BUILDAPLAN FINANCIAL EDUCATION, LLC PRIVACY POLICY

INTRODUCTION: This privacy policy (hereinafter the "Privacy Policy") provides an explanation of how BuildaPlan Financial Education, LLC (hereinafter "BuildaPlan") uses your personal information. For additional information please email us at hello@BuildaPlan.com You refers to the end-suser who is providing information to BuildaPlan. Your Information refers to the information that you provide to BuildaPlan. The Service refers to the services provided by BuildaPlan to the end-user.

Last updated: October 28, 2022. This Privacy Policy describes BuildaPlan’s policies and procedures on the collection, use and disclosure of Your Information when You use the Service and informs You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of Your Information in accordance with this Privacy Policy.

Interpretation and Definitions

Capitalized words have meanings defined hereunder. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

• "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR(General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service. Under CCPA (California Consumer Privacy Act), You can be referred to as the consumer, California resident or as the User as you are the individual using the Service.
• "Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to BuildaPlan Financial Education, LLC.
  For the purpose of the GDPR, the Company is the Data Controller. For the purposes of the CCPA, the Company is the Data Broker.
• "Affiliate" means an entity that controls, is controlled by or is under common control with a party (You or Company), where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• "Referred Planner" means a Certified Financial Planner™ that has met the minimum requirements to be available on the Company platform.
• "Account" means a unique account created for You to access our Service or parts of our Service.
• "Website" refers to BuildaPlan.com, accessible from https://BuildaPlan.com.
• "Service" refers to the options available at the Website.
• "Service Provider" means any natural or legal person who processes the data received from You on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered "Data Processors".
• "Third-party Social Media Service" refers to any website or any social network website through which a User can log in or create an account to use the Service.
• "Facebook Fan Page" is a public profile named BuildaPlan.com specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/BuildaPlan.com
• "Personal Data" is any information that relates to an identified or identifiable individual, typically You. For the purposes for GDPR, Personal Data means any information relating to You such as your name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of CCPA, Personal Data means any information that identifies, relates to, or could reasonably be linked with You or your household such as name, social security number, email address, records of products purchased, internet browsing history, geolocation data, biometrics, and inferences from other personal information that could create a profile about your preferences and characteristics.
• "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• "Data Controller", for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• "Data Broker", for the purposes of the CCPA (California Consumer Privacy Act), refers to the Company as the business that knowingly collects and sells to third parties the personal information of a consumer (You) with whom the business does not have a direct relationship.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, we may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Postal / Zip Code
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), rowser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. We use both session and persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies
  Type: Persistent Cookies Administered by: Us
  Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
• Tracking and Performance Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities or services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, services and events which we offer that are similar to those that you have already used or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to help support and maintain Our Service, to contact You, or for payment processing.
• For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates any subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With Referred Planners: We will only share Your information with a Referred Planner upon request (such as a request to be introduced to a Certified Financial Planner™), and will require any Referred Planner to honor this Privacy Policy.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to assist you with improving your plan and to assist with the implementation of financial services. They are obligated not to disclose or use it for any other purpose.

Analytics

We may use a variety of third-party Service providers to monitor and analyze the use of our Service.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. We may use Email Marketing Service Providers to manage and send emails to You.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Your Rights under the CCPA

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are a California Resident, to:

• The right to know about the personal information a business collects about them and how it is used and shared;
• The right to delete personal information collected from them (with some exceptions);
• The right to opt-out of the sale of their personal information; and
• The right to non-discrimination for exercising their CCPA rights.

Exercising of Your CCPA Data Protection Rights

You may exercise Your rights under the CCPA by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. You have the right to file a consumer complaint with the California Office of the Attorney General if you believe We have violated the CCPA.

Children’s Privacy

Links to Other Websites

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. Upon any changes, we will update this page and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Hold Harmless And Disclaimer

By using the Service, You agree to this Privacy Policy. If You do not agree, then please do not use the Service. Your use of the Service is Your agreement to be bound by this Privacy Policy, including, but not limited to, holding Us harmless from any liability resulting from the use of this Service, including payment of any and all attorney fees, expert fees, court costs, and any other fee associated with a claim associated with this Privacy Policy and/or the use of the Service. Further, this includes Your agreement to hold us harmless from any judgment, claim, liability, or allegation and/or assertion of such a judgment, claim, or liability.

Contact Us

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

• By email: admin@BuildaPlan.com.