privacy policy

Last updated March 31, 2025

This Privacy Notice for EverySpend, Inc (doingbusinessas101+) ("we," "us," or "our"),describeshowand why we might access, collect, store, use, and/or share("process")yourpersonal information when you use our services ("Services"),includingwhen you:

Visit our website at https://www.101.plus or any website of ours that links to this Privacy Notice

Download and use our mobile application (101+), or any other application of ours that links to this Privacy Notice

Use 101+. Discover your path to a longer, healthier life. Get personalized health insights, track progress, and optimize your vitality with science-backed strategies. Unlock the future of longevity with science-backed strategies designed to enhance your healthspan and extend your lifespan. Our app delivers personalized insights, expert-guided interventions, and cutting-edge supplements—all tailored to optimize your cellular health, energy, and overall vitality. Track progress, uncover what your body needs, and take control of your health journey. Live healthier, longer, and stronger.

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading thisPrivacyNotice will help you understand your privacy rights and choices. Weareresponsible for making decisions about how your personal informationisprocessed. If you do not agree with our policies and practices, please donotuse our Services. If you still have any questions or concerns, pleasecontactus at privacy@101.plus.

SUMMARY OF KEY POINTS

This summary provides key points from ourPrivacyNotice, but you can find out more details about any of these topics byclickingthe link following each key point or by using our tableofcontents below to find the section you are looking for.

What personal information do we process? Whenyouvisit, use, or navigate our Services, we may process personalinformationdepending on how you interact with us and the Services, the choicesyoumake,and the products and features you use. Learn moreabout personalinformation you disclose tous.

Do we process any sensitive personal information? Someofthe information may be considered "special" or"sensitive"in certain jurisdictions, for example your racial orethnic origins, sexualorientation, and religious beliefs. We may processsensitive personalinformation when necessary with your consent or as otherwisepermitted byapplicable law. Learn more about sensitive information weprocess.

Do we collect any information from third parties? Wemaycollect information from public databases, marketing partners, socialmediaplatforms, and other outside sources. Learn moreabout informationcollected from other sources.

How do we process your information? Weprocessyour information to provide, improve, and administer our Services,communicatewith you, for security and fraud prevention, and to comply with law.We mayalso process your information for other purposes with your consent. Weprocessyour information only when we have a valid legal reason to do so. Learnmoreabout how we processyourinformation.

In what situations and with which types of parties doweshare personal information? We may share informationinspecificmsituations and with specific categories of third parties.Learnmoremabout when and withwhom weshare your personal information.

How do we keep your information safe? Wehaveadequate organizational and technical processes and procedures in placetoprotect your personal information. However, no electronic transmission overtheinternet or information storage technology can be guaranteed to be 100%secure,so we cannot promise or guarantee that hackers, cyber criminals, orotherunauthorized third parties will not be able to defeat our securityandimproperly collect, access, steal, or modify your information. Learnmoreabout how we keepyourinformation safe.

What are your rights? Depending on where youarelocated geographically, the applicable privacy law may mean you havecertainrights regarding your personal information. Learn more about yourprivacyrights.

How do you exercise your rights? Theeasiestwayto exercise your rights is by submitting a data subject accessrequest,or by contacting us. We will consider and act upon any request inaccordancewith applicable data protection laws.

Want to learn more about what we do with any informationwecollect? Review the Privacy Noticeinfull.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

6. HOW LONG DO WEKEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOUREVIEW, UPDATE, OR DELETE THE DATA WECOLLECTFROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collectpersonalinformation that you provide to us.

We collect personal information that you voluntarilyprovideto us when you register on the Services, express an interest inobtaininginformation about us or our products and Services, when youparticipateinactivities on the Services, or otherwise when you contactus.

Personal Information Provided by You. Thepersonalinformation that we collect depends on the context of yourinteractions with usand the Services, the choices you make, and the productsand features you use.The personal information we collect may include thefollowing:

Names

Phone numbers

Email addresses

Mailing addresses

Usernames

Passwords

Contact preferences

Contact or authentication data

Billing addresses

Debit/credit card numbers

Health dats

Biometric data

Sensitive Information. When necessary, withyourconsent or as otherwise permitted by applicable law, we process thefollowingcategories of sensitive information:

Health data

Financial dats

Genetic data

Biometric data

Data about a person's sex life or sexual orientation

Payment Data. We may collect data necessarytoprocess your payment if you choose to make purchases, such as yourpaymentinstrument number, and the security code associated with yourpaymentinstrument. All payment data is handled and stored by Stripe. You mayfindtheir privacy notice link(s) here: https://stripe.com/privacy.

Application Data. If you useourapplication(s),we also may collect the following information if you choosetoprovide us with access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's calendar, contacts, microphone, reminders, sms messages, sensors, bluetooth, camera, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain thesecurityand operation of our application(s), for troubleshooting, and for ourinternalanalytics and reporting purposes.

All personal information that you provide to us must betrue,complete, and accurate, and you must notify us of any changes to suchpersonalinformation.

Information automatically collected

In Short: Some information — suchasyour Internet Protocol (IP) address and/or browser and devicecharacteristics—is collected automatically when you visit our Services.

We automatically collect certain information when youvisit,use, or navigate the Services. This information does not reveal yourspecificidentity (like your name or contact information) but may include deviceandusage information, such as your IP address, browser anddevicecharacteristics,operating system, language preferences, referring URLs,devicename, country, location, information about how and when you use ourServices,and other technical information. This information is primarily neededto maintainthe security and operation of our Services, and for our internalanalytics andreporting purposes.

Like many businesses, we also collect informationthroughcookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API

Our use of information received from Google APIswilladhereto Google API Services User Data Policy, includingthe LimitedUse requirements.

Information collected from other sources

In Short: We may collectlimiteddatafrom public databases, marketing partners, and other outsidesources.

In order to enhance our ability to providerelevantmarketing, offers, and services to you and update our records, we mayobtaininformation about you from other sources, such as public databases,jointmarketing partners, affiliate programs, data providers, and from otherthirdparties. This information includes mailing addresses, job titles,emailaddresses, phone numbers, intent data (or user behavior data),InternetProtocol (IP) addresses, social media profiles, social media URLs, andcustomprofiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process yourinformationto provide, improve, and administer our Services, communicate withyou, forsecurity and fraud prevention, and to comply with law. We may alsoprocess yourinformation for other purposes with your consent.

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

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

To post testimonials. We post testimonials on our Services that may contain personal information.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOURPERSONALINFORMATION?

In Short: We may share informationinspecific situations described in this section and/or with thefollowingcategories of third parties.

Vendors, Consultants, and Other Third-PartyServiceProviders. We may share your data with third-party vendors,serviceproviders, contractors, or agents ("third parties")whoperform services for us or on our behalf and require access to suchinformationto do that work. We have contracts in place with our third parties,which aredesigned to help safeguard your personal information. This means thattheycannot do anything with your personal information unless we haveinstructedthem to do it. They will also not share your personal informationwith anyorganization apart from us. They also commit to protect the data theyhold onour behalf and to retain it for the period we instruct.

The categories of third parties we may sharepersonalinformation with are as follows:

Ad Networks

Affiliate Marketing Programs

AI Platforms

Cloud Computing Services

Communication & Collaboration Tools

Data Analytics Services

Data Storage Service Providers

Finance & Accounting Tools

Government Entities

Order Fulfillment Service Providers

Payment Processors

Performance Monitoring Tools

Product Engineering & Design Tools

Retargeting Platforms

Sales & Marketing Tools

Social Networks

Testing Tools

User Account Registration & Authentication Services

Website Hosting Service Providers

We also may need to share your personal information inthefollowing situations:

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.

When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: Location; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled "HOW DO WE PROCESS YOUR INFORMATION?" Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise. We obtain and store on your device ("cache") your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

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

We may use cookies and similar tracking technologies(likeweb beacons and pixels) to gather information when you interact withourServices. Some online tracking technologies help us maintain the securityofour Services and your account, prevent crashes, fix bugs, saveyourpreferences, and assist with basic site functions.

We also permit third parties and service providers touseonline tracking technologies on our Services for analytics andadvertising,including to help manage and display advertisements, to tailoradvertisementsto your interests, or to send abandoned shopping cart reminders(depending onyour communication preferences). The third parties and serviceproviders usetheir technology to provide advertising about products andservices tailoredtoyour interests which may appear either on our Services or onother websites.

To the extent these online tracking technologies aredeemedtobe a "sale"/"sharing" (which includestargetedadvertising,as defined under the applicable laws) under applicable USstatelaws, you can optout of these online tracking technologies by submittingarequest as describedbelow under section "DO UNITED STATES RESIDENTS HAVESPECIFIC PRIVACYRIGHTS?"

Specific information about how we use such technologiesandhow you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics totrackand analyze the use of the Services. The Google Analytics AdvertisingFeaturesthat we may use include: Remarketing with Google Analytics, GoogleDisplayNetwork Impressions Reporting and Google Analytics Demographics andInterestsReporting. To opt out of being tracked by Google Analytics acrosstheServices,visit https://tools.google.com/dlpage/gaoptout. You canoptout of Google Analytics Advertising Features through AdsSettings andAd Settings for mobile apps. Other opt outmeansinclude http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice.Formore information on the privacy practices of Google, pleasevisitthe Google Privacy & Terms page.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products,features,or tools powered by artificial intelligence, machine learning, orsimilartechnologies.

As part of our Services, we offer products, features,ortools powered by artificial intelligence, machine learning, orsimilartechnologies (collectively, "AI Products"). These tools aredesignedto enhance your experience and provide you with innovative solutions.The termsin this Privacy Notice govern your use of the AI Products within ourServices.

Use of AI Technologies

We provide the AI Products through third-partyserviceproviders ("AI Service Providers"), including OpenAI,AmazonWebServices (AWS) AI, Microsoft Azure AI, Perplexity and Anthropic. Asoutlinedinthis Privacy Notice, your input, output, and personal informationwill beshared with and processed by these AI Service Providers to enable youruseofour AI Products for purposes outlined in "WHEN AND WITH WHOM DO WESHAREYOUR PERSONAL INFORMATION?" You must not use the AI Products in anywaythat violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

AI applications

AI automation

AI bots

AI deployment

AI development

AI document generation

AI insights

AI predictive analytics

AI research

AI search

AI translation

Blockchain

Image analysis

Image generation

Machine learning models

Natural language processing

Text analysis

How We Process Your Data Using AI

All personal information processed using our AI Productsishandled in line with our Privacy Notice and our agreement withthirdparties.This ensures high security and safeguards your personalinformationthroughout the process, giving you peace of mind about your data'ssafety.

‍

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your informationforas long as necessary to fulfill the purposes outlined in this PrivacyNoticeunless otherwise required by law.

We will only keep your personal information for as long asitis necessary for the purposes set out in this Privacy Notice, unless alongerretention period is required or permitted by law (such as tax,accounting, orother legal requirements). No purpose in this notice willrequire us keepingyour personal information for longer than six (6) monthspast the termination ofthe user's account.

When we have no ongoing legitimate business need toprocessyour personal information, we will either delete or anonymizesuchinformation,or, if this is not possible (for example, because yourpersonalinformation has been stored in backup archives), then we will securelystoreyour personal information and isolate it from any further processinguntildeletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protectyourpersonal information through a system of organizational and technicalsecuritymeasures.

We have implemented appropriate and reasonable technicalandorganizational security measures designed to protect the security ofanypersonal information we process. However, despite our safeguards and effortstosecure your information, no electronic transmission over the Internetorinformation storage technology can be guaranteed to be 100% secure, sowecannot promise or guarantee that hackers, cybercriminals, or otherunauthorizedthird parties will not be able to defeat our security andimproperly collect,access, steal, or modify your information. Although we willdo our besttoprotect your personal information, transmission of personalinformation toand from our Services is at your own risk. You should only accessthe Serviceswithin a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

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

We do not knowingly collect, solicit data from, ormarkettochildren under 18 years of age, nor do we knowingly sell suchpersonalinformation. By using the Services, you represent that you are at least18 orthat you are the parent or guardian of such a minor and consent tosuchminordependent’s use of the Services. If we learn that personalinformationfrom users less than 18 years of age has been collected, we willdeactivate theaccount and take reasonable measures to promptly delete such datafrom our records.If you become aware of any data we may have collected fromchildren under age18, please contact us at privacy@101.plus.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change,orterminate your account at any time, depending on your country, province,orstate of residence.

Withdrawing your consent: If we are relyingonyour consent to process your personal information, which may be expressand/orimplied consent depending on the applicable law, you have the right towithdrawyour consent at any time. You can withdraw your consent at any time bycontactingus by using the contact details provided in the section"HOW CAN YOUCONTACT US ABOUT THIS NOTICE?"below.

However, please note that this will not affect thelawfulnessof the processing before its withdrawal nor, when applicable lawallows, will itaffect the processing of your personal information conducted inreliance onlawful processing grounds other than consent.

Opting out of marketing and promotional communications: Youcanunsubscribe from our marketing and promotional communications at any timebyclicking on the unsubscribe link inthe emails that we send,replying"STOP" or "UNSUBSCRIBE"to the SMS messages that wesend, orby contacting us using the details provided in the section "HOWCAN YOU CONTACT US ABOUT THIS NOTICE?"below. You will then be removedfromthe marketing lists. However, we may stillcommunicate with you — for example,to send you service-related messages thatare necessary for the administrationand use of your account, to respond toservice requests, or for othernon-marketing purposes.

No mobile information will be shared with third partiesoraffiliates for marketing or promotional purposes. Information sharingtosubcontractors in support services, such as customer service, ispermitted.Allother use case categories exclude text messaging originator opt-indataandconsent; this information will not be shared with third parties.

Account Information

If you would at any time like to review or changetheinformation in your account or terminate your account, you can:

Upon your request to terminate your account, wewilldeactivate or delete your account and information from our activedatabases.However, we may retain some information in our files to preventfraud,troubleshoot problems, assist with any investigations, enforce our legaltermsand/or comply with applicable legal requirements.

Cookies and similar technologies: MostWebbrowsers are set to accept cookies by default. If you prefer, youcanusuallychoose to set your browser to remove cookies and to reject cookies.If youchoose to remove cookies or reject cookies, this could affect certainfeaturesor services of our Services.

If you have questions or comments about yourprivacyrights,you may email us at privacy@101.plus.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systemsandmobile applications include a Do-Not-Track ("DNT") feature orsettingyou can activate to signal your privacy preference not to have dataabout youronline browsing activities monitored and collected. At this stage, nouniformtechnology standard for recognizing and implementing DNT signals hasbeenfinalized. As such, we do not currently respond to DNT browser signals oranyother mechanism that automatically communicates your choice not to betrackedonline. If a standard for online tracking is adopted that we must followin thefuture, we will inform you about that practice in a revised version ofthisPrivacy Notice.

California law requires us to let you know how werespondtoweb browser DNT signals. Because there currently is not an industry orlegalstandard for recognizing or honoring DNT signals, we do not respond tothem atthis time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFICPRIVACYRIGHTS?

In Short: If you are a residentofCalifornia, Colorado, Connecticut, Delaware, Florida, Indiana,Iowa,Kentucky,Maryland, Minnesota, Montana, Nebraska, New Hampshire, NewJersey,Oregon,Rhode Island, Tennessee, Texas, Utah, or Virginia, you may havetheright to request access to and receive details about the personalinformationwe maintain about you and how we have processed it, correct inaccuracies, geta copy of, or delete your personal information. You may alsohave the right towithdraw your consent to our processing of your personalinformation. Theserights may be limited in some circumstances by applicablelaw. More informationis provided below.

Categories of Personal Information We Collect

We have collected the following categories ofpersonalinformation in the past twelve (12) months:

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias,postaladdress, telephone or mobile contact number, unique personalidentifier,online identifier, Internet Protocol address, email address,and accountname

YES

B. Personal information as defined intheCalifornia Customer Records statute

Name, contact information,education,employment, employment history, and financial information

C. Protected classification characteristics under stateor federal law

Gender, age, date of birth, race and ethnicity,national origin, marital status, and other demographic data

YES

‍

D. Commercial information

Transaction information, purchase history,financial details, and payment information

YES

‍

E. Biometric information

Fingerprints and voiceprints

YES

‍

F. Internet or other similar network activity

Browsing history, search history, online behavior, interestdata, and interactions with our and other websites,applications, systems,and advertisements

‍

G. Geolocation data

Device location

‍

H. Audio, electronic, sensory, or similar information

Images and audio, video or call recordings createdin connection with our business activities

‍

I. Professional or employment-related information

Business contact details in order to provide youour Services at a business level or job title, work history, andprofessional qualifications if you apply for a job with us

‍

J. Education Information

Student records and directory information

‍

K. Inferences drawn from collected personal information

Inferences drawn from any of the collectedpersonal information listed above to create a profile or summary about,forexample, an individual’s preferences and characteristics

YES

‍

L. Sensitive personal Information

Account login information, biometric data, debit orcredit card numbers, genetic data, health data and precisegeolocation

YES

We only collect sensitive personal information, as definedbyapplicable privacy laws or the purposes allowed by law or with yourconsent.Sensitive personal information may be used, or disclosed to aserviceprovideror contractor, for additional, specified purposes. You may havetheright tolimit the use or disclosure of your sensitive personal information.Wedo not collect or process sensitive personal information for the purposeofinferring characteristics about you.

We may also collect other personal information outsideofthese categories through instances where you interact with us inperson,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 the collected personalinformationasneeded to provide the Services or for:

Category A - As long as the user has an account with us

Category C - As long as the user has an account with us

Category D - As long as the user has an account with us

Category E - As long as the user has an account with us

Category K - As long as the user has an account with us

Category L - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personalinformationwecollect in "WHATINFORMATIONDO WE COLLECT?"

How We Use and Share Personal Information

Your personal information may be used in profilingandautomated processes that could produce legal or similarly significanteffectsfor you. Learn more about how we use your personal information inthesection,"HOW DO WE PROCESSYOURINFORMATION?"

We collect and share your personal information through:

Targeting cookies/Marketing cookies

Social media cookies

Beacons/Pixels/Tags

Social media plugins: WhatsApp. We use social media features, such as a "Like" button, and widgets, such as a "Share" button, in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.

Will your information be shared with anyone else?

We may disclose your personal information withourserviceproviders pursuant to a written contract between us and eachserviceprovider.Learn more about how we disclose personal information to inthesection, "WHEN AND WITH WHOM DO WE SHARE YOURPERSONALINFORMATION?"

We may use your personal information for ourownbusinesspurposes, such as for undertaking internal researchfortechnologicaldevelopment and demonstration. This is not considered tobe"selling"of your personal information.

We have disclosed the following categoriesofpersonalinformation to third parties for a business or commercial purposeinthepreceding twelve (12) months:

The categories of third parties to whom wedisclosedpersonalinformation for a business or commercial purpose can be foundunder"WHEN AND WITH WHOM DO WE SHAREYOURPERSONAL INFORMATION?"

We have sold or shared the following categoriesofpersonalinformation to third parties in the preceding twelve (12) months:

The categories of third parties to whom wesoldpersonalinformation are:

Ad Networks

Affiliate Marketing Programs

AI Platforms

Data Analytics Services

Retargeting Platforms

Social Networks

User Account Registration & Authentication Services

The categories of third parties to whom wesharedpersonalinformation with are:

Ad Networks

Affiliate Marketing Program

AI Platforms

Data Analytics Services

Retargeting Platforms

Social Networks

User Account Registration & Authentication Services

Your Rights

You have rights under certain US state dataprotectionlaws.However, these rights are not absolute, and in certain cases, wemaydeclineyour request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request the deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to non-discrimination for exercising your rights

Right to opt out of the processing of your personal data if it is 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 ("profiling")

Depending upon the state where you live, you may alsohavethefollowing rights:

Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota

Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a datasubject access request, by emailing us atprivacy@101.plus, or byreferring to the contact details at the bottom of this document.

You can opt out from the selling of your personal information,targeted advertising, or profiling by disabling cookies in Cookie PreferenceSettings.

Under certain US state data protection laws, you can designatean authorized agent to make a request on your behalf. We may deny are questfrom an authorized agent that does not submit proof that they have been validlyauthorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identityto determine you are the same person about whom we have the information in oursystem. We will only use personal information provided in your request toverify your identity or authority to make the request. However, If we cannotverify your identity from the information already maintained by us, we mayrequest that you provide additional information for the purposes of verifyingyour identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we mayneed to collect additional information to verify your identity before processingyour request and the agent will need to provide a written and signed permissionfrom you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline totake action regarding your request, you may appeal our decision by emailing usat privacy@101.plus. We will inform you in writing of any action taken or nottaken in response to the appeal, including a written explanation of the reasonsfor the decisions. If your appeal is denied, you may submit a complaint to yourstate attorney general.

Financial Incentives

"Financial incentive" means a program, benefit, orother offering, including payments to consumers as compensation, for the disclosure,deletion, sale, or sharing of personal information.

The law permits financial incentives or a price or service differenceif it is reasonably related to the value of the consumer’s data. A businessmust be able to explain how the financial incentive or price or service differenceis reasonably related to the value of the consumer’s data. The explanation mustinclude:

a good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and

a description of the method the business used to calculate the value of the consumer’s data.

We may decide to offer a "bona fide loyalty program"under Colorado law, or a "financial incentive" under California law(e.g., price or service difference) in exchange for the retention, sale, orsharing of a consumer’s personal information.

If we decide to offer a financial incentive, we will notify youof such financial incentive and explain the price difference, as well as materialterms of the financial incentive or price of service difference, including thecategories of personal information that are implicated by the financialincentive or price or service difference.

Under California law, the value of your personal informationto us is related to the value of the free or discounted products or services, orother benefits that you obtain or that are provided as part of the applicable program,less the expense related to offering those products, services, and benefits toprogram participants.

If you choose to participate in the financial incentive you canwithdraw from the financial incentive at any time by emailing usatprivacy@101.plus, or by referring to the contact details at the bottomof this document.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known asthe" Shine The Light" law, permits our users who are Californiaresidents to request and obtain from us, once a year and free of charge,information about categories of personal information (if any) we disclosed tothird parties for direct marketing purposes and the names and addresses of allthird parties with which we shared personal information in the immediatelypreceding calendar year. If you are a California resident and would like tomake such a request, please submit your request in writing to us by using thecontact details provided in the section "HOW CANYOU CONTACT US ABOUT THISNOTICE?"

12. DO WE MAKE UPDATES TO THIS NOTICE?

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

We may update this Privacy Notice from time to time. The updatedversion will be indicated by an updated "Revised" date at the top ofthis Privacy Notice. If we make material changes to this Privacy Notice, we maynotify you either by prominently posting a notice of such changes or bydirectly sending you a notification. We encourage you to review this PrivacyNotice 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 emailus at privacy@101.plus or contact us by post at:

Every Spend, Inc

417 Main St, Little Rock, AR 72201, USA

Little Rock, AR 72201

United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATAWECOLLECT FROM YOU?

Based on the applicable laws of your country or state of residencein the US, you may have the right to request access to the personal informationwe collect from you, details about how we have processed it, correct in accuracies,or delete your personal information. You may also have the right to withdrawyour consent to our processing of your personal information. These rights maybe limited in some circumstances by applicable law. To request to review,update, or delete your personal information, please fill out and submit a datasubject access request.