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PLANFUL PRIVACY POLICY

Effective Date: January 24th, 2023

Planful Inc. and its affiliates (“Planful”, “We”, “Us”, “Our”) respects Your
privacy rights. Not only do We strive to collect, process, use and disclose
Personal Data in a manner consistent with the laws of the countries in which We
do business, but We also aim to uphold the highest ethical standards in Our
business practices. You may print a copy of this Policy by clicking here. If You
require an alternative format of this Policy to be able to access it please
contact dpo@planful.com.


SCOPE AND APPLICABILITY OF THIS POLICY

This Policy applies to https://planful.com (“Site”) and services owned and
operated by Planful, including the cloud application run as Software as a
Service (SaaS) (“Services”). By using or accessing the Site or Services in any
manner, You acknowledge that You accept the practices outlined in this Policy
and You hereby consent that We will collect, use, and share Your information as
outlined in this Policy.

This Policy does not apply to any third-party applications or software that
integrate with Services or any other third-party products, services, or
businesses.

If You use the Site and Services as part of an entity or organization that has a
corporate account with Planful, like Your employer (“Client”), that Client may
have entered into a separate agreement with Planful (“Client Agreement”), which
may contain more restrictive terms than what is described in this Policy.


DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Personal Data” means any information or set of information that directly or
indirectly identifies or could be used by Planful or its agents to identify an
individual, such as a name, address, location data, online identifier, one or
more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that individual, and also includes information
referred to as “personally identifiable information” or “personal information”
under applicable data privacy laws, rules, or regulations.

“Aggregate Data” is de-identified information, learnings, logs, and data We
collect about a group or category of services or users.

Personal Data does not include Aggregate Data or publicly available information
that has not been combined with non-public Personal Data.


PLANFUL’S ROLE AS A DATA CONTROLLER AND DATA PROCESSOR

Planful acts as a data controller when We collect and define the purpose for and
control the means by which Personal Data is processed. For example, Planful acts
as a data controller when collecting customer feedback or information to improve
Our Services.

Planful acts as a data processor when We provide our Services to our Clients.
When acting as a data processor, Planful will only process Personal Data in
accordance with a Client’s instructions, Client Agreement, and this Policy.


INFORMATION THAT WE COLLECT FROM YOU:

We collect information You share with us through our Site and when You register
for and use our Services or participate in Planful events.

Information collected from the Site:

Automatically Collected Information from the Site. We automatically receive
certain types of information when You interact with Our Site, services, and
communications. Your Web browser may automatically send information to every
site You visit, including Ours. That information includes Your computer’s IP
address, access times, Your browser type and language, Internet service provider
(ISP), and referring site addresses. We may also collect information about the
type of operating system You use, Your account activity, and files and pages
accessed or used by You. We do not link this automatically-collected information
to Personal Data.

Local Storage (HTML5) We and Our third-party partners use Local Storage (HTML5)
to provide certain features on Our Site, display advertising based on Your Web
browsing activities, or store content information and preferences. Various
browsers may offer their own management tools for removing HTML5.

Information Provided by You. As You engage with the Site You may choose to share
Personal Data, such as Your first and last name, job title, email address,
mailing address, phone number, and company name.

Cookies and Tracking Technologies. We and Our partners, affiliates, or analytics
or service providers may use certain kinds of technology such as cookies, Web
beacons, scripts, and tags to collect information, analyze trends, administer
the Site, track users’ movements around the Site, and gather demographic
information about our user base as a whole. We may receive reports based on the
use of these technologies from these companies on an individual or aggregated
basis. To learn more about Our use of cookies and tracking technologies, please
refer to Our Cookie Policy.

Information collected from the Planful Sponsored events:

When You register for Planful sponsored events You may be required to provide
Personal Data, such as Your first and last name, Company name, business email,
Your job title, billing information (such as billing name, billing address, and
credit card number), dietary restrictions and preferences.

Information collected when You Register as Planful’s Client:

Registration and Profile Information. When You register to use the Services, We
may collect information about You, such as Your name, email address, title,
company and other information You provide.

Payment Information. If You are Our Client, You will be providing Us with Your
payment information to pay for the Services, including Your credit card
information and billing address.

Submissions and Customer Service. From time to time, We may use surveys,
contests, or sweepstakes requesting Personal Data or demographic information and
Client feedback. Participation in these surveys or contests is completely
voluntary and You have a choice whether to disclose this information. We may
also use Personal Data to provide customer support, resolve customer issues, and
apply fixes to bugs.

Information collected when You Apply to Planful’s Job Postings

Contact Information. When You apply to work at Planful, We collect personal
identifiers and contact information from You, such as Your first name, last
name, mailing address, email address, and phone number.

Employment History and References. When You apply to work at Planful, We collect
information about Your current and previous employment information, such as Your
job title, name of the employer, and employment history. You may also be asked
to provide professional references, which includes disclosure of the following
Personal Data of Your references: the first and last name, job title, email
address, and phone number.

Protected Classifications Under State and Federal Law. As part of Your
employment application, We may also collect data regarding Your gender, veteran
status, race, and disability status. The provision of this data by You is
optional.

No Sensitive Data

Planful does not generally collect sensitive Personal Data, which includes
Personal data such as racial or ethnic origins, religious, political, or
philosophical beliefs, health or medical information, genetic or biometric data,
back account information (except when required to process your purchases), or
other sensitive Personal Data as defined by applicable law. Planful will obtain
Your consent should We need to collect Your sensitive Personal Data.


INFORMATION PROVIDED BY THIRD PARTY SOURCES

Planful may collect Personal Data about You from third parties from whom Planful
purchased business contact information. Planful may also use publicly accessible
Websites, such as professional network sites, press releases, or Your employer’s
Website to collect such information. The Personal Data that Planful may collect
from Third Parties includes: first and last name, email address, phone number,
company’s mailing address, job title, employment history, company name, and
online identifier.


HOW WE USE YOUR PERSONAL DATA

To provide You with Services, Site, and support;

To contact You: We use Your Personal Data and information We collect about Your
activities on the Site to contact You with promotional content based on Your
preferences, including but not limited to telemarketing calls, marketing emails,
newsletters, whitepapers, and information on upcoming events. We also use it to
send administrative information, such as notices related to Services or policy
changes.

To administer Your account: We may also use Your Personal Data to facilitate
Your account administration and use of the operation of the Site and Services;

To inform You: We use Your Personal Data to provide You with information or
services You request, including our product documentation and white papers as
Well as update You on our events, promotions, products or services We believe
will be of interest to You;

To elicit Your feedback: We may use Your Personal Data to contact You for
feedback to enable Us to develop, customize, and improve the Site and Services;

To communicate with You: We may use Your Personal Data to send You an onboarding
Welcome email and contact You about Your use of the Site and Services; to
respond to Your emails, submissions, requests, or complaints; to perform
after-sales services; to anticipate and resolve problems with our Services; to
respond to support inquiries, and to inform You of updates to the Services;

To Manage Events: We use Your Personal Data to manage events sponsored by
Planful, including registration, billing, and connecting with other event
attendees, or to contact You further about relevant products and services. You
may also provide Us with information about Your emergency contacts or dietary
preferences, which would be used solely for Your safety and health.

To Process Your Application for Employment with Us: We use Your Personal Data to
review Your candidacy for the job postings to which You applied.

Accomplish other purposes about which We notify You.

Planful does not sell Personal Data that We collect or process under this
Privacy Policy.

Aggregate Data

Aggregate Data helps us understand trends in our users’ needs, so that We can
consider new features or better tailor our services. This Policy in no way
restricts or limits our collection and use of Aggregate Data. We may share
Aggregate Data about our users with third parties for various purposes,
including to help us better understand our Customers’ needs, improve our
services, and for advertising and marketing purposes.


HOW WE SHARE YOUR PERSONAL DATA

Service Providers. We engage with service providers to perform business
functions and provide services to us. We use third-party services to help
operate our services and use third party providers for such functions as data
hosting, analytics, customer relationship management, and email service. Planful
may share Your Personal Data with these service providers only on Planful’s
behalf and solely pursuant to Our instructions and subject to obligations
consistent with this Policy and any other appropriate confidentiality, privacy,
and security measures.

To comply with applicable laws. We may disclose information to a third party as
required by law when We believe in good faith that disclosure is necessary (i)to
comply with a regulation, court order, subpoena, or a similar legal process,
(ii) to enforce Our policies, terms of use, or Our contracts, (iii) to protect
Us, Our agents, Our customers, and Our associates, (iv) to respond to an
emergency, protect personal safety, or to help prevent security threats, fraud,
or other malicious activity, (v) to respond to an authorized information request
of a government or law enforcement authorities. We will have no duty to notify
You of such compliance with local law where applicable.

Events and Partners. Planful and its partners may offer services jointly –
Webinars, events, whitepaper downloads, or other services related to Planful
offerings or services. We may share Your contact information and interests in
these offerings with these approved partners and third parties solely to
communicate with You about Planful’s Services and the approved partner’s
services.

Corporate Affiliates. Planful may share Personal Data with its corporate
affiliates, parent(s), or subsidiaries.

Business Transition. We may also share Personal Data in connection with an
acquisition, merger, or sale of all or a substantial portion of Our business,
with or to another company. In any such event, We will notify You if Your data
is transferred and becomes subject to a substantially different privacy policy.


GLOBAL OPERATIONS AND INTERNATIONAL DATA TRANSFERS

To facilitate Our global operations, We may transfer, store and process Your
Personal Data in jurisdictions other than where You live, including in the
United States. Laws in these countries may differ from the laws applicable to
Your country of residence. For instance, if You are a European Economic Area
(EEA) data subject and Your Personal Data is shared with our affiliates,
partners, or third-party service providers acting on Our behalf outside of the
EEA, then it is done so pursuant to necessary means to ensure an adequate level
of protection.

Standard Contractual Clauses. Planful offers Standard Contractual Clauses, also
known as E.U. Model Clauses, to meet the adequacy and security requirements for
Our Clients that operate in the E.U. and other international transfers of Client
data. To receive a copy of our standard Data Processing Addendum, incorporating
Standard Contractual Clauses, please email dpo@planful.com. In addition,
Planful, Inc. has executed Standard Contractual Clauses with its sub processors
who process Personal Data on behalf of Planful, Inc.

Privacy Shield. Planful, Inc. participates in and has certified its compliance
with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield
Framework. To learn more about the Privacy Shield Framework, visit the U.S.
Department of Commerce’s Privacy Shield List.

Planful, Inc. is responsible for the processing of Personal Data it receives,
under each Privacy Shield Framework, and subsequently transfers to a third party
acting as an agent on its behalf. Planful, Inc. complies with the Privacy Shield
Principles and the Standard Contractual Clauses for all onward transfers of
Personal Data from the EU and Switzerland, including the onward transfer
liability provisions.

With respect to Personal Data received or transferred pursuant to the Privacy
Shield Frameworks, Planful, Inc. is subject to the regulatory enforcement powers
of the U.S. Federal Trade Commission. In certain situations, Planful, Inc. may
be required to disclose Personal Data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements. Planful, Inc. is also subject to the enforcement powers of the
applicable EU supervisory data authority.

If You have an unresolved privacy or data use concern that We have not addressed
satisfactorily, please contact our U.S.-based third-party dispute resolution
provider (free of charge).

Under certain conditions, more fully described on the Privacy Shield Website,
You may invoke binding arbitration when other dispute resolution procedures have
been exhausted.


EUROPEAN UNION RESIDENT DATA SUBJECT RIGHTS UNDER THE GENERAL DATA PROTECTION
REGULATION (“GDPR”)

If You are a resident of the European Union, United Kingdom, Lichtenstein,
Switzerland, Iceland, or Norway, You have the data subject rights under the GDPR
as described in the table below. If You have questions whether any of the
following applies to you, please contact Us at dpo@planful.com or through the
Planful Privacy Portal and we will respond to Your questions as soon as
practicable.

Please note that We process Personal Data of our Clients’ end users or employees
in connection with our provision of Services, in which case We may not be able
to respond to You request. As such, please contact the data controller (Your
employer or university) to address your rights with respect to such data.

Personal Data Processed by Planful’s Services Personal Data Collected by Planful
Right to Erasure Planful does not have control over the Client data that is
stored and processed by using the Services. As such, all requests to delete
Personal Data should be addressed to Your employer or university (data
controller). If the data controller cannot fulfill Your request and asks Us to
address it, we will respond to the data controller within 30 days. Even if You
request that We delete Your Personal Data, We may still retain data collected
from you in an aggregated and anonymized form. If You would like to delete Your
Personal Data, please contact Us at dpo@planful.com or through the Planful
Privacy Portal and We will respond to your request within 30 days. Even if You
request that We delete Your Personal Data, We may still retain data collected
from you in an aggregated and anonymized form. Right to Access and Rectification
Planful does not have control over the Client data that is stored and processed
by using the Services. As such, all requests to access or rectify inaccurate or
incomplete Personal Data should be addressed to Your employer or university
(data controller). If the data controller cannot fulfill Your request and asks
Us to address it, we will respond to the data controller within 30 days. If You
would like to access or rectify inaccurate or incomplete Personal Data, please
contact Us at dpo@planful.com or through the Planful Privacy Portal and We will
respond to your request within 30 days. Right to Data Portability Planful does
not have control over the Client data that is stored and processed by using the
Services. As such, all requests to receive a copy of Your Personal Data should
be addressed to Your employer or university (data controller). If the data
controller cannot fulfill Your request and asks Us to address it, we will
respond to the data controller within 30 days. If You would like to receive a
copy of Your Personal Data, please contact Us at dpo@planful.com or through the
Planful Privacy Portal and We will respond to your request within 30 days. Right
to Object to Processing If You object to any processing by Planful, please
communicate such request to your employer or university (data controller). If
you communicate such request to Us, We will notify the data controller as soon
as possible. Right to Restrict Processing You have a right to restrict
processing of Your Personal Data by Planful. Please send Your request to
dpo@planful.com or through the Planful Privacy Portal. Right to Withdraw Consent
If We are processing your Personal Data based on Your consent, You have the
right to withdraw Your consent at any time by emailing dpo@planful.com or the
Planful Privacy Portal Right to File a Complaint You can contact our DPO by
emailing dpo@planful.com. If We are unable to resolve Your complaint, You can
contract the European Data Supervisory Authority for Planful, Inc., which is the
Office of the Data Protection Commissioner. They can be contacted here: Canal
House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland. email
info@dataprotection.ie

Personal Data Processing Grounds

When We process Your Personal Data, We do so on the following grounds:

Performance under a Contract: We may process Your Personal Data as part of Our
contractual obligations to You or Your employer/university.

Consent: We may process Personal Data based on the consent You expressly grant
to us at the time we collect such data. You can withdraw Your consent at any
time, which will not affect the lawfulness of the processing before Your consent
was withdrawn.

Legitimate Interest: We process Personal Data for the legitimate interests of
Planful and that Our partners, affiliates, and Clients. These legitimate
interests include, investigating illegal activities, detecting security issues,
improving and maintaining the Site and the Services, contacting You to provide
support, sending you relevant marketing information (subject to applicable
laws). We will balance our interests and rights against the impact of the
processing on data subjects.

Legal Obligation & Other Grounds: We may need to process Your Personal Data to
comply with a legal obligation, such as a lawful subpoena, court order,
law-enforcement request, or to fulfill the lawful instructions of Our Clients
(when they are acting as the data controller). We may also need to process Your
Personal Data to protect vital interests and defend legal claims.


CALIFORNIA RESIDENT RIGHTS

If You are a California resident, You have the following rights with regards to
Your Personal Data. If You have any questions about this section, whether any of
the following applies to You, or to exercise Your rights, please email
dpo@planful.com or through the Planful Privacy Portal.

Right to Disclosure & Access You have the right to request certain information
about our collection and use of your Personal Data over the past 12 months. We
will provide you with the following information: (i) categories of Personal Data
that We have collected about You; (ii) categories of sources from which that
Personal Data was collected; (iii) categories of third parties with whom We have
shared Your Personal Data; (iv) the business or commercial purpose for
collecting or selling Your Personal Data; (v) the specific items of Personal
Data that We collected about You; and (vi) if We disclosed/sold Your Personal
Data over the last 12 months, We will identify the categories of Personal Data
shared/sold with each category of third-party recipient. For more information on
collection, use, and sharing of Your Personal Data, please refer to the Sections
titled “Information that We Collect from You”, “How We Use Your Personal Data”,
and “How We Share Your Personal Data”.

Right to Correction You have the right to request that We correct Your Personal
Data.

Right to Deletion You have the right to request that We delete the Personal Data
that we have collected from You.

Right to Data Portability. You may request to receive the specific pieces of
Your Personal Data, including a copy in a portable format.

Right to Opt-Out of Sales or Sharing. You can ask that we do not “sell” or
“share” your Personal Data as “sell” and “share” are explicitly defined under
the CCPA. For more information, please refer to the section titled “Sale and
Sharing of Personal Data under California Law” below.

Right to be Free from Discrimination. You may freely exercise these rights
without fear of being denied our Services. We will not charge You different
prices or rates or provide You with a lower quality of services if You exercise
Your rights under CCPA.

Sale and Sharing of Personal Data under California Law
We do not sell Personal Data in the conventional sense. However, when You use
Planful’s websites, Planful’s authorized third parties may collect information
on you by using web cookies or similar technologies and use such data for their
own purposes. Making your Personal Data available to these third parties may
qualify as “sale” or “sharing” of Your Personal Data under CCPA. For more
information on sharing of Your Personal Data, please refer to the Section “How
We Share Your Personal Data”.

You may request to opt-out of “sale” or “sharing” of Your Personal Data by using
the Cookie Consent Manager. To learn more about Our use of cookies and tracking
technologies, please refer to Our Cookie Policy.

Sensitive Personal Data under California Law
As stated in the Section “Information that We Collect from You”, we generally do
not collect sensitive Personal Data. We may collect Your Driver’s License,
Passport, or another form of identification to verify your identity in certain
instances, such as for an event or office visit. If We collect Your sensitive
Personal Data, We will not disclose it to third parties and only use it for
purposes permitted under CCPA and CPRA such as performing the Services, ensuring
physical safety of persons, and preventing, detecting, and investigating
security incidents. We do not collect Your sensitive Personal Data to infer any
characteristics about You.

Exercising Your Rights.All requests pursuant to this section must be addressed
to dpo@planful.com or through the Planful Privacy Portal. In compliance with
CCPA We will require certain identifying information from You to verify Your
request. We will make best efforts to respond to Your valid request within 45
days from the receipt. In some instances, We may be required to continue to
retain or share portions of your Personal Data to comply with regulatory or
legal obligations.


OTHER STATE RESIDENT RIGHTS

Nevada If You are a Nevada resident, You have the right to opt-out of the sale
of certain Personal Data to third parties who intend to license or sell that
Personal Data. You can exercise this right by contacting Us
at dpo@planful.com or through the Planful Privacy Portal and providing us with
your name and the email address associated with your account. We do not
currently sell Your Personal Data as sales are defined in Nevada Revised
Statutes Chapter 603A.


CHILDREN’S PRIVACY

Planful does not knowingly collect or solicit Personal Data from anyone under
the age of 16. If We learn that We have collected Personal Data from a child
under age 16, We will delete the information We have stored as quickly as
possible. If You believe that We might have any information from or about a
child under 16, please contact us at dpo@planful.com.


SECURITY

Planful, Inc. uses industry standard security measures to protect against the
loss, misuse and alteration of the Personal Data under Our control. Although We
make good faith efforts to store the Personal Data collected by Planful, Inc. in
a secure operating environment that is not available to the public, Planful,
Inc. cannot guarantee complete security. Further, while We take reasonable steps
to ensure the integrity and security of our network and systems, We cannot
guarantee that our security measures will prevent third-party “hackers” from
obtaining this information.


DATA RETENTION

Planful retains the Personal Data we receive as described in this Privacy Policy
for as long as You use Our Services or as necessary to fulfill the purpose(s)
for which it was collected, provide Our Services, resolve disputes, establish
legal defenses, conduct audits, pursue legitimate business purposes, enforce our
agreements, and comply with applicable laws.


CHANGES TO THIS PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements
of the Privacy Shield Principles. Appropriate public notice will be given
concerning material amendments or changes to this Policy. If We make any
material changes, We will notify You by email (sent to the e-mail address
specified in Your account) or by means of a notice on this Website prior to the
change becoming effective. We encourage You to periodically review this page for
the latest information on our privacy practices.


CONTACT OUR DATA PROTECTION OFFICER

Any questions or concerns regarding the use or disclosure of Personal Data
should be directed to Planful, Inc. at the address given below. Planful, Inc.
will investigate and attempt to resolve complaints and disputes regarding use
and disclosure of Personal Data in accordance with the principles contained in
this Policy.

Planful, Inc. DPO
555 Twin Dolphin Drive, Suite 400
Redwood City, CA 94065

+1 (888) 914-9661
PIN: 196383
or via email at dpo@planful.com


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PRIVACY PREFERENCE CENTER

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browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
and the services we are able to offer.
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STRICTLY NECESSARY COOKIES

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These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser to block
or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.

TARGETING COOKIES

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.

FUNCTIONAL COOKIES

Functional Cookies

These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages. If you do not allow these cookies then some
or all of these services may not function properly.

PERFORMANCE COOKIES

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

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