# Privacy Policy

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*Last updated: April 1, 2024*

This Privacy Policy outlines how E12 Holdings, Inc. (“Haven”, “we”, “us”) uses your personal information through our website – begingrace.com, our mobile applications, our interactions with you through other modes of communication (such as SMS or instant messaging), and any other sites or services that link to this Privacy Policy (collectively, the “Services”).

Users deserve transparency regarding how we work, particularly when it comes to their data. This Policy is one part of that transparency. It documents what data we collect, how we keep it secure, and describes how we use that data to improve our Services for everyone. Here are the top level points:

- When you use Haven, we collect data including your name, phone number, email, and IP address. We use this data to run Haven, inform improvements to our Services, keep you safe, and comply with all applicable laws.

- Keeping your conversations with Haven private and safe is our top priority, and we will never sell or share your data for advertising or marketing purposes. We have strict internal controls over the use of and access to user data.

- You agree to follow our Acceptable Use policy. When you talk to Haven, you should not try to get it to talk about harmful, abusive, or illegal topics. You also should not attempt to evade our security measures or learn about the models, algorithms, prompts, or source code of Haven. If our automated systems detect this activity, you may be suspended.

### **Information We Collect**

Information you provide to us

- Contact and account information, such as your name and email address.

- Content and metadata of any messages that you send using the Services directly.

- Communications that we exchange with you, including when you respond to our surveys or contact us with questions, feedback or otherwise.

- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

**Automatic data collection**. We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, online resources and our communications, such as:

- Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings and general location information such as city, state or geographic area.

- Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened or otherwise engage with our communications.

We use the following tools for automatic data collection:

- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.

- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Sensitive data. In your conversations with the Services, you may choose to provide sensitive information. This includes, but is not limited to, your religious views, sexual orientation, political views, health, racial or ethnic origin, philosophical beliefs, or trade union membership. By providing sensitive information, you consent to our use of it for the purposes set out in this Privacy Policy.

### **How We Use Your Information**

We use personal information for the following purposes or as otherwise described at the time of collection:

**Provide our Services**. We use personal information to operate, maintain, and provide you with our Services. In particular, we use personal information to perform our contractual obligations under our Terms of Service.

**Communicate with you about our Services**. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, surveys, reminders, updates, security alerts, and support and administrative messages.

**Improve, monitor, personalize, and protect our Services**. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:

- Understanding your needs and interests, and personalizing your experience with the Services and our communications.

- Troubleshooting, testing, and research, and keeping the Services secure.

- Investigating and protecting against fraudulent, harmful, unauthorized, or illegal activity.

**Research and development**. We may use personal information for research and development purposes where it is in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

**Compliance and protection**. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

- Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims).

- Audit our internal processes for compliance with legal and contractual requirements and internal policies.

- Enforce the terms and conditions that govern the Services.

- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

### **Sharing Your Information**

We do not sell or share your personal information with third-parties for interest-based advertising purposes . We may disclose your personal information as described below:

**Service providers**. We may rely on third-party service providers in furtherance of the purposes described above. In these cases, personal information may be accessed by these third-parties and processed or stored on our behalf. These service providers can include hosting services, cloud computing and storage services, maintenance services, security services, and customer support services.

**Business transferees**. Personal information may be transferred to another entity in the event of a bankruptcy, change of control, or shutdown of Haven. We may also transfer personal information in the course of a sale or merger of the business.

**Authorities and others**. If we are legally obliged or otherwise believe it necessary to do so, personal information may be disclosed to regulatory agencies, law enforcement agencies, courts, and other government authorities, including for the compliance and protection purposes described above.

### **Privacy Rights and Choices**

**Delete your account**. You may request that we delete your account by navigating to the “Delete account” screen on the App.

**Personal information requests**. We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:Personal information requests. We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:

- Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

- Correction of personal information that is inaccurate or out of date.

- Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.

- Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

- Additional rights, such as to object to and request that we restrict our use of personal information.

**Third-Party Websites and Content**

Please be advised that you may encounter links or content through our Services that are provided by third-parties. You acknowledge that any data you provide to these third-parties shall be governed solely by the terms of service, privacy policies, and other terms applicable to those third-parties.

### **Children**

Our Services are not intended for minors under the age of 13. We do not knowingly collect or solicit personal information from minors under the age of 13. If you are a minor under the age of 13, please do not attempt to use our Services, register an account with us, or send any personal information to us.

If you believe that a minor under the age of 13 has provided personal information to us or is otherwise using our Services, please let us know immediately at havenappcontact1@gmail.com and we will seek to delete this information and revoke access as quickly as possible.

### **Retention**

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory

requirements.

### **International Data Transfers**

You will provide personal information directly to our Services in the United States. We may also transfer personal information to our affiliates, partners, and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

### **Changes To This Policy**

We are continuing to iterate on our Services, and this Privacy Policy will need to be updated. Please be aware that we reserve the right to modify this Privacy Policy at any time.

When we do so and unless required by law to provide an alternative notice, we will post an updated version on this page. If you choose to continue your use of our Services after such a revision, you consent to be governed by the amended Privacy Policy.