its effectiveness.
To detect and prevent fraud, chargebacks, and unauthorized access.
For business transfers, such as a merger, acquisition, or asset sale in which user data may be transferred as a business asset.
For data analysis, usage trend identification, and Service improvement.
To comply with applicable law, including Arizona's data breach notification law (A.R.S. §§ 18-551 and 18-552).

3.3 Sharing Your Personal Data

We may share your personal information in the following situations:

With Service Providers: We share data with third-party vendors who help us operate the Service, including Stripe (payments and seller payouts), Shippo (shipping), Avalara (tax compliance), Beehiiv (marketing email), and analytics providers. Each is governed by its own privacy policy.
With Affiliate Partners via Avantlink/RockPorch: We share transaction confirmation data (order ID and amount) for commission attribution when a purchase originates from an affiliate referral link. See Section 4.7.
With Other Users: When you list gear for sale or complete a transaction, certain profile information and transaction details will be visible to the other party.
For Business Transfers: In connection with a merger, acquisition, or asset sale.
With Affiliates: We may share information with our corporate affiliates, who are required to honor this Privacy Policy.
For Legal Compliance: We may disclose information when required by law, court order, or government authority, or to protect the rights, property, or safety of The Gear Project, its users, or the public.
With Your Consent: We may share information for other purposes with your explicit consent.

3.4 Retention of Your Personal Data

We retain Personal Data only as long as necessary for the purposes outlined in this Privacy Policy, including to comply with legal obligations, resolve disputes, and enforce our agreements. Transaction records may be retained for the period required under applicable tax and financial recordkeeping laws. Usage Data is generally retained for a shorter period unless needed to improve security or functionality. When your data is no longer required, we will delete it in accordance with applicable law.

3.5 Transfer of Your Personal Data

The Gear Project is domiciled in the State of Arizona and operates exclusively within the United States. Your information is processed in the United States. By using the Service, you consent to the processing of your data in the United States.

3.6 Deleting Your Personal Data

You have the right to request deletion of your Personal Data. You may update or delete account information directly in your account settings, or contact us at team@thegearproject.com to request deletion. Note that we may be required to retain certain data to fulfill legal obligations, including tax records, transaction history, and data breach notification obligations under A.R.S. § 18-552.

3.7 Security of Your Personal Data

The Gear Project maintains reasonable administrative, technical, and physical safeguards designed to protect the personal information we collect from unauthorized access, disclosure, or acquisition. The Gear Project does not store payment card numbers or bank account details — all such information is handled directly by Stripe, which maintains PCI-DSS compliance.

In the event The Gear Project determines that a security system breach has occurred involving your personal information as defined under A.R.S. § 18-551, The Gear Project will notify affected individuals in accordance with applicable law, including within forty-five (45) days of determining that a breach has occurred, as required by A.R.S. § 18-552. If the breach affects more than one thousand (1,000) Arizona residents, The Gear Project will notify the Arizona Attorney General and the Director of the Arizona Department of Homeland Security as required by law. If you receive a breach notification involving your account credentials, you should promptly change your password and update any other accounts that use the same credentials.

4. Third-Party Service Providers

The following third-party service providers may have access to your Personal Data in connection with operating the Service. Each is governed by its own privacy policy. The Gear Project requires all Service Providers to protect your information in a manner consistent with this Privacy Policy.

4.1 Payments and Seller Payouts — Stripe

Stripe, Inc. processes all buyer payments and seller payouts. The Gear Project does not store or access payment card numbers, bank account numbers, or other financial account details. These are provided directly to Stripe and governed by the Stripe Privacy Policy (stripe.com/privacy) and Stripe Services Agreement. By completing a purchase or listing on the Service, you acknowledge that your payment data is subject to Stripe's terms. The Gear Project receives only transaction confirmation data necessary to fulfill orders and release seller payouts.

Stripe Connect is used to onboard sellers and manage payout flows. Seller financial verification is performed by Stripe independently. Sellers should consult Stripe's documentation at stripe.com/docs/payouts for information on payout timelines.

4.2 Shipping — Shippo

Shippo, Inc. provides shipping label generation, real-time rate calculations, and shipment tracking. Order and address information necessary to generate labels is shared with Shippo. Shipping labels are governed by Shippo's Terms of Service (goshippo.com/terms). Optional shipping loss and damage assistance is described in The Gear Project's Terms of Service. Shipping insurance (Total Protection coverage via XCover) is available on eligible shipments.

4.3 Tax Compliance — Avalara

Avalara, Inc. calculates, collects, and remits sales tax on transactions. Transaction and address data necessary for tax calculation and remittance is shared with Avalara. The Gear Project is obligated to collect and remit sales tax in states where it has economic nexus, including California, where certain members of the founding team reside and hold majority ownership. See the Tax sections of the Terms of Service for additional information.

4.4 Marketing Email — Beehiiv

Beehiiv manages our marketing newsletter and promotional email communications. You may unsubscribe from marketing emails at any time using the unsubscribe link in any marketing email or by contacting us at team@thegearproject.com.

4.5 Analytics

We may use analytics services, including Google Analytics 4, to understand how users interact with the Service. Analytics tools collect usage data that may be linked to a pseudonymous device identifier. You may opt out of Google Analytics via the opt-out browser add-on at tools.google.com/dlpage/gaoptout.

4.6 Affiliate Marketing — RockPorch and Avantlink

The Gear Project participates in affiliate marketing programs managed through Avantlink, an affiliate marketing network platform, and RockPorch, an outdoor-industry affiliate marketplace that operates on the Avantlink network. These programs allow Affiliate Partners — including outdoor influencers and content creators — to earn commissions by referring buyers to The Gear Project.

How affiliate tracking works:

When you click an affiliate link posted by an Affiliate Partner and arrive at the Service, Avantlink's tracking technology (typically a cookie) records the referral source.
If you complete a purchase within the tracking window, The Gear Project shares transaction confirmation data (order ID and transaction amount) with Avantlink to calculate and pay the Affiliate Partner's commission.
The Gear Project does not share your name, email address, payment information, or other personally identifying details with Affiliate Partners or with Avantlink/RockPorch beyond what is necessary for commission attribution.
The existence of an affiliate relationship does not affect the price you pay or the commission charged to Sellers.
The Gear Project requires all Affiliate Partners to comply with applicable FTC disclosure requirements when promoting the Service.

Avantlink's privacy practices are governed by the Avantlink Privacy Policy, available at avantlink.com. RockPorch's practices are governed by its separate privacy policy. The Gear Project is not responsible for the privacy practices of Affiliate Partners in their own communications.

Note for attorney review: Confirm that transaction data shared with Avantlink for commission calculation constitutes a "Sale" under the CCPA's broad definition and, if so, ensure this is reflected in Section 6.5.

4.7 Behavioral Remarketing

We may use remarketing services from Google, Meta (Facebook/Instagram), and Pinterest to show advertising to users who have previously visited the Service. These vendors use cookies and similar technologies. You may opt out through:

NAI opt-out: networkadvertising.org/choices
DAA opt-out: optout.aboutads.info
Your mobile device's ad personalization settings (Limit Ad Tracking on iOS; Opt Out of Ads Personalization on Android)

5. Links to Other Websites

Our Service may contain links to third-party websites not operated by The Gear Project, including websites operated by Affiliate Partners. The Gear Project is not responsible for the content or privacy practices of those sites. We encourage you to review the privacy policy of any website you visit.

6. CCPA, CalOPPA, and California Privacy Rights

This section applies to residents of California and supplements the information above. The Gear Project is subject to California consumer protection law, including the California Consumer Privacy Act (CCPA), because it conducts business with California residents. The Gear Project has economic nexus in California due to transaction volume with California buyers and the California residency of certain majority members of the founding team.

Note: Under California Civil Code Section 1789.3, California users may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

6.1 Categories of Personal Information Collected

In the preceding twelve (12) months, we may have collected the following categories of personal information from California residents:

| Category | Description | Collected | |----------|-------------|-----------| | A | Identifiers (name, email address, IP address, account name, postal address) | Yes | | B | California Customer Records (name, address, telephone number) — financial info processed directly by Stripe, not collected by The Gear Project | Yes | | C | Protected classifications | No | | D | Commercial information (transaction history, listings, purchases) | Yes | | E | Biometric information | No | | F | Internet or network activity (page visits, interactions with the Service) | Yes | | G | Geolocation | No | | H–K | Sensory, professional, education, or inference data | No |

6.2 Sources of Personal Information

We obtain personal information directly from you (account registration, listings, transactions), indirectly through your activity on the Service, automatically through cookies and tracking technologies, and from Service Providers in connection with operating the platform.

6.3 Business Purposes for Use of Personal Information

We use personal information to operate the Service, process transactions, respond to inquiries, fulfill legal obligations, improve the platform, detect fraud, conduct internal analytics, and attribute referrals to Affiliate Partners for commission calculation. See Section 3.2 for the complete list.

6.4 Disclosure of Personal Information

In the preceding twelve (12) months, we may have disclosed the following categories of personal information for business purposes: Category A (Identifiers), Category B (California Customer Records as noted above), Category D (Commercial information), and Category F (Internet activity). Transaction confirmation data (order ID and amount) is shared with Avantlink for affiliate commission calculation as described in Section 4.6.

6.5 Sale of Personal Information

We do not sell personal information in the traditional sense. However, sharing certain data — such as identifiers and internet activity — with advertising or analytics partners, or sharing transaction confirmation data with Avantlink/RockPorch for affiliate commission purposes, may constitute a "sale" under the CCPA's broad definition. Categories potentially involved include Category A (Identifiers), Category D (Commercial information), and Category F (Internet activity). You have the right to opt out — see Section 6.8.

6.6 Personal Information of Minors

We do not knowingly collect personal information from individuals under the age of 16. The Service is available only to users 18 years of age or older (or to users between 13 and 17 through a parent or guardian's account as described in the Terms of Service). If you believe a minor has provided information to us, please contact team@thegearproject.com and we will delete it promptly.

6.7 Your Rights Under the CCPA

California residents have the following rights:

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, how it has been used, and how it has been shared.
Right to Delete: You may request deletion of your personal information, subject to certain legal exceptions (including retention required for tax records, transaction history, and data breach notification compliance).
Right to Opt Out of Sale: You may direct us not to sell your personal information. To submit an opt-out request, contact us at team@thegearproject.com.
Right to Non-Discrimination: We will not discriminate against you for exercising these rights.

6.8 Exercising Your CCPA Rights

To exercise any of your California privacy rights, contact us at:

Email: team@thegearproject.com
Mail: The Gear Project LLC, PO Box 4010, Sedona, AZ 86336

We will respond to verifiable requests within 45 days. We may need to verify your identity before processing your request. You may authorize an agent registered with the California Secretary of State to make a request on your behalf. Any disclosures we provide will cover the 12-month period preceding the verifiable request.

7. Do Not Track

Some browsers include a Do Not Track (DNT) feature that signals websites not to track your activity. Because there is no uniform standard for how DNT signals should be interpreted, The Gear Project does not currently alter its data collection practices in response to DNT signals. We will update this policy if a widely accepted standard is established.

8. Children's Privacy

The Service is not directed at children under the age of 13 and does not knowingly permit minors to create independent accounts. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has submitted personal information to us independently, please contact us at team@thegearproject.com. We will delete such information promptly upon verified request. See the Age Requirements section of the Terms of Service for additional information.

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically. When we make material changes, we will update the Effective Date at the top of this document and notify you by email or by a prominent notice on the Site. We encourage you to review this Privacy Policy regularly. Your continued use of the Service after any changes become effective constitutes your acceptance of the updated policy.

10. Contact Us

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

The Gear Project LLC PO Box 4010 Sedona, AZ 86336

Email: team@thegearproject.com Website: www.thegearproject.com

This Privacy Policy was last revised on May 19, 2026.