Privacy Policy

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include:

• Names
• Email addresses

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice at stripe.com/privacy.

Application Data. If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:

• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and IP address (or proxy server).
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). You can turn these off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, recorded in log files — including IP address, device information, browser type, activity in the Services, and device event information (such as system activity and error reports).
• Device Data. Information about the computer, phone, tablet, or other device you use to access the Services, including IP address, device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. Information about your device's location, which can be either precise or imprecise. You can opt out of allowing us to collect this information by refusing access to the information or disabling your Location setting on your device — though you may not be able to use certain aspects of the Services.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries/offer support to users.
• To send administrative information to you, such as details about changes to our terms and policies.
• To request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications, in accordance with your marketing preferences. You can opt out at any time — see What Are Your Privacy Rights? below.
• To protect our Services, including fraud monitoring and prevention.
• To identify usage trends so we can improve how our Services are used.
• To determine the effectiveness of our marketing and promotional campaigns.
• To save or protect an individual's vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law — like your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK

The GDPR and UK GDPR require us to explain the valid legal bases we rely on to process your personal information:

• Consent. You can withdraw your consent at any time — see Withdrawing your consent.
• Performance of a Contract. To fulfill our contractual obligations to you, including providing our Services.
• Legitimate Interests, for example to send information about offers and discounts, analyze how our Services are used, support our marketing activities, diagnose problems and prevent fraud, and understand how users use our products.
• Legal Obligations, such as cooperating with law enforcement or a regulatory agency, or exercising or defending our legal rights.
• Vital Interests, where necessary to protect your vital interests or those of a third party, such as situations involving potential threats to safety.

If you are located in Canada

We may process your information if you have given us express or implied consent for a specific purpose. You can withdraw your consent at any time. In some exceptional cases we may be legally permitted to process your information without consent, including for fraud detection and prevention, business transactions, insurance claims, identifying and communicating with next of kin, financial abuse investigations, compliance with a subpoena or court order, and other purposes permitted by applicable law.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties designed to safeguard your personal information — they cannot use it except as we instruct, and they must protect it and retain it only for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• Data Analytics Services
• Communication & Collaboration Tools
• Data Storage Service Providers
• Payment Processors
• User Account Registration & Authentication Services

We may also need to share your personal information in the following situation:

• Business Transfers. We may share or transfer your 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.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (including targeted advertising, as defined under applicable laws) under applicable US state laws, you can opt out as described under Do United States Residents Have Specific Privacy Rights? below.

Google Analytics

We use Google Analytics to track and analyze use of the Services. To opt out of being tracked by Google Analytics across the Services, visit tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings. Other opt-out means include optout.networkadvertising.org and networkadvertising.org/mobile-choice. For more information on Google's privacy practices, visit the Google Privacy & Terms page.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us to keep your personal information for longer than the period of time in which you have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because it has been stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Although we will do our best to protect your personal information, transmission to and from our Services is at your own risk, and you should only access the Services within a secure environment.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to their use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under 18, please contact us at hello@wishuponaplan.com.

9. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or if you are in the EEA, UK, Switzerland, or Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada) you have certain rights under applicable data protection laws, including the right to (i) request access and obtain a copy of your personal information, (ii) request rectification or erasure, (iii) restrict the processing of your personal information, (iv) data portability, and (v) not be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. You can make such requests using the contact details in How Can You Contact Us About This Notice? below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can complain directly to us, in addition to your rights under the UK GDPR and the Data Protection Act 2018. We will acknowledge your complaint within 30 days, investigate without unjustifiable delay, and keep you informed of progress and the outcome. If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office:

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw it at any time by contacting us using the details in How Can You Contact Us About This Notice? below, or by updating your preferences. This will not affect the lawfulness of processing before withdrawal, nor will it affect processing conducted in reliance on lawful grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us using the details in How Can You Contact Us About This Notice? below. You will then be removed from marketing lists — however, we may still send you service-related messages necessary for the administration of your account.

Account Information

If you would like to review or change the information in your account, or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at hello@wishuponaplan.com.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you in a revised version of this Privacy Notice.

Global Privacy Control: We recognize Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of your personal information for targeted advertising purposes under applicable state privacy laws, including the CCPA. For more information about GPC and how to enable it, visit globalprivacycontrol.org.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. See What Information Do We Collect? for a comprehensive inventory.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of receiving help through our customer support channels, participation in customer surveys or contests, and facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain collected personal information as needed to provide the Services, generally for as long as you have an account with us.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider — see When and With Whom Do We Share Your Personal Information? We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration; this is not considered "selling" your personal information. We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. These rights include the right to:

• Know whether or not we are processing your personal data
• Access your personal data
• Correct inaccuracies in your personal data
• Request the deletion of your personal data
• Obtain a copy of the personal data you previously shared with us
• Non-discrimination for exercising your rights
• Opt out of the processing of your personal data if used for targeted advertising (or sharing, as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending on where you live, you may also have the right to access categories of personal data being processed, obtain a list of categories or specific third parties we've disclosed personal data to, obtain a list of third parties to which we've sold personal data, review and correct how personal data has been profiled, limit use and disclosure of sensitive personal data, and opt out of collection of data through voice or facial recognition features — each as permitted by applicable state law.

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting wishuponaplan.com/contact, by emailing us at hello@wishuponaplan.com, or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof they have been validly authorized to act on your behalf.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from information already maintained by us, we may request additional information for verification and security or fraud-prevention purposes. If you submit the request through an authorized agent, we may need additional information to verify your identity, and the agent will need to provide a written and signed permission from you.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hello@wishuponaplan.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine the Light" Law

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of those third parties in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit it in writing using the contact details in How Can You Contact Us About This Notice?

12. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer by email at hello@wishuponaplan.com, or by post at:

14. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit wishuponaplan.com/contact.