Effective Date: August 15, 2022

Magnifi U, Inc. (“Company,” “we,” “our,” or “us”) is committed to respecting and protecting the privacy of our users. This Privacy Policy (“Policy”), describes how we collect, use, and disclose information that we obtain about visitors to our website, magnifiu.com, (the “Site”), our mobile application (the “Application”), and the services available through our Site and Application (collectively, the “Services”), and does not apply to any other platforms or services that we own or operate.

Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes.

The Information We Collect About You

We collect information about you directly from you and from third parties, and automatically through your use of our Services.

Information We Collect Directly from You. The information we collect from you depends on how you use our Services. Information we collect may include:

  • When you create an account, we collect your username, name, e-mail address, mailing and billing addresses, and zip code. We also collect information such as your technology requirements, life stage, topics of interest, goals, accomplishments, education level, and military status. If you choose to provide it to us, we may also collect information such as your preferred pronouns.
  • When you purchase products or services from us, we collect your contact information, billing and mailing address, phone number, order information, including details of products and subscriptions you choose to purchase, and payment information.
  • When you use the Services, we collect information such as the types of courses you have completed, your responses on course quizzes, and your feedback regarding products and services you have requested or purchased from us.
  • We collect information and we use it to track badges and rewards that you earn when using the Services, such as information about your participation in contests, your leaderboard status, and your uses of rewards points you may receive through the Services.
  • We collect photos, videos, and user generated content, such as comments and feedback, that you choose to provide when using the Services, including when you choose to make your user generated content available to other users of our Services.
  • When you subscribe to receive updates from us about new features available on our Site or though the Services, we collect contact information from you, such as your name, mailing address, e-mail address, or telephone number.
  • We collect the information you provide us when you fill out a survey, questionnaire, or other type of form you complete through the Services. If you contact us, we collect records and copies of your correspondence, including e-mail addresses and other contact information.
  • While you are navigating the Site or using the Services, we may also collect your search queries or information about your viewing history.
  • We collect any information you choose to e-mail or communicate to us while using the Services.

Information We Collect Automatically. We automatically collect information about your use of our Services through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

When you use our Site, we may collect your browser type and operating system, web pages you view on the Site, links you click on the Site, and your IP address. We may also collect information about the length of time you spent visiting our Site and/or using our Services, and the referring URL, or the web pages that led you to our Site.

Information We Collect from Other Entities. When you access the Services, we may collect information about you from third-party sources, such as: service providers, business partners, public and third-party databases, platform providers, non- affiliated partners, other users of our Services, public sources, third-party advertising partners, or from other third parties. Information we collect may be combined with other information we have collected about you in order to complete requests you have made or facilitate transactions you have initiated via the Services, or for other purposes, for which we provide you with notice or to which you consent. Information we may collect about you from third-party sources may include your name, e-mail address, mailing address, phone number, and other contact information.

Additionally, you may be able to choose to log into our Services through a third- party account such as Facebook or Google. If you log into our Services using your third-party account, you must enter your third-party account login information; however, we do not collect the log-in information.

We store the information that we receive from third parties with other information that we collect from you (like when you created an account) or receive about you (from third parties). The third-party platform controls the information it collects from you. For information about how third-party platforms may use and disclose your information, including any information you make public, please look at their respective privacy policies. We have no control over how any third-party uses or discloses the personal information it collects about you.

How We Use Your Information

Our Uses of Your Personal Information. We use your information, including your personal information, for the following purposes:

  • To present our Site, Application, and their contents to you, or to provide you with access to the Services.
  • To provide you with information, products, or services that you request from us.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, such as for billing and collection.
  • To notify you about changes to our Services, or any products or services we offer or provide though the Services.
  • To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes
  • To tailor the content and information that we may send or display to you, including customized product recommendations, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Services
  • To contact you via e-mail or text messages regarding services you have requested from us
  • For marketing purposes, including to provide you with special offers, promotions, news, and newsletters; to contact you about products we think may interest you; to administer contests, promotions, and other offers; and for other marketing, advertising, and promotional purposes.
  • To better understand how users access and use our Services, both on an aggregated and individualized basis
  • To handle inquiries and complaints you or other users of our Services submit to us.
  • To administer surveys and questionnaires, such as for market research or user satisfaction purposes
  • For research and analytics purposes, including analyzing data, identifying trends and issues and creating statistical reports, analyzing the accuracy and effectiveness of our Services, including administering, troubleshooting, and enhancing and improving the Services.
  • To comply with legal obligations, as part of our general business operations, and for other business administration purposes, such as maintaining customer records, monitoring your compliance with any of your agreements with us, collecting debts owed to us, and safeguarding our business interests
  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, and in situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy
  • For research and analytics purposes
  • To fulfill any other purpose for which you provide the information
  • For any other purpose with your consent

How We Share Your Information

We may share your information, including personal information, as follows:

Vendors, Service Providers, and Other Processors. We may disclose the information we collect from you to vendors, service providers, contractors, agents, or other processors who perform functions on our behalf. For example, we share your information with customer management providers, IT services providers, data storage providers, technical support providers, payment processors, and shipping providers. We also share your information with service providers who host our Site and Application, analyze aggregate information about our customers, assist us in detecting and deterring fraud, security incidents, or other unlawful activity, and for other business purposes as described in the How We Use Your Information section.

Subsidiaries and Affiliates. We may disclose the information we collect from you to any current or future parent company, affiliate, subsidiary, or division.

Site and Application Users. We may share your information with other users of our Site and Application. For example, if you post a review, pictures, or other content on our Services, the contents of your post (including pictures and videos that you post) as well as other information, such as your username, may be available to all visitors to our Site and Applications. Additionally, if you sign up for or purchase

certain features of our Services, such as participating in group activities, meetings, or programs available to other users, we may share your information with other users of our Site and Application to help facilitate your use of those features and to deliver the Services to you.

Analytics Providers/Advertisers. As set forth above, we share information with analytics providers and advertisers to assist us in implementing and evaluating relevant advertising. Often, the information that we share is collected from you through cookies and other tracking technologies on our Sites and Application. See the section Our Use of Cookies and Other Tracking Mechanisms for more information.

In addition, we may also share your personal information under the following circumstances:

Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.

  • In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.

Aggregate and De-Identified Information. We share aggregate or de-identified information about users with third parties for marketing, advertising, research, or other purposes.

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Services. We may combine this information with other personal information we collect from you (and our third- party service providers may do so on our behalf).

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities while using our Services. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in and as you move through our Services.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve the performance of our Sites, Services, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/.

You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Use. We and our third party service providers, including Google, may use the information that we collect about you (whether directly from our Site, through your device(s), or from a third party) to help us and our third party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers also may use the cross- device use and other information we learn about you to serve targeted advertising on your devices and to send you e-mails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Third-Party Ad Networks section below. Please note: if you opt-out of these targeted advertising cookies, your opt- out may be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you may need to opt-out from each browser or device that you use.

Do-Not-Track Signals. Please note that our Site does not recognize or respond to any signal which your browser might transmit through the so-called “Do Not Track” feature your browser might have. If you wish to disable cookies on our Site, you should not rely on any “Do Not Track” feature your browser might have. For more information about do-not-track signals, please click here.

Ad Networks. We use network advertisers to serve advertisements on non- affiliated websites or other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, pixels, LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you.

Users may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising. Please be advised that opting out of ad networks will opt you out from certain companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Additional information is available on the DAA’s website at www.aboutads.info and https://youradchoices.com/appchoices.

Session Replay Technology. Session replay technologies, such as Hotjar, may be used to collect information regarding visitor behavior on the Services. For more information about Hotjar, please see the Hotjar Privacy Policy available at https://www.hotjar.com/legal/policies/privacy/.

User Generated Content

We invite you to post content on our Services, including your comments and reviews that you would like to be available on our Services. If you post content to our Services, including photos, videos, and reviews, all of the information that you post will be available to all users on our Services. If you post your own content on our Services, your posting may become public and we will not have control over how your content may be used by third parties. We may also request your permission to share your user generated content, such as photos and videos, via social media platforms, subject to the terms of the relevant social media platform.

Third-Party Links

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of Your Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing of after using a shared computer, choosing a robust, unique password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access Your Personal Information

You may access, modify and request correction of any inaccurate personal information that you have submitted by contacting us using the information in the Contact Us section below.

Your Choices Regarding Our Use of Your Personal Information

We may send periodic promotional e-mails to you. You may opt-out of promotional e-mails by following the opt-out instructions contained in the e-mail. If you opt-out of receiving promotional e-mails, we may still send you e-mails about your account or any services you have requested or received from us.

Notice Concerning Children

We do not knowingly collect, use, or disclose information from children under 18, except as required by law or regulation. If we learn that we have collected the personal information of a child under 18, we will take steps to delete the information as soon as possible. Please immediately contact us if you become aware that a child has provided us with personal information.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and if it is appropriate, notify (either by email or indirectly when you next open the Application or visit the Site.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at:

Magnifi U, Inc.
6 North Main Street
Fairport, NY 14450

E-mail: contact@magnifiu.com