PLANET WEALTH, INC. AND ATS PRODUCT & PLATFORM DEVELOPMENT, LLC

JOINT PRIVACY POLICY

Exclusively Opt-In Policy

Planet Wealth, Inc. and ATS Product & Platform Development LLC (“ATS P&P”, and collectively with Planet Wealth, Inc., the “Associates”) conduct a joint program of collecting, storing and sharing with each other information regarding persons who utilize their respective services. In particular, they have agreed to share ownership, but independently utilize, a database of information about individuals who may wish to invest in offerings of securities (the “Database”). The Associates will collect the information from the following sources:

  • Individuals who register to use the Planet Wealth website will be solicited to agree to the collection of their personal information in the Associates’ database.
  • Members of Planet Wealth, a network sponsored by Planet Wealth, Inc., will be solicited to agree to the collection of their personal information in the Associates’ database.
  • Issuers that utilize the Planet Wealth LaunchPro will be solicited to agree to the collection of their personal information in the Associates’ database.
  • Issuers who utilize the LaunchPro to organize and promote offerings of their securities are provided the opportunity to customize a website for the offering. The website is hosted on servers provided by Planet Wealth, which gives Planet Wealth access to information communicated to the issuers by potential investors and actual investors in those offerings.
  • Issuers and Investors who subscribe for training and seminars provided by ATS P&P will be solicited to agree to the collection of their personal information in the Associates’ database.
  • Investors in Planet Wealth may be solicited to agree to the collection of their personal information in the Associates’ database.

OUR COLLECTION OF INFORMATION WILL BE ON AN EXCLUSIVELY OPT-IN BASIS. THE ASSOCIATES WILL NOT COLLECT OR RETAIN ANY INVESTOR INFORMATION, REGARDLESS OF SOURCE, UNLESS THE INVESTOR HAS AFFIRMATIVELY CONSENTED TO SUCH COLLECTION. CONSENT WILL BE SOLICITED ON THE REGISTRATION PAGE FOR VISITORS TO PLANET WEALTH, ON THE REGISTRATION PAGE FOR MEMBERSHIP IN PLANET WEALTH, ON THE SUBSCRIPTION PAGE FOR USERS OF THE LAUNCHPRO, ON THE WEBSITES OF ISSUERS HOSTED BY PLANET WEALTH SERVERS, AND ON THE REGISTRATION PAGE FOR ATS P&P’S TRAINING PROGRAMS.

This Privacy Policy describes how we collect, use and share personal information collected in this manner from investors who have affirmatively consented to the Associates’ use of their personal information.

WHAT INFORMATION WE COLLECT

The list below includes examples of the types of personal and financial information (“Personal Information”) that, if you approve, we will collect:

  • Your name
  • Your e-mail address, mailing and physical address
  • Your phone (or mobile) number
  • Your date of birth
  • Your Social Security number
  • Your investment experience
  • Your investments in Planet Wealth-assisted offerings
  • Whether you are an accredited investor
  • Any anti-money-laundering report prepared concerning you
  • Any know-your-customer report prepared concerning you.

WHY WE COLLECT INFORMATION

We collect Personal Information exclusively to populate our Database. Our purpose in developing our Database is to have ready access to a pool of individuals who have expressed interest in reviewing opportunities to invest in private or public offerings of securities. We intend to use the Database in the future:

  • as a market for possible securities offerings by Planet Wealth or ATS P&P;
  • as a market for products and services related to the capital markets; and
  • to sell or license to third parties for use in their securities offerings.

HOW WE COLLECT INFORMATION

We Collect Information Through Our Interactions With You

After you consent to our collection of your Personal Information, we collect information from you when:

  • You subscribe for a service offered by one of the Associates;
  • You visit the website of an issuer that subscribes to the Planet Wealth LaunchPro;
  • You respond directly to our request for information.

We Collect Information from Other Sources

If you invest in an offering on a website hosted on a Planet Wealth server, the issuer will generally secure third party reports concerning you in order to satisfy issuer’s obligation to comply with anti-money-laundering and know-your-customer policies. If you have consented to our collection of your Personal Information, we will add those reports (or their conclusions only) to the Database.

We may also obtain information from third parties, including business partners, affiliates, and publicly available sources, that can enhance and add to our information about you (e.g., adding address information).

HOW WE PROTECT THE INFORMATION WE COLLECT

No method of transmission over the Internet, or method of electronic processing or storage, is fully secure. While we maintain reasonable security measures to protect the confidentiality and security of information transmitted to us, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

We take precautions to protect your Personal Information. When you submit sensitive information via an

Issuer website or otherwise, or when we receive an AML or KYC report regarding you, your information is protected both online and offline. Only employees of the Associates who need the information to perform a specific job are granted access to personally identifiable information. The computers/servers and file cabinets in which we store personally identifiable information are kept in a secure environment.

HOW WE SHARE THE INFORMATION WE COLLECT

Our Affiliates

We may share Personal Information with our corporate affiliates (e.g. sister companies, subsidiaries, joint ventures) for them to develop their own products or market to you.

Service Providers

We may share Personal Information with third parties that provide services to us. Among other things, these third parties help us with the administration, operation, and marketing of Planet Wealth. This includes hosting, communications, printing, marketing, data enhancement, technical support, payment or transaction processing, and fulfillment of services. In some cases, we share your information with these third parties to aid them in performing services on our behalf.

Other Third Parties

We may sell, lease or otherwise share your Personal Information with nonaffiliated third parties who wish to market a securities offering or an investment-related product or service to you.

Legal Requirements

We may disclose Personal Information when we believe disclosure is appropriate to comply with the law. For example, we may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

With Your Consent

We may ask if you consent to share your information with other unaffiliated third parties who are not described elsewhere in this Policy, and may share your information with your consent.

Business Transfers

If another entity acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. We also may retain a copy of that information.

International Data Transfers

The Planet Wealth website is controlled and operated from facilities within the U.S. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your data. By submitting your information to us and consenting to the terms of this Privacy Policy, you agree to the transfer, storage and processing of your information in the U.S. and other countries, including countries other than your country of residence.

WHAT CHOICES AND RIGHTS YOU HAVE REGARDING YOUR INFORMATION

If your Personal Information was collected by us under this Policy, you can make the following choices regarding that information. In order to exercise any of these rights, you can contact us by using the contact information provided at the end of this Policy or such contact information as we may provide in the future.

Access To Your Personal Information

You may request access to your information by contacting us using the contact information provided at the end of this policy. If permitted and required by law, we will grant you reasonable access to the data that we have about you.

Changes To Your Personal Information.

We rely on you to update and correct your personal information. Note that we may keep historical information in our backup files as permitted by law.

Deletion Of Your Personal Information.

Typically, we retain your data for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of data, or request that we delete your personal information by contacting us using the contact information provided at the end of this policy. Except in a situation where we have a legal obligation to retain your Personal Information, we will grant a request to delete Personal Information.

Objection to Certain Processing.

You may object to our use of your information by contacting us using the contact information provided at the end of this policy.

E-mail Marketing

When we send you promotional emails based on your consent or as permitted by applicable laws, you have the right to unsubscribe. You also have the ability to unsubscribe to promotional e-mails by following the unsubscribe instructions in e-mails. Please allow us up to 10 business days to implement your request to unsubscribe.

ADDITIONAL INFORMATION

Third Party Websites and Services

Planet Wealth contains links to other websites and services not maintained by us or our Associates. In addition, other websites and services may also reference or link to Planet Wealth. Use of such third-party websites is subject to the terms of use and privacy policies of those third parties. We do not control the privacy policies or practices of these third-party websites. We encourage you to be aware when you enter or leave Planet Wealth, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

Privacy Policy Revisions

We may change this Policy and our information collection, use, and sharing practices over time. To the extent that our Policy changes in a material way, the Policy that was in place at the time that you consented to our collection and use of your Personal Information will generally govern that information unless we receive your consent to the new privacy policy.

 

HOW TO CONTACT US REGARDING THIS POLICY

Please submit your questions or comments regarding this Policy via one of the methods:

Mail: Planet Wealth, Inc.

1416 Sweet Home Road, Suite 9b

Amherst, NY U.S.A.14228

(716) 650-4123

Email: info@PlanetWealth.com

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