Plus.Fan

Privacy Policy

Last Updated: May 23, 2025

This Privacy Policy (“Policy”) describes how PlusFan Inc. (“we,” “us,” or “our“), may access,

collect, store, use, and/or share (“process“) your personal information when you visit our

website at https://plus.fan/ or any other website that links to this Policy, use our application, or

engage with us in other ways including through any PlusFan, Inc. sales, marketing, or events

(collectively the “Services”). By using our Services, you acknowledge that you have read and

understood this policy. If you do not agree with our data management practices, do not use the

Services. BY USING THE SERVICES, YOU AGREE THAT YOU CONSENT TO THE

COLLECTION AND USE OF YOUR INFORMATION AS OUTLINED IN THIS POLICY.

Questions or concerns? Reading this Policy will help you understand your privacy rights and

choices. We are responsible for making decisions about how your personal information is

processed. If you do not agree with our policies and practices, please do not use our Services. If

you still have any questions or concerns, please contact us at info@plus.fan.

Summary

The following information summarizes the Policy. Please review the full Policy carefully for all

information about how we may collect, use, and disclose your information.

What personal information do we process? When you visit, use, or navigate to our Services,

we may process personal information depending on how you interact with us and the Services,

the choices you make, and the products and features you use.

Do we process any sensitive personal information? Yes, we process sensitive personal

information. The sensitive personal information we process includes precise geolocation

information.

Do we collect any information from third parties? Yes, we collect information from third

parties as described in this Privacy Policy.

How do we process your information? We process your information to provide, improve, and

administer our Services, communicate with you, conduct security and fraud prevention, and

comply with law. We may also process your information for other purposes with your consent,

as described in this Policy. We process your information only when we have a valid legal reason

to do so.

In what situations and with which parties do we share personal information? We may share

information in specific situations and with specific third parties, i.e., the teams to which you

subscribe, as described in this Policy.How do we keep your information safe? We have organizational and technical processes and

procedures in place to protect your personal information. However, no electronic transmission

over the internet or information storage technology is 100% secure.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a

data subject access request by contacting us, as described below. We will consider and act upon

any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS PERSONAL

INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. IS INFORMATION TRANSFERRED INTERNATIONALLY?

7. HOW LONG DO WE KEEP INFORMATION?

8. HOW DO WE KEEP INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. UNIVERSAL OPT-OUT MECHANISMS

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

FROM OR ABOUT YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us: We collect personal information that you provide to

us.We collect personal information that you voluntarily provide to us when you register on the

Services, express an interest in obtaining information about us or our products and Services,

when you participate in activities through the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on

the context of your interactions with us and the Services, the choices you make, and the products

and features you use. The personal information we collect may include the following:

Personal Identifiers: include information which can be used to identify you directly such

as given and family name, phone number, email address, mailing address, username, or

password.

Financial Information: includes information connected to your financial accounts or

which can be used to make purchases such as billing address, debit or credit card

numbers, and CVC or security number.

Payment Data: We may collect information necessary to process your payment if you

choose to make purchases, such as your payment instrument number and the security

code associated with your payment instrument. We use Stripe and Razor Pay to process

payments. You may find their privacy notices here: https://stripe.com/privacy/ and

https://razorpay.com/privacy/.

Payment processing in India is managed through our Indian agent Ten24 Private India

Ltd. DLF 2 HORIZON CENTRE 5TH FLOOR PHASE 5, Gurgaon, Basai Road,

Haryana, India, 122001.

Sensitive Information: includes information that can be used to infer characteristics

about you. We collect precise geolocation information.

You represent that all personal information that you provide to us is true, complete, and accurate,

and you will notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This

information does not reveal your specific identity (like your name or contact information) but

may include device and usage information. The personal information we collect in this manner

may include:

Internet or other electronic network activity information: such as your IP address,

browser and device characteristics, operating system, language preferences, referring

URLs, device name, information about how and when you use our Services, and other

technical information. This information is needed to maintain the security and operation

of our Services, and for our internal analytics and reporting purposes.Like many businesses, we also collect information through cookies and similar technologies, as

discussed in more detail below.

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).

Google API. Our use of information received from Google APIs will adhere to GoogleAPI

Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS INFORMATION?

We process personal information for a variety of reasons, depending on how you interact

with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. 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 Services.

To save or protect an individual’s vital interest. We may process your information when

necessary to save or protect an individual’s vital interest, such as to prevent harm.

To complete our business requirements. We may use your personal information for our own

business purposes, such as for undertaking internal research for technological development and

demonstration. This does not constitute “selling” your personal information.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS INFORMATION?

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid

legal bases on which we rely to process your personal information. As such, we may rely on the

following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use

your personal information for a specific purpose. You can withdraw your consent at any time.

Learn more about withdrawing your consent below.Performance of a Contract. We may process your personal information when we believe it is

necessary to fulfill our contractual obligations to you, including providing our Services or at your

request prior to entering into a contract with you.

Legal Obligations. We may process your information when we believe it is necessary for

compliance with our legal obligations, such as to cooperate with a law enforcement body or

regulatory agency, exercise or defend our legal rights, or disclose your information as evidence

in litigation in which we are involved.

Vital Interests. We may process your information when we believe it is necessary to protect

your vital interests or the vital interests of a third party, such as situations involving potential

threats to the safety of any person.

If you are located in India, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent)

to use your personal information.

We may also process your information if it is in furtherance of a specific purpose for which you

have provided your information to us, in this instance for the provision of the Services and in the

manner described within this Policy.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent)

to use your personal information for a specific purpose, or in situations where your permission

can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your

information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be

obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to assess,

process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next of

kin

If we have reasonable grounds to believe an individual has been, is, or may be

victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise

the availability or the accuracy of the information and the collection is reasonablefor purposes related to investigating a breach of an agreement or a contravention

of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or rules

of the court relating to the production of records

If it was produced by an individual in the course of their employment, business, or

profession and the collection is consistent with the purposes for which the

information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available as specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE PERSONAL INFORMATION?

We may share your personal information in the following 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., GoogleMaps API, Places API). Google Maps uses GPS, Wi-

Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters. 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.

Business Partners. We may share your information with our business partners, including third-

party marketing services, to offer you certain products, services, or promotions.

We have disclosed or sold to or shared with third parties, i.e., the team to which you subscribe,

personal information for the above business or commercial purposes in the preceding twelve (12)

months.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather

information when you interact with our Services. Some online tracking technologies help us

maintain the security of our Services and your account, prevent crashes, fix bugs, save your

preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our

Services for analytics and advertising, including to help manage and display advertisements, to

tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending

on your communication preferences). The third parties and service providers use their

technology to provide advertising about products and services tailored to your interests which

may appear either on our Services or on other websites.To the extent these online tracking technologies are deemed to be a “sale”/“sharing” (which

includes targeted advertising, as defined under the applicable laws) under applicable US state

laws, you can opt out of these online tracking technologies by submitting a request as described

below under “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

Specific information about how we use such technologies and how you can refuse certain

cookies is described below.

Google Analytics We may share your information with Google Analytics to analyze use of our

Services. For more information about how Google uses information from sites or apps that use

its services, please visit www.google.com/policies/privacy/partners/ or Google’s Privacy Policy.

And for information about the Google Analytics Opt-Out Browser Add-On, please visit

https://tools.google.com/dlpage/gaoptout.

6. IS INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the United States. If you are accessing our Services from outside the

United States, please be aware that your information may be transferred to, stored by, and

processed by us in our facilities and in the facilities of the third parties with whom we may share

your personal information (see “WHEN AND WITH WHOM DO WE SHARE PERSONAL

INFORMATION?” above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or

Switzerland, then other countries may not necessarily have data protection laws or other similar

laws as comprehensive as those in your country. However, we will take all necessary measures

to protect your personal information in accordance with this Privacy Policy and applicable law.

7. HOW LONG DO WE KEEP INFORMATION?

We retain personal information consistent with the Services we provide, your requests related to

your information and our business practices as set out in this Privacy Policy, unless a longer

retention period is required or permitted by law (such as tax, accounting, or other legal

requirements).

8. HOW DO WE KEEP INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures

designed to protect the security of any personal information we process. However, despite our

safeguards and efforts to secure your information, no electronic transmission over the Internet or

information storage technology is 100% secure. Although we will do our best to protect your

personal information, transmission of personal information to and from our Services is at your

own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor

do we knowingly sell such personal information. By using the Services, you represent that you

are at least 18 years old or that you are the parent or guardian of a minor under 18 years old and

consent to such minor dependent’s use of the Services. If we learn that personal information

from users under 18 years of age has been collected without parental or guardian consent, we

will deactivate the account and take reasonable measures to promptly delete such data from our

records. If you become aware of any data we may have collected from children under age 18

without parent or guardian consent, please contact us at info@plus.fan.

10. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your state of residence in the United States or in some regions, such as the

European Economic Area (EEA), United Kingdom (UK), Switzerland, India, and Canada, you

may have rights that allow you greater access to and control over your personal information.

You may review, change, or terminate your account at any time, depending on your country,

province, or state of residence.

In some regions (like the EEA, UK, Switzerland, India, and Canada), you have certain rights

under applicable data protection laws. These may include the right (i) to request access and

obtain a copy of your personal information, (ii) to request rectification or erasure of your

personal information; (iii) to restrict the processing of your personal information; (iv) if

applicable, to data portability; and (v) not to be subject to automated decision-making. In certain

circumstances, you may also have the right to object to the processing of your personal

information. You can make a related request by contacting us as described in “HOW CAN YOU

CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal

information, you also have the right to complain to your Member State data protection authority

or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information

Commissioner.

If you are located in Canada, you may contact the Office of the Privacy Commissioner and your

provincial data protection authority.

Withdrawing your consent: If we are relying on your consent to process your personal

information, which may be express and/or implied consent depending on applicable law, you

have the right to withdraw your consent at any time. You can withdraw your consent at any time

by contacting us as describe in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

below or updating your preferences.However, please note that this will not affect the lawfulness of the processing before the

withdrawal of your consent nor, when applicable law allows, will it affect the processing of your

personal information conducted in reliance on lawful processing grounds other than consent.

Account Information If you would at any time like to review or change the information in your

account or terminate your account, you can:

Log in to your account settings and update your user account; or

Contact us using the contact information provided below.

Upon your request to terminate your account, we will deactivate or delete your account and

information from our active databases. However, we may retain some information in our files to

prevent fraud, address problems, assist with any investigations, enforce our legal terms, and/or

comply with applicable legal requirements.

Cookies and similar technologies: Many web browsers are set to accept cookies by default. If

you prefer, you may choose to set your browser to remove cookies and to reject cookies. If you

choose to remove cookies or reject cookies, this could affect certain features or functions of our

Services.

If you have questions or comments about your privacy rights, you may contact us using the

information in the Contact Us section below.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Your Rights

Depending on in which U.S. state you reside, you may have rights under certain U.S. state data

protection laws. However, these rights are not absolute, and in certain cases, we may decline

your request as permitted by law. These rights include:

Right to know whether 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 applicable U.S. state privacy laws), the sale of

personal data, or profiling in furtherance of decisions that produce legal or similarly

significant effects (“profiling”)

Right to obtain a list of the categories of third parties to which we have disclosed

personal data (as permitted by applicable law) Right to limit use and disclosure of sensitive personal data (as permitted by applicable

law)

How to Exercise Your Rights To exercise your rights, you can contact us by submitting a data

subject access request via email at info@plus.fan, or by using other contact methods provided

below.

Under certain U.S. state data protection laws, you can designate an authorized agent to make a

request on your behalf. We may deny a request from an authorized agent that does not submit

written proof that they have been validly authorized to act on your behalf in accordance with

applicable laws.

Request Verification Upon receiving your verifiable request, we may need to verify your

identity to determine you are the same person about whom we have information in our system. If

you have submitted a request to opt-out of the sale of your information, to opt-out of targeted

advertising, or to opt-out of certain processing we will comply with such a request without any

additional verification. For all other requests, we will make all commercially reasonable attempts

to only use personal information provided in your request to verify your identity or authority to

make the request. However, if we cannot verify your identity from the information already

maintained by us, we may request that you provide additional information, consistent with

applicable law.

If you submit the request through an authorized agent, we may need to collect additional

information to verify your identity before processing your request, and, as noted above, the agent

will need to provide written and signed permission from you to submit such request on your

behalf. As noted above, requests submitted through an authorized agent to opt-out of the sale of

your information, to opt-out of targeted advertising, or to opt-out of certain processing do not

require verification.

California “Shine The Light” Law California Civil Code Section 1798.83, also known as the

“Shine The Light” law, permits our users who are California residents to request and obtain from

us, once a year and free of charge, information about categories of personal information (if any)

we disclosed to third parties for direct marketing purposes and the names and addresses of all

third parties with which we shared personal information in the immediately preceding calendar

year. If you are a California resident and would like to make such a request, please submit your

request in writing to us by using the contact details provided in the section “HOW CAN YOU

CONTACT US ABOUT THIS NOTICE?” below.

12. DO WE MAKE UPDATES TO THIS POLICY?

We may update this Policy from time to time. The updated version will be indicated by an

updated “Effective” date at the top of this Policy. If we make material changes to this Policy, we

may notify you either by prominently posting a notice of such changes or by directly sending youa notification. We encourage you to review this Policy frequently to be informed of how we are

handling your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email our Chief Technology

Officer at info@plus.fan or contact us by post at:

PlusFan Inc.

20 Franklin St

Worcester, MA 01608

United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

FROM YOU?

You have the right to request access to the personal information we collect from you, details

about how we have processed it, correct inaccuracies, or delete your personal information. You

may also have the right to withdraw your consent to our processing of your personal information.

These rights may be limited in some circumstances by applicable law. To request review, update,

or deletion of your personal information, please submit a data subject access request as described above.