Privacy Policy for Jiyu

LaudHaus LLC, operating the Jiyu application (“Company” “we” or “us” or “our”), respects the privacy of its users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Jiyu website and application (together, the “Site”). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.

Service details confirmed for this version: Jiyu is available at https://ji-yu.io. Privacy choices and requests are available at https://ji-yu.io/privacy#privacy-choices or by email at JiyuPlatform@proton.me. Jiyu does not sell or share personal information for cross-context behavioral advertising and does not currently use third-party advertising or analytics tools.

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this Policy. If we make a material change to how we collect, use, or share personal data, we will notify affected customers by reasonable electronic means, such as email or a prominent notice on the Site, and we will give you a reasonable opportunity to withdraw any consent you previously gave before we apply the materially different practice to personal data collected under the prior version of this Policy. Changes apply to personal data collected after their effective date, and your continued use of the Service after that date means the updated Policy governs that data.

Definitions

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

“Account” means a unique account created for you to access our Site or parts of our Site.

“Affiliate” means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

“Business,” for the purpose of the California Consumer Privacy Act (“CCPA”), refers to the Company as the legal entity that collects Consumers' personal information and has the meaning set forth in CCPA § 1798.140(d).

“Consumer,” for the purpose of the CCPA, means a natural person who is a California resident and has the meaning set forth in CCPA § 1798.140(i).

“Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.

“Device” means any device that can access the Site such as a computer, a cellphone or a digital tablet.

“Do Not Track” (“DNT”) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

“Personal Information” is any information that relates to an identified or identifiable individual. For the purposes of the CCPA, Personal Information means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you and has the meaning set forth in CCPA § 1798.140(v).

“Sale,” for the purpose of the CCPA means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information to another business or a third party for monetary or other valuable consideration and has the meaning set forth in CCPA § 1798.140(ad).

“Site” refers to the Jiyu website and/or application.

“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies and individuals employed by the Company to facilitate the Site, to provide the Site on behalf of the Company, to perform services related to the Site or to assist the Company in analyzing how the Site is used.

“Third-party Social Media Service” refers to any website or any social network website through which a User can log in or create an account to use the Site.

“Usage Data” refers to data collected automatically, either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit).

“Website” refers to the Jiyu website, accessible at https://ji-yu.io.

“You” and “you” means the individual accessing or using the Site, or the company, or other legal entity on behalf of which such individual is accessing or using the Site, as applicable.

Collection Of Your Information

We may collect information about you in a variety of ways. The information we may collect via the Site depends on the content and materials you use, and includes:

Personal Information

The personal information we collect depends on how you use the Site. Account and identity information includes your name, email address, public username, password, age attestation, referral code, account status, and notification preferences, which you provide. Passwords are processed through Firebase Authentication and are not stored in our application database. Questionnaire and demographic information includes your financial behavior questionnaire answers, approximate annual income, approximate debt, age range, and state, which you provide. Sweepstakes information includes rules acceptance, eligibility attestations, residence state, entry history, winner status, and prize and claim records. Security and device information includes session cookies, hashed device tokens, IP-derived rate- limit keys, and server logs generated when you use the Site.

Derivative Data

Information our servers automatically collect when you access the Site, such as your native actions that are integral to the Site, as well as other interactions with the Site via server log files.

Financial Data

Billing information needed to complete a subscription purchase is collected and processed by Stripe through its hosted payment pages. Stripe directly collects your payment card, bank account, identity, and any required tax information. We receive limited billing details, transaction status, and fraud-prevention information from those providers, but we do not store complete card numbers and security codes together on our systems.

If you choose to link a financial account, we use Plaid, Inc. (“Plaid”) to connect to your financial institution on a read-only basis. You enter your bank credentials directly into Plaid Link, and we never receive or store them. From Plaid we receive institution and account identifiers, account names, masked account digits, liability type, balances, credit limits, APR, minimum payment amounts, payment dates, balance history, connection status, and an identity match result. We do not store full account numbers. Account owner names may be processed transiently to produce the identity-match result and are not retained. We use this data for debt tracking, account synchronization, progress calculations, and dashboard features. Plaid’s collection and use of your information is governed by the Plaid End User Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy. You can connect and disconnect linked accounts at any time in the application.

We create a persona classification, financial health, debt-progress, behavior, and engagement scores, and suggested next actions using deterministic application rules applied to the information described above. These scores are not credit scores, are not consumer reports, and are not used by us or anyone else to approve or deny credit, employment, housing, insurance, or any comparable service.

We may also collect the following information:

Information collected from other Sources

We may collect personal information automatically through network requests and any logs, cookies, pixels, SDKs, or similar technologies configured on the Site, directly from you when you submit a form or otherwise interact with the Site, from payment processors and fraud-prevention partners that support transactions, and from analytics providers configured on the Site, depending on how you use the Site and which features you choose to use.

Examples of source data can include information you choose to provide through Site forms, usage, network, log, device, and similar technical data generated when you use the Site or app, payment confirmations, fraud signals, and transaction-status details from payment providers, and usage or event data from the analytics tools configured on the Site.

Third-Party Data

We may also receive transaction confirmations, payment-status details, or fraud-prevention signals from the payment processors that support the Site. We may also receive usage or event data from the analytics providers configured on the Site.

Subscription Data

When you sign up for an account your email is automatically added to our database for email subscription.

Use Of Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

• Respond to a subpoena.

• Compile anonymous statistical data and analysis for use internally or with third parties.

• Create and manage your account.

• Email you regarding your account or order.

• Fulfill and manage purchases, orders, payments, and other transactions related to the Site.

• Increase the efficiency and operation of the Site.

• Monitor and analyze usage and trends to improve your experience with the Site.

• Notify you of updates to the Site

• Offer new products, services, mobile applications, and/or recommendations to you.

• Perform other business activities as needed.

• Process payments and refunds.

• Request feedback and contact you about your use of the Site.

• Resolve disputes and troubleshoot problems.

• Respond to product and customer service requests.

• Solicit support for the Site.

Disclosure Of Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share information with service providers that perform services for us or on our behalf, including hosting, security, data analysis, email delivery, payment processing, and customer service. We require those providers to use the information only to provide the contracted services or as otherwise permitted by law.

Affiliates

We may share your information with our affiliates, in which case we require those affiliates to honor this Privacy Policy. Affiliates include entities that control, are controlled by, or are under common control with us.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the acquirer or successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. A successor may adopt different privacy practices after the transaction, subject to applicable law and any required notice or consent.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

Tracking Technologies

Cookies and Web Beacons

We use browser, network, and similar technologies for essential technologies for core site functions. These technologies help us operate the Site, remember preferences, measure usage, support account functions, and support transaction functions. Where cookies are in use, you can manage them through your browser settings and any consent tools we make available on the Site.

Website Analytics

The Site does not currently use third-party advertising pixels or cross-site behavioral-advertising tools. Jiyu maintains first-party operational and product events to understand reliability, feature use, and performance. If we later introduce a third-party analytics or advertising tool, we will update this Policy and provide controls where required.

Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Site and services, complete transactions, maintain required records, resolve disputes, and comply with legal obligations. Sweepstakes entry and winner records are retained as required by applicable sweepstakes law. Our current retention periods are as follows. Account and profile information: (name, email address, public username, and notification preferences): retained for the life of your account, deleted from active systems no later than 30 days after account closure, with backup copies expiring no later than 90 days after closure. Questionnaire and demographic information: retained for the life of your account and deleted with your account. Financial account information received from Plaid: deleted no later than 30 days after you disconnect the linked account or close your account. Derived scores, persona classifications, and progress metrics: deleted with your account; retained after that only in de-identified, aggregated form. Sweepstakes entry records for non-winning entries: retained no longer than 12 months following the close of the applicable weekly draw. Winner records, prize and claim records, affidavits, and related tax documentation: retained for three years for tax, accounting, dispute, and sweepstakes administration purposes. Tax forms collected from winners are held by our tax reporting provider under its own retention terms. Subscription and transaction records: retained for seven years for tax and accounting purposes. Server logs, session records, hashed device tokens, and rate-limit keys: retained no longer than 90 days. Support and privacy request correspondence: retained for 24 months following resolution. Email suppression records: retained indefinitely, because we must keep a record of your opt-out in order to honor it. When personal data is no longer needed for these purposes, we delete it or de-identify it unless a longer period is required by law.

Third-Party Websites

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

Security Of Your Information

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. We cannot guarantee complete security if you provide personal information.

Controls For Browser Privacy Signals

We do not sell or share personal information or use it for cross-context behavioral advertising. A universal opt-out preference signal does not change those practices. Analytics providers configured on the Site may collect information about your activity on the Site to measure usage, performance or other metrics.

Options Regarding Your Information

Account Information

You may at any time review or change the information in your account or terminate your account by contacting 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, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms & Conditions and/or comply with legal requirements.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

• Noting your preferences at the time you register your account with the Site

• Contacting us using the contact information provided below

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

California Privacy Rights

California Consumer Privacy Act (“CCPA”)

California residents have certain rights with respect to the processing and use of their personal information, including the following rights:

The right to notice. You must be properly notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.

The right to know and access. You have the right to request that the Company disclose the personal information it has collected about you, the categories of sources, the business purposes for collecting it, the categories of third parties to which it was disclosed, and the specific pieces of personal information collected.

The right to opt out of the sale or sharing of Personal Information. You have the right to direct the Company not to sell your Personal Information and not to share it for cross-context behavioral advertising. You can submit such a request through our "Do Not Sell or Share My Personal Information" link or the privacy request methods described in this Privacy Policy.

The right to correct. You have the right to request that the Company correct inaccurate Personal Information it maintains about you, taking into account the nature of the Personal Information and the purposes of processing it. We may ask for information needed to verify your identity and the requested correction.

The right to limit the use of sensitive Personal Information. To the extent the Company uses or discloses your sensitive Personal Information beyond the purposes the CCPA permits without a right to limit, you have the right to direct the Company to limit its use and disclosure of that information to those permitted purposes. You can exercise this right through the "Limit the Use of My Sensitive Personal Information" link, where provided, or the privacy request methods described in this Privacy Policy.

The right to know about your Personal Information. You have the right to request and obtain from the Company information regarding the disclosure of the following:

• The categories of Personal Information collected;

• The sources from which the Personal Information was collected;

• The business or commercial purpose for collecting or selling the Personal Information;

• Categories of third parties with whom we share Personal Information; and

• The specific pieces of Personal Information we collected about you

The right to delete Personal Information. You have the right to request the deletion of your Personal Information subject to the CCPA's limits and exceptions.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer's rights, including by:

• Denying goods or services to you;

• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties;

• Providing a different level or quality of goods or services to you;

• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Information Collected

Category	Examples	Collected
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers	Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories	Yes
Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), medical records and other data covered by HIPAA	Yes
Commercial information	Records of products or services purchased, obtained, or considered, including purchasing or consuming histories or tendencies.	Yes
Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	No
Internet or other similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement	Yes
Geolocation data	Physical location or movements	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No
Professional or employment-related information	Current or past job history or performance evaluations.	No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Yes
Sensitive personal information	Account log-in or financial account information combined with credentials allowing access to an account. This category also includes precise geolocation, certain protected traits, specified communications, genetic data, qualifying biometric information, health information, and sex life or sexual orientation.	Yes

Personal information does not include:

• Publicly available information from government records

• De-identified or aggregated consumer information

• Information that is exempt from the CCPA such as:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We may collect personal information automatically through network requests and any logs, cookies, pixels, SDKs, or similar technologies configured on the Site, directly from you when you submit a form or otherwise interact with the Site, from payment processors and fraud-prevention partners that support transactions, and from analytics providers configured on the Site, depending on how you use the Site and which features you choose to use.

• Directly from users of the Site or their agents, such as when a person voluntarily submits information to us
• Indirectly from our clients or their agents, such as when we collect information by providing goods or services to them.
• Directly and indirectly from activity on or through the Site.
• From third parties that interact with us in connection with the Site.

Exercising your CCPA Rights

To exercise the privacy rights described in this Policy, you may submit a request by email at JiyuPlatform@proton.me or through our online privacy request form at https://ji-yu.io/privacy#privacy-choices. If an authorized agent submits a request on your behalf, we may ask for proof of the agent's authority and verification of your identity before acting on the request.

The Company will disclose and deliver the required information free of charge within 45 days of receiving your request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell or Share My Personal Information

We do not sell personal data as that term is defined by applicable law. We do not share personal data for cross-context behavioral advertising.

You can opt out of the sale or sharing of your personal data and of targeted advertising at any time through our privacy choices page at https://ji-yu.io/privacy#privacy-choices.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Website Tracking Controls

If you want to limit analytics, advertising, or similar third-party tracking on the Site, you can use browser cookie settings, our privacy choices page at https://ji-yu.io/privacy#privacy-choices, and the provider-specific controls described in the relevant vendor notices.

Browser Privacy Signals and Online Activity Disclosures

We do not sell or share personal information or use it for cross-context behavioral advertising. A universal opt-out preference signal does not change those practices. Analytics providers configured on the Site may collect information about your activity on the Site to measure usage and performance.

California Business and Professions Code § 22581

The Site is not offered to users under the age of 18, and the Site does not enable a user to post content publicly other than the masked winner username described in the Official Rules. If you believe a minor has posted content through the Site, please contact us using the information below and we will remove it. California Business and Professions Code § 22581 provides registered users under 18 a right to request removal of publicly posted content, and we will honor any such request.

Additional State Privacy Disclosures

Your U.S. Privacy Rights

We extend the following rights to all United States consumers, whether or not the law of your state requires it. You have the right to confirm whether we process your personal data and to access that data; the right to correct inaccurate personal data, taking into account the nature of the data and the purposes of the processing; the right to delete personal data; the right to obtain a copy of the personal data you previously provided to us in a portable and readily usable format; and the right to opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

For your protection, we will not send certain data in response to an access request, including Social Security numbers, driver's license or other government identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answers, and biometric data. If we have collected information of that kind, we will tell you so with enough specificity to identify it, without disclosing the data itself.

Sensitive Personal Data

We collect account log-in credentials, which are sensitive personal information under California law, and we process them only to authenticate you and maintain your account. The financial account information we receive from Plaid does not include your credentials, security codes, or full account numbers, and California law treats a financial account number as sensitive personal information only in combination with credentials allowing access to the account. We use sensitive personal information only as necessary to deliver the services you choose. We don't use account log-in credentials to infer characteristics about you. We don't sell sensitive personal information or disclose it for cross-context behavioral advertising.

Payment Card Data

Payment card numbers and security codes are collected and processed by Stripe to complete your transactions. We receive transaction confirmations and limited billing details, but we do not store complete card numbers and security codes together on our systems.

Caloppa Website Disclosures

We do not sell or share personal information or use it for cross-context behavioral advertising. A universal opt-out preference signal does not change those practices.

Analytics providers configured on the Site may collect information about your activity on the Site to measure usage and performance.

These website-level California disclosures stand alongside the broader California privacy disclosures in this Policy.

Delaware Privacy Disclosures

Analytics providers configured on the Site may collect information about your activity on the Site to measure usage and performance.

Florida Privacy Disclosures

For Florida residents, this Privacy Policy describes the categories of personal data we process, the purposes for processing, the categories of personal data shared with third parties, and the categories of third parties that receive personal data.

Florida residents can use the privacy request methods listed in this Privacy Policy to submit rights requests, and can use the appeal path in this Privacy Policy when a request is denied.

Connecticut Privacy Disclosures

We do not use personal data to train large language models (LLMs) or other artificial intelligence systems, and no artificial intelligence provider processes user personal data, unless this Privacy Policy is updated to say otherwise.

Nevada Privacy Disclosures

Analytics providers configured on the Site may collect information about your activity on the Site to measure usage and performance.

Nevada residents may use the privacy request methods described in this Privacy Policy for Nevada-specific privacy inquiries, including certain requests relating to sales of covered information under Nevada law. Material changes to this Privacy Policy will be communicated by updating the Last updated date or by other notice where appropriate.

Oklahoma Privacy Disclosures

Beginning January 1, 2027, Oklahoma residents may have the right to confirm whether we process their personal data, access that data, correct inaccuracies, delete personal data provided by or obtained about them, obtain a portable copy of personal data they previously provided to us where technically feasible, and opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects. We generally respond to qualifying requests within 45 days and may extend that period once by an additional 45 days when permitted by law.

If we deny an Oklahoma privacy request, we will explain the reason for the denial and describe how to appeal. We generally decide Oklahoma appeals within 60 days. If we deny an Oklahoma appeal, we will provide information about the Oklahoma Attorney General's online complaint mechanism.

When we process sensitive data about Oklahoma residents, we do so only with the consent required by Oklahoma law.

Sale, Sharing, And Targeted Advertising Opt-Outs

You can opt out of the sale or sharing of your personal data and of targeted advertising at any time through our privacy choices page at https://ji-yu.io/privacy#privacy-choices.

State Privacy Appeals

If we deny your privacy request, you can appeal that decision by email at JiyuPlatform@proton.me or through our online privacy request form at https://ji-yu.io/privacy#privacy-choices. Include your original request details and the reason you are appealing. We will respond to an appeal in writing within 45 days, and if we deny your appeal, we will tell you how to submit a complaint to your state's Attorney General.

How To Contact Us

If you have a privacy concern, complaint, or a question for us, please contact us at:

JiyuPlatform@proton.me, LaudHaus LLC, 2630 Bissonnet St, Unit 5405, Houston, TX 77005.

Unless otherwise stated, the data is processed in the United States of America and at any other location where other parties processing information are located.