GDPR Statement

Supplements the Plan With Ivy Privacy Policy for residents of the United Kingdom and European Economic Area governed by the UK GDPR or EU GDPR.

Who We Are

Top Secret Ventures LLC, 30 N Gould St #3927, Sheridan, WY 82801, USA, is the data controller responsible for your personal data collected through Plan With Ivy. You can contact us regarding privacy matters at info@planwithivy.com.

Lawful Basis for Processing

We only collect and process your personal data where we have a lawful basis to do so:

Where we rely on legitimate interests, those interests include: operating and improving our business, protecting against security threats and fraud, and maintaining our relationship with you as a customer. We do not rely on legitimate interests where doing so would override your rights and freedoms.

Special Category Data

We do not ask you to submit special category data (racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning your sex life or sexual orientation), and it is not necessary to provide any such information to use Plan With Ivy. If you choose to include this type of information anyway — for example, in a free-text field — you are providing your explicit consent to our processing of it in accordance with this Statement.

Automated Decision-Making and Profiling

Plan With Ivy uses AI to generate retirement projections and scenario comparisons based on the information in your profile. As currently designed, this processing is intended to inform your own decisions, not to make a decision about you without your involvement — you review, interpret, and act on the output yourself.

Under Article 22 GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you. If a future feature meets that threshold, we will, before turning it on: identify the processing as such at the point of collection; provide meaningful information about the logic involved and the significance and likely consequences for you; and give you the ability to obtain human intervention, express your point of view, and contest the decision.

Your Rights

Subject to certain exceptions, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate or incomplete data
• Erasure — request deletion of your data, including where it's no longer necessary for the purposes it was collected for
• Restriction — request that we limit the processing of your data in certain circumstances
• Portability — request your data in a structured, machine-readable format, and request that we transfer it to another controller where technically feasible
• Object — object to processing based on legitimate interests or to direct marketing at any time
• Withdraw consent — where processing is based on consent, withdraw it at any time without affecting the lawfulness of processing before withdrawal
• Automated decision-making rights — as described above
• Lodge a complaint — with your local data protection supervisory authority (in the UK, the Information Commissioner's Office; in the EU, your national supervisory authority)

International Data Transfers

Because Top Secret Ventures LLC is based in the United States, using the Services involves transferring your personal data outside the UK/EEA. Where we do this, we rely on Standard Contractual Clauses approved by the European Commission and, for UK transfers, the UK International Data Transfer Addendum, together with supplementary measures where appropriate, to ensure your data continues to receive an equivalent level of protection.

Retention

We retain your personal data only for as long as necessary for the purposes described in the Privacy Policy and this Statement — generally for as long as your account is active, plus any additional period required to comply with legal obligations, resolve disputes, or enforce our agreements. AI conversation data is retained according to the specific window described in the Privacy Policy.

How to Exercise Your Rights

You can exercise any of the rights above by contacting info@planwithivy.com. We may ask you to verify your identity before responding. We aim to respond within one month of a verified request, as required by GDPR, and will let you know if we need additional time for a complex request.

Contact

Questions about this Statement can be directed to:

Top Secret Ventures LLC
30 N Gould St #3927
Sheridan, WY, 82801, USA
info@planwithivy.com