WELLVYL PRIVACY POLICY STRVYN Inc. Effective as of March 29, 2018 Your privacy is critically important to us at Wellvyl operating through STRVYN, Inc. (“Wellvyl,” “our,” “us,” or “we”). Therefore, we have adopted this policy (this “Privacy Policy”), which sets forth, among other things, how we collect, use, process, and disclose your information from and through https://wellvyl.com (the “Site”), on our mobile, tablet, and other smart device application program interfaces (the “Application”), and all associated services (collectively, “Services”). The Site, Application, and Services together are hereinafter collectively referred to as the “Platform”. This policy applies to all information we collect through the Platform. This agreement supplements the Terms of Use, Payment Terms of Service, [Activity Provider Agreement], and other policies applicable to your use of the Platform, each of which are incorporated by reference into this Agreement. This Privacy Policy applies to all visitors, users, and others who access the Platform, to those registered in order to list programs such as classes, camps, workshops, activities, and other groups and events (“Activities”) [Chris: Feel free to add any categories of activities you plan to offer] on the Platform and to enroll participants in such Activities via the Platform (each an “Activity Provider”), and to those who register to access the Platform (each a “Member” or “Purchaser”) in order to schedule and make a purchase of Activities (each a “Booking”). By accessing the Platform, you are consenting to the collection and the use of your information by Wellvyl, but only to the extent described herein. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you and you should stop accessing the Platform. Should you wish to revoke your consent and delete your account, you may do so in accordance with the provisions of Section 6 below. If you see an undefined term in this Privacy Policy it has the same definition as outlined in our Terms of Use. Wellvyl reserves the right to modify this Privacy Policy at any time, pursuant to Section 11. Please review this Privacy Policy regularly to ensure that you are aware of its terms.

1. PRIVACY OF CHILDREN

This Site is not directed to persons under the age of 18. We understand the importance of protecting children’s privacy in the interactive world. If you are a child under 13 years of age, you are not permitted to use the Site under any circumstances or for any reason, and should not send any information about yourself to us through the Site. In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with the Children’s Online Privacy Protection Act of 1998. In addition, we will not disclose such information to any other companies. If a parent or guardian becomes aware that their child has provided us with personal information without the parent’s or guardian’s consent, such parent or guardian should contact us at legal@wellvyl.com with “Privacy” as the subject line of the email.

2. INFORMATION WE COLLECT

Our primary goals in collecting information is to improve, market, administer your use of, enable you to enjoy, and easily navigate the Platform. 2.1 Information You Give Us We collect certain information you share with us when you use the Platform, including but not limited to: Member Account Information. If you’re an individual who wants to book Activities through the Platform, or if you are an Activity Provider providing Activities through our Platform, you will be required to register and create an account with Wellvyl (“Account”). In order to access and use certain features of the Platform, such as publishing a Listing and scheduling and/or purchasing an Activity. When you create a Member Account, we will require that you provide certain identifiable information (“Personally Identifiable Information”), including but not limited to, your full name, age, date of birth, gender, address and email address. When you create an Activity Provider Account, we will ask you for business identifiable information. This refers to information that can be used to contact or identify the business (“Activity Provider Information”). Activity Provider Information includes, but is not limited to, the business name, the “doing-business-as” name of the business, phone number, email address, corporate tax identification information (“EIN”), owner name and contact information, representative name and contact information, business postal address, bank account information, bank routing number, and Yelp business ID. [Chris: Please review based on current practices] We will also asking you for information on the Activities you provide, including but not limited to, price, description, name, associated images, type, and attendee requirements and age ranges. Profile Information. To use certain features within the Platform, we may also ask you to complete a profile, which may include your address, phone number, and Activity preferences. Payment Information. We will collect the financial information, including bank information and credit card information, that you provide when making a Booking with an Activity Provider. Communications with Wellvyl, Members, and Activity Providers. When you communicate with Wellvyl or use the Platform to communicate with other Members or an Activity Provider, including when making a Booking, we collect information about your communication and any information you choose to provide. User and Activity Provider Contributions. We will also collect information you provide to be published or displayed on public areas of the Platform, including reviews and listings of Activities on the Platform (“Listing”). Other Information. You may otherwise choose to provide us information when you fill in a form, join our mailing list, participate in a promotion, post a review, engage with us on our various social media platforms, or use other features of the Platform. 2.2 Information We Automatically Collect From Your Use Of The Platform When you use the Platform, we collect information about the services you use and how you use them, including but not limited to: Usage Information. We collect information about your interactions with the Platform, such as pages or other content you view, searches for Listings, Bookings, and other actions you take on the Platform. [Chris: Please confirm] Log Data. When you visit the Platform, whether as a Member or a non-registered user browsing the Platform, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, hardware and software information, browser type, the webpage you visit before and after using our Platform, pages of our Platform that you visit, the time spent on those pages, information you search for on our Platform, access times and dates, and other statistics. We use this information to monitor and analyze use of the Platform and for the Platform’s technical administration, to increase our Platform’s functionality and user-friendliness, and to better engage with our Members and Activity Providers. [Chris: Please confirm] Location Information. We may collect different types of information about your location through your use of the Platform. Cookies and Pixel Tags. Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we use persistent cookies to save your login information for future logins to the Platform. Second, we use session ID cookies to enable certain features of the Platform, to better understand how you interact with the Platform, and to monitor aggregate usage by Members, Activity Providers, and web traffic routing through the Platform. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Platform and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or functionality of the Platform. [Chris: Please confirm] We may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means (individually or collectively “Pixel Tags”) in connection with our Service to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services and to help determine the effectiveness of promotional or advertising campaigns. [Chris: Please confirm] Transaction Information. We collect information related to your Bookings on the Platform, including the date and time, amounts charged, and other related details. 2.3 Information We Collect From Third Parties We may collect information that others provide about you when they use the Platform, or obtain information from other sources and combine that with information we collect through the Platform, including but not limited to: Third Party Services. If you link, connect, or login to the Platform with a third party service (e.g. Facebook, Instagram, etc.), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service. [Chris: Please confirm] Background Information. To the extent permitted by applicable laws, Wellvyl may obtain reports from public records of criminal convictions or sex offender registrations. We may use your information, including your full name and date of birth, to obtain such reports. Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you.

3. HOW WE USE THE INFORMATION WE COLLECT

We use, store, and process information about you to provide and improve the Platform. Your information is mainly used to provide the Service, for marketing purposes, and to send notifications of Bookings. This includes sending you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences. [Chris: Please confirm] We also use your information to enable you to access and use the Platform, enable you to communicate with other Members and Activity Providers, operate, protect, improve, and optimize the Platform experience, enable you to use our payment system, provide customer service, and send you Service and Platform related information. The information we collect is also used to detect and prevent fraud, spam, abuse, security incidents, and other activity harmful to the Platform and in violation of our Terms of Use, Payment Terms of Service, and other policies. For example, as part of our fraud prevention efforts, we may scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We will use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

4. INFORMATION SHARING AND DISCLOSURE

Payments. Wellvyl may share your personal information to facilitate payments. Advertising and Online Tracking. We may at times contract with other companies to help us process information and provide other services to us (“Service Providers”) to place our banner advertising on other websites. These Service Providers may collect information from us about your visits to our Platform and your interactions with our Services. They also may use this information to tailor banner advertisements for goods and services. This anonymous information is collected through the use of Pixel Tags. [Chris: Please confirm] Regardless of anything contrary in this Privacy Policy, Personal Information may be shared with our Service Providers and its service providers, including, without limitation, your name, postal address and email address, as well as a record of any transactions you conduct on our Platform or offline in order to deliver banner advertisements and other advertising tailored to your interests when you visit certain websites. [Chris: Please confirm] We may track this information across the different devices you use to access the Platform. Our trusted Service Provider will keep this data anonymous and will not share any personal information with any other third parties, except as required to provide this service. Sharing Between Members and Activity Providers. To help facilitate Bookings, certain information about you will be shared once a Booking is confirmed. This information includes your name, phone number, and any other information you agree to share. We do not share billing and payout information with other Members or Activity Providers who are not a party to a transaction. Your general location, such as city, may be made visible to other Members or Activity Providers. Profiles, Listings, and Other Public Information. Information you publish to be displayed on public areas of the Platform, including reviews and Listings, may be visible to the general public. Other information about Members and Activity Providers that may be shared on the Platform include parts of your public profile, including your name and city. Social Networking Service. The Platform gives you the option to share information with certain social networking services (i.e. Instagram and Facebook), including Activities of interest or purchased. Wellvyl will not share your Account information, which may contain your Personal Information, with such social networking services unless you expressly authorize such disclosure. Aggregated Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose non-identifying Information and Log Data with third parties for industry analysis, demographic profiling, and to deliver targeted advertising about other products and services. Any aggregated information shared in these contexts will not contain your Personal Information. Third-Party Service Providers. We may employ third party companies and individuals to facilitate our Services, to provide the Service on our behalf, to perform Platform-related services (e.g., without limitation, maintenance services, database management, payment processors, web analytics, and improvement of the Site’s features), or to assist us in analyzing how our Platform and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Safety and Compliance with Laws and Law Enforcement. Wellvyl cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Wellvyl or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity. Business Transfers. Wellvyl may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. Certain Non-Identifying Information. We may combine your Personal Information with non-identifying Information and aggregate it with information collected from other Members and Activity Providers to attempt to provide you with a better experience, to improve the quality and value of the Platform, and to analyze and understand how our Platform is used. We may also use the combined information without aggregating it to serve you specifically, for instance, to deliver information to you according to your preferences or restrictions. Widgets. We may display parts of the Platform (e.g. Activity Provider Listings) on sites operated by Wellvyl’s business partners, using technologies such as widgets or application programming interfaces. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed. Other Uses. We also use your Personal Information (like your email or postal address) to contact you with marketing and promotional materials and other information that may be of interest to you (some of which may be sent by a third party service provider). If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications, or if you do not want us to share your Personal Information with these third party service providers, contact us at legal@wellvyl.com with “Privacy” as the subject line of the email. (See “Changing or Deleting Your Information” below.) with “Privacy” as the subject line of the email.

5. YOUR CALIFORNIA PRIVACY RIGHTS

We may from time to time elect to share your aggregated information, non-identifying information, demographic information and usage information with third parties for those third parties’ direct marketing purposes. Under California Civil Code § 1798.83, California residents are entitled to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information. If you are a California resident and want a copy of this notice, please submit a written request to the following address (limit one request per year): [Insert Address], Attn: Customer Service – California Privacy Rights Notice. You must include your full name, email address, and postal address in your request. Please allow us thirty (30) days to respond.

6. CHANGING OR DELETING YOUR INFORMATION

All Members may review, update, correct, or delete the Personal Information in their Member Account by contacting us or by making edits via the “My Account” section of the Platform. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your account in our system, please contact us at info@wellvyl.com with “Account Deletion” as the subject line of the email with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

7. INFORMATION SECURITY

Wellvyl is very concerned with safeguarding your information from identity theft and we take steps to protect your Personal Information against loss, misuse, alteration, and unauthorized access, but no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information (such as a credit card number) on our Platform, we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems. Identity theft and the practice currently known as “phishing” are of great concern to us. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach, and restore the reasonable integrity of the Platform’s data system.

8. INTERNATIONAL TRANSFER

Our Platform is operated in the United States and intended for users located in the United States, although your information may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. The data protection laws in the United States may also differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing, and storage of your information in the United States.

9. LINKS TO OTHER SITES

Our Site contains links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. Other websites may follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

10. HOW WE RESPOND TO DO NOT TRACK SIGNALS

Wellvyl does not track its users across third party websites, nor does it allow third parties to collect Personal Information on our Site. As such, our service does not respond to browser “Do Not Track” requests, but several of our Service Providers who utilize these cookies and other tracking technologies on our Site enable you to opt out of this type of advertising. To learn more about browser tracking signals and Do Not Track please visit (http://www.allaboutdnt.org/. Please also visit the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) or the Digital Advertising Alliance (http://www.aboutads.info/choices/) to learn more about the use of this information by our Service Providers or to choose limited use of this information by opting out of interest-based online advertising.

11. CHANGES TO THIS PRIVACY POLICY

Wellvyl reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access or use of the Platform will constitute acceptance of the revised Public Policy. You are advised to consult the Privacy Policy regularly for any changes.

12. QUESTIONS

If you have any questions about this Privacy Policy, please contact us at info@wellvyl.com with “Privacy” as the subject line of the email or at: STRVYN, Inc. legal@wellvyl.com [Number]