Julep Wellness Privacy Policy

Introduction

Welcome to Julep Wellness, LLC (“Julep” or “we”)! We prioritize the protection and privacy of your data, including personal information. This Privacy Policy outlines our practices and the uses of information gathered through our website (http://www.julep.app), mobile application (the “app”), and other services (collectively referred to as the “Services”).

Consent

By using the Services, you consent to the terms of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, including having your personally identifiable information (“Personal Information” as defined below) used in any of the ways described in this Privacy Policy, you may be unable to access certain features, necessitating the revocation of your subscription and/or service access.

Consent to Our Terms and Conditions

This Privacy Policy is part of our Terms of Use. Please review our Terms of Use to understand disclaimers, limitations of liability, and your overall consent to using our Services.

Access

When using our Services, you’ll be assigned a user ID and password. Your user ID and password may only be used by you. You may not share your user ID and password with anyone else and you are solely responsible for maintaining and protecting the confidentiality of your user ID and password. You are fully responsible for all activities that occur under your user ID and password.

Personal Information

Definition

“Personal Information” includes data like your name and email that specifically identifies you.

Collection and Storage

By voluntarily providing Personal Information, you consent to its use and storage within the United States. For EU or UK users, we employ safeguards compliant with relevant regulations. When we transfer, store or process Personal Information outside of your jurisdiction, we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Policy and applicable law. For individuals in the European Union or the United Kingdom, we may use contracts or the Standard Contractual Clauses approved by the European Commission or, as may be applicable, the equivalent clauses approved by the UK Government, to help ensure your information is protected. For more information on the transfer safeguards we rely on please contact us at: yourfriends@julep.app.

Information Collection

We collect information in various ways:

· Submitted Information: Voluntarily provided during your use of the Service. We also collect user submitted financial information you submit through our platform or Services (“User Submitted Content”). We do not collect or store billing information directly.

· Third Party Information: Received when connecting your account to third-party services. For example, you may choose to connect your social media account or login with such credentials. We also use a third-party billing processor, who will collect and store your billing information and process payments for the Services. We do not receive or store your billing information.

· Linked Information: Provided by third-party processors without storing your credentials. We also use a third-party processor (Plaid: http://www.plaid.com) who connects with your financial account information and provides us account balances and transactions. For example, to provide your Julep account with information from your bank accounts. We do not have, receive, or store your account credentials. We receive a token from our third-party provider which is used to retrieve account balance and transaction information only. Our third-party provider does not share your financial account credentials with Julep. You are subject to such third-party providers’ terms of use and privacy policy.

· Usage Information: Collected through tools like Google Analytics. We may also collect general, non-personal, statistical information about the use of the Services, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they click on.

· Cookies: Automatically collected non-personally identifiable information. The use of cookies helps us improve the quality of the Services we provide to you, by identifying information which is most interesting to you or storing information you may want to retrieve on a regular basis. At any time, you may adjust settings on your browser to refuse cookies according to the instructions related to your browser. You may also get cookies from our advertisers or other third parties with links on the Site as described below. We do not directly control these cookies. The use of advertising cookies sent by third party ad servers is standard in the Internet industry.

· Device Information: Details about your device. We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.

· Support Information: Collected when you reach out for assistance. We may collect personal information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, subscribe to marketing, attend our events, participate in product research or training or otherwise interact or communicate with us.

· Social and Community Content: Information you post on social and community pages.

· Coach Communications: Details about interactions with financial coaches. The Julep Services may provide an opportunity for you to connect with live financial coaches.

· Publicly-available and Third-party Source Information: Data from public databases.

How We Use the Information

We use collected information for personalization, communication, research, safety, security, legal rights, business interests, and specific consents. How we use the information we collect also depends in part on which of our Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the Personal Information we collect about you.

To provide Services and personalize your experience: We use Personal Information to provide a more personalized experience, authenticate you or your device when you log in, to connect you with a financial coach, to provide customer support and to operate and maintain the Services.

Communication: We use your Personal Information to send certain communications via email, including responding to your comments, questions and requests, providing customer support, and sending you technical notices or updates, security alerts, and administrative messages. We use Mailchimp to collect emails, manage email subscriber lists and to send emails to our subscribers. When you provide your email or additional information when signing up for our newsletters such Personal Information is sent directly to Mailchimp. You can control whether you want to receive these communications by opting-out whenever you receive such a communication from Julep Wellness by using the included opt-out link in any such communication.

For research and development: We are always looking for ways to make our Site and Services smarter, faster, better integrated, more secure and useful to you. We use collective learnings about how people use our Site and Services and feedback provided to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement.

For safety and security: We use information about you and your use of the Site and Services to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of our policies. Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, to publish testimonials or featured customer stories with your permission.

Information Sharing

We disclose Personal Information under certain conditions, including user permission, legal requirements, business transactions, and service providers. We do not disclose Personal Information to third parties, except when one or more of the following conditions is true; we have your permission:

· The disclosure assists in fulfilling the purpose for which the personal information was obtained;

· The disclosure is permitted by applicable law;

· The Personal Information to be disclosed is otherwise publicly available through no fault of Julep Wellness;

· The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets;

· The disclosure is for our own marketing purposes; or

· The disclosure is to outside businesses to perform certain services for us, such as maintaining our Services, mailing lists, data analysis, processing orders, and delivering the Services.

Furthermore, we may disclose Personal Information or User Submitted Content if the disclosure is, in our sole discretion, desirable for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, subpoena or government request, or in connection with litigation. We may also disclose aggregate visitor data in order to describe the use of the Services to our existing or potential business partners or other third parties, or in response to a government request.

Security Measures

We use various service providers to host the Site, host the technology used to provide the Services and store and secure the data we collect. We ensure a variety of security measures are implemented by such service providers, including firewalls, Secure Socket Layer (SSL) technology, encryption and authentication tools, to help protect your information. Various security measures are in place, such as firewalls and encryption, through our service providers like Amazon (“AWS”). You can learn about Amazon’s security here: https://aws.amazon.com/security/

Third-Party Websites and Links

While we currently do not have third-party links, future additions are subject to their privacy policies. We disclaim liability for actions of third parties. Our Services do not currently contain any third-party links. In the future we may add or the Site and Services may contain links to other sites operated by third parties. Julep Wellness does not control such other sites and is not responsible for their content, their privacy policies, or their use of any information. Julep Wellness does not support or endorse any third party unless Julep Wellness expressly states such support or endorsement. Any information submitted by you to these third parties is subject to that third party’s privacy policy. In addition, if you click on links, which take you to third party websites, you may be subject to the third parties’ privacy policies. While we support the protection of our customer’s privacy on the Internet, Julep Wellness expressly disclaims any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties.

Personal Rights

You are, as data-owner and user of the Site and Service, entitled to (i) access your Personal Information and be informed about the way in which your information is treated, (ii) rectify your Personal Information in case it is not up-to-date, it is inaccurate or incomplete, (iii) ask for your data to be removed if you consider that it is not used in accordance with the applicable principles, duties and obligations, and (iv) object to the processing of your Personal Information for specific purposes. These rights are known as “Personal Rights”.

How to Exercise Your Personal Rights. If you decide to exercise your Personal Rights, your request should be emailed to yourfriends@julep.app, together with the following information and documentation:

Your ID information and, if applicable, the information of your legal representative. For legal representative, please attach a copy of his/her power-of-attorney.

A clear and precise description of the Personal Information about which the Personal Rights are to be exercised, as well as the right or rights that are to be exercised.

An address where you desire to hear and receive Julep Wellness’s response and any future communications and/or notifications, or, in its case, your desire to receive our response and/or future notifications or responses via email, providing us with your email address.

If you prefer to correspond via email, you must expressly state your desire to receive Julep Wellness’s response through an email communication, specifying the corresponding email address.

Julep Wellness will issue a response within a timely manner following receipt of your request, which will be informed to you using your selected method. Once you receive our response you will have a 20-business day period to respond to our communication. In the event you need to speak with us or in the event you disagree with our response please contact us at to yourfriends@julep.app along with a phone number for us to reach you, in order for Julep Wellness to discuss with you any issue. In case you do not reply to our response within the before mentioned period we will understand in good faith that you agree with our conclusion.

If your request refers to your right to access data, Julep Wellness will provide you with copies of the information and/or scanned documents.

Julep Wellness may refuse the exercise of your Personal Rights in instances permitted by the laws and regulations of the Territories which are applicable to your use and shall inform you about such decision. The refusal may be partial, in which case Julep Wellness will carry out the access, rectification, cancellation, deletion, or objection in the corresponding part.

Revocation of Consent

You, as data-owner, can revoke your consent to the treatment of your Personal Information in accordance with the procedure set forth above “How to Exercise your Personal Rights”, in the understanding that once we receive your request to revoke your consent we will issue our response within a five-day period.

Children’s Privacy

Our Services are not intended for individuals under 18 years old.

Governing Law

This Privacy Policy is subject exclusively to the laws of Delaware.

Changes to Privacy Policy

We may update this Privacy Policy, and your continued use of the Services implies agreement with modifications.

How to Contact Us

All requests, questions, concerns, or complaints about your Personal Information or this Privacy Policy, please contact us at the following: to yourfriends@julep.app.