Privacy Policy

Last Updated: March 10, 2026

1. Introduction

BudgetWills's services are intended for use by business and consumer customers, and we may process information about you when providing our services and operating our business. This Privacy Policy (the "Policy") provides a comprehensive description of how BudgetWills collects, uses, and discloses information about you ("Personal Information"), as well as your rights and choices regarding such Personal Information. For purposes of this Policy, "BudgetWills", "we", "our", and "us" refers to BudgetWills and its affiliates, and "you" or "your" refers to the individual interacting with us.

Some regions provide additional rights by law. For region-specific terms, please see the following sections below:

• "Additional Disclosures for Nevada Residents"
• "Additional Disclosures for California Residents"
• "Additional Disclosures for Virginia Residents"
• "Additional Disclosures for Data Subjects in the European Economic Area, Switzerland, and United Kingdom"
• "Additional Disclosures for Individuals Located in Canada"

For our contact details, please visit the "Contact Us" section below.

2. Applicability of this Policy

This Policy applies to (a) www.budgetwills.com (the "Website") and (b) our emails, advertisements and any other location, online or offline, where you interact with our business (e.g., conferences or third party social media and networking sites) (collectively, with the Services and Website, the "Business").

Moreover, this Policy does not apply to any third-party applications or services that are used in connection with our Services, or any other products, services or accounts provided by other entities under their own terms of service and privacy policy (collectively, "Third-Party Services"). For example, a customer may connect, directly or through another application, messaging systems, e-mail services, e-commerce platforms, and other products and services to its Services account ("BudgetWills Account").

If you do not agree with this Policy, then do not access or use the Services, Website or any other aspect of our Business.

3. Information BudgetWills Processes

BudgetWills will process information continuously through the operation of our Services and Websites, and through other interactions with our Business, as described in the Agreement. If you provide us with information about another individual, by acknowledging or agreeing to this Policy, you represent and warrant that you have the authority to do so and have delivered any required notices and obtained all necessary rights and consents to provide such information to us for processing in accordance with this Policy. If you believe information has been provided to us improperly, please notify us in accordance with the "Contact Us" section below.

A. Information Provided to BudgetWills
We receive information when you submit it to our Business:

• Contact Information, including your first name, last name, email address, phone number, employer, job title and address.
• Communications, including when contacting sales or support, asking a question, providing product feedback or corresponding with our business teams.
• Content, including any documentation, files or information you provide, which may include information about you or your business.
• Third-Party Information, including information you provide about any co-workers, contractors, vendors or potential referrals, such as their Contact Information.

If you or someone at your Company begins the process of applying for a BudgetWills Account, we may receive information about you, your Company, and individuals associated with your Company. We may collect: (1) your Contact Information; (2) Identifying Data of owners, control persons and other relevant personnel, such as their date of birth, residential address, government-issued identification, and any information captured on such identification or through our identification verification process; and (3) other information requested by or provided to us. This information is needed to verify the identity of the customer wishing to use the Services, comply with legal and regulatory obligations applicable to us, determine the availability of Services offerings, and maintain your BudgetWills Account.

In connection with providing Services, we receive additional information submitted by, on behalf of and relating to a customer and its Authorized Users, such as:

• Authorized User Data, including your Contact Information, login credentials, and other information used to invite and manage Authorized Users.
• Transaction Data, including information associated with your contracts, documentation, processes and playbooks made through your BudgetWills Account.
• Connected Data, including information and documentation relating to you made available by Third-Party Services connected to the Services. Connected Data may be made available to BudgetWills during the application process and after a BudgetWills Account is opened. For example, some Third-Party Services (e.g., artificial intelligence systems and cloud service providers) may provide us with information about activities outside of the Services, like your location or business activity. Other third party services may disclose your Authorized User Data, and if you connect your email or messaging service, we may receive your email or messaging communications and attachments for processing. We may continue to access and receive Connected Data from a Third-Party Service until it is disconnected by you.

B. Information Generated and Collected by BudgetWills
We generate, collect and derive information when you use or interact with our Services, Website and other products and services provided or used by our Business:

• Use Data, including information and metadata about the pages or content you visit, the features you interact with, the workflows you construct, how much time you spend on a particular Website or using the Services, login and crash data, Third-Party Services you elect to connect to or use with the Services, your preferences or selections, the time of day you browse, and your referring and exiting pages.
• Device Data, including information about the type of device or browser you use, your device's operating software and settings, your internet service provider, and device identifiers, such as IP address and advertising identifier.
• Location Data, including an approximate geolocation derived from your IP address or business information.

We use cookies and other technologies to help us process information:

• Log Files, which are files that record events that occur in connection with your use of technology services, including the Services and Website.
• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate websites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
• Pixels (also known as web beacons), which are code embedded in a website, email, application or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access technology that contains a pixel, the pixel may permit us or a separate entity to track your interactions. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising, and provide you with additional functionality.
• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device, such as JavaScript objects and installed fonts, to create a "fingerprint" of your device and uniquely identify your device or applications on your device.
• Software Development Kits (also referred to as SDKs), which are software tools used by developers to interact with a third-party platform.

C. Information Collected by BudgetWills from Other Sources
We also collect and receive information from other sources:

• Identity Verification, Fraud and Compliance Monitoring, and Business Information Providers, which may help us supplement our understanding of your business and its personnel, maintain security, prevent fraud and comply with regulation and contractual obligations.
• Vendors and Console Users transacting with or supporting our customers.
• Service Providers, which help us operate our Business.
• Social Networks and Advertising Providers, including to help us identify or enrich our understanding of prospective customers, and to serve and measure advertising.
• Joint Marketing, Business Partnership, Referrals, and Rewards Partners that we engage for joint marketing activities and our referrals and rewards programs.
• Other Data Suppliers that provide information about industries, business trends, organizations and other matters related to our business.
• Publicly-Available Sources, including information in the public domain that helps us identify potential customers and partners or conduct due diligence and risk management for potential and existing customers.

The categories of information we collect and receive from these sources may include all of the categories identified above in "Information Provided to BudgetWills" and "Information Generated and Collected by BudgetWills." We treat the information obtained from other sources in accordance with any laws or contractual obligations applicable to us.

4. How BudgetWills Uses Information

We use information for business and commercial purposes in accordance with the practices described in this Policy. In addition, BudgetWills uses information to operate our Services, Website, and Business as follows:

• Providing and Maintaining Our Services, Website and Business. To provide, operate and manage our Services, Website and other parts of our Business, including to perform customer validation and enable you to use our Services, prevent or address technical issues and disruptions, and analyze and monitor usage and activities.
• Communicating with You. To send you notices, updates, security alerts, information regarding changes to our policies and terms, and support administrative messages.
• Security and Fraud Prevention. To maintain the safety and security of our Business and manage risk, including identifying and troubleshooting any issues with the Services, investigating suspicious activity, detecting and preventing potentially fraudulent or unauthorized transactions and breaches of policies and terms, and threats of harm, including in an automated fashion.
• Legal Obligations and Enforcing Our Rights. To fulfill legal, regulatory and contractual obligations, including when cooperating with government authorities, courts and regulators in accordance with applicable law, maintaining records to demonstrate compliance with applicable law and regulation, protecting our legal rights and pursuing remedies available to us.
• Developing and Improving Our Business. To make the Services and other aspects of our Business as useful as possible for customers, including by improving and expanding our products and operations.
• Auditing and Research. To conduct internal reporting, auditing, and research, including focus groups and surveys.
• Marketing and Advertising. To develop, send and measure advertising, direct marketing, and communications about our products, offers, promotions, rewards, events, and Services. We may also use information to engage in personalized advertising, including Interest-based Advertising.
• Generating Aggregate or De-identified Information. To develop de-identified information by removing or masking information that could be used to identify you and by aggregating or combining information with other information.
• At Your Direction. To fulfill any other purpose at your direction, including as expressed through your use of Services functionality.
• With Notice to You and Your Consent. We may otherwise use the information we collect after providing notice to you and obtaining your consent.

Notwithstanding the above, we may use information that does not identify you for any purpose permitted by law or contractual obligation applicable to us. For information on your rights and choices regarding how we use your Personal Information, please see the "Your Rights and Choices" section below.

5. Disclosure of Information by BudgetWills

We disclose information we collect in accordance with the practices described in this Privacy Policy. The categories of parties to whom we disclose information are:

• Service Providers. We disclose information to service providers that process information on our behalf. Service providers assist us with services, such as artificial intelligence, cloud infrastructure, website hosting, analytics, collaboration and technical support. Depending on the service, we provide information on a continuous basis (e.g., fraud services) or on an as-needed basis. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law or contractual obligation. Additional information about the subprocessors we use to support delivery of our Services is made available at contact@budgetwills.com.
• Affiliates. We disclose information to our affiliates and related entities.
• Business Customers. We disclose information to our business customers to provide Services on their behalf.
• Connected Services. We disclose information to Third-Party Services and their providers if you use Third-Party Services in connection with the Services.
• Identity Verification and Customer Validation Services. We disclose information as necessary to verify your identity and perform other compliance functions.
• Vendors and Console Users. We disclose information to entities that transact with or support you.
• Marketing and Advertising. We disclose information to vendors, platforms, analytics providers and other parties for marketing and advertising related purposes.
• Mergers and Acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual financing, merger, purchase, sale or any other type of equity or debt transaction or acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security, Fraud Detection and Compelled Disclosure. We disclose information to comply with the law, regulations, payment network rules, or legal process, investigate suspicious or potentially fraudulent activity, and where required in response to lawful requests by regulators, law enforcement.
• Referrals and Joint Marketing. We disclose information about you and your BudgetWills Account to our partners in connection with facilitating referral partnerships or engaging in joint marketing activities.
• At Your Request. We disclose information at your request or direction.
• With Notice to You and Your Consent. We may otherwise disclose information after providing notice to you and obtaining your consent.

6. Analytics and Interest-Based Advertising

Where permitted under laws applicable to our Business, we use analytics services to help us understand how users access and use the Website and other aspects of our Business. In addition, we work with agencies, advertisers, ad networks, and other technology services to place advertisements on our behalf on other websites and services. For example, we may place ads through Google, LinkedIn and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may use tracking technologies (including incorporating them into our Website and emails), as well as incorporating into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you ("Interest-based Advertising").

7. Data Transfer

Our Business is operated from the United States, Canada and other jurisdictions. Any of your Personal Information we collect may be transferred to, processed, used, handled, and stored in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may differ from those of your country of residence. We take measures to comply with applicable data protection laws when we transfer Personal Information internationally.

For personal data transferred from the European Economic Area, Switzerland or the United Kingdom, we will provide appropriate safeguards, such as through the use of the relevant standard contractual clauses. For further information on these transfers and the relevant appropriate safeguards, please see the "Additional Disclosures for Data Subjects in the European Economic Area, Switzerland and the United Kingdom" section below.

8. Additional Important Information

Security. We use organizational, technical, and administrative measures designed to protect your Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction. However, no information security program or transfer via the internet is entirely secure so we cannot guarantee the security of your Personal Information.

Use by Minors. We do not direct any of our Services or other aspects of our Business to children. We do not knowingly collect personal information (as defined by the U.S. Children's Privacy Protection Act, or "COPPA") from children under 13. We also do not knowingly "share" or "sell," as those terms are defined under the California Privacy Rights Act, the personal information of minors under 16 who are California residents. If you are a parent or guardian and believe we have violated this provision, contact us at contact@budgetwills.com.

Retention. BudgetWills collects and stores Personal Information for the purposes outlined in this Policy. We retain Personal Information for as long as we continue to have a business or operational purpose to retain it, and may continue to retain and use Personal Information as necessary to comply with (or demonstrate compliance with) our legal or regulatory obligations, resolve disputes, prevent fraud, and enforce our rights.

Changes to this Privacy Policy. We reserve the right to change and reissue this Policy at any time by posting an updated version. If we have an existing relationship with you, we may provide you notice through our Website or your BudgetWills Account or directly using the Contact Information provided to us. Any privacy notice is effective upon posting or when it is provided to you.

9. Your Rights and Choices

Region-Specific Rights. In addition to these rights and choices, you may have additional rights based on your region. For region-specific terms, please see the bottom of this Policy.

Tracking Technology Choices.

• Cookies and Pixels. Most browsers and devices accept cookies by default. You can instruct your browser or device, by changing its settings, to decline or delete cookies. If you use multiple browsers or devices, you may need to instruct each separately.
• Do Not Track. Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to "Do Not Track" signals.

Please be aware that if you disable or remove tracking technologies some parts of our Services, Website and Business may not function correctly.

Communications.

• E-mails. You can opt out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link. Please note that you cannot opt-out of non-promotional emails, such as those about your BudgetWills Account, transactions, servicing, or our ongoing business relations.
• Text or SMS Messages. If you have opted in to receiving text or SMS messages related to your use of the Services, you can opt-out at any time by texting "STOP" to the short code. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed.

11. Additional Disclosures for Nevada Residents

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please refer to the "Contact Us" section above.

12. Additional Disclosures for California Residents

These additional disclosures apply only to California residents and only to the extent applicable.

Notice of Collection.
The California Consumer Privacy Act as amended by the California Privacy Rights Act ("CPRA") provides additional rights and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights. In the past 12 months, we have collected the following categories of personal information enumerated in the CPRA:

• Identifiers, including name, postal address, email address, and online identifiers (such as IP address).
• Customer records, including phone number, billing address, bank account and credit or debit card information.
• Commercial or transaction information, including records of products or services purchased, obtained, or considered.
• Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
• Approximate location data.
• Precise geolocation data when you choose to enable certain features.
• Employment and education information.
• Inferences drawn from the above information about your predicted characteristics and preferences.

We collect and use these categories of personal information for the business purposes described in the "How We Use Information" section above. We disclose the personal information to the categories of persons set out in the "Disclosure of Information" section above.

Right to Know, Correct and Delete.
You have the right to know certain details about our data practices. In particular, you may request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold or shared;
• The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
• The business or commercial purpose for collecting or selling or sharing the personal information;
• The specific pieces of personal information we have collected about you.

In addition, subject to exceptions, you have the right to correct or delete the personal information we have collected from you. To exercise any of your rights, please submit a request to us at contact@budgetwills.com.

Additional Notice and Opt-Out
Under the CPRA, some marketing practices, like the disclosure of Website visitor data to obtain targeted ads and analytics to advertise our products on third party sites, may be considered a "share" or "sale" even if no money is exchanged. A "share" is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising, and a "sale" is broadly defined under the CPRA to include a disclosure for something of value. Under these definitions, we may collect, share, or sell the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transaction information, internet activity, non-precise geolocation data, and inferences drawn. To the extent our marketing practices constitute a "share" or "sale" of your personal information, you have the right to opt out. You can exercise this right by modifying your cookie preferences on your browser or extension.

Retention
We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we may require signed proof of the agent's permission to do so and verify your identity directly.

Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at contact@budgetwills.com.

13. Additional Disclosures for Virginia Residents

Virginia provides additional rights to Virginia residents through the Virginia Consumer Data Protection Act ("VCDPA"). This section addresses those rights and applies only to Virginia residents acting in an individual or household context.

You have the following rights under the VCDPA:

• To confirm whether or not we are processing your personal data
• To access your personal data
• To correct inaccuracies in your personal data
• To delete your personal data
• To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format
• To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you

To exercise any of these rights, please submit a request to us at contact@budgetwills.com.

14. Additional Disclosures for Data Subjects in the European Economic Area, Switzerland and the United Kingdom

Roles.
BudgetWills may process personal data in accordance with the instructions of or on behalf of a customer, including when providing Services under an Agreement. In this context, BudgetWills acts as a processor and the customer acts as a controller. BudgetWills may also act as a controller when directly determining the processing of personal data in other Business contexts set out in this Policy.

Lawful Basis for Processing.
Data protection laws in Europe require a "lawful basis" for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or business customers; (b) processing is necessary for the performance of a contract; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

International Transfers.
We may transfer your personal data to our operations in the United States or to our service providers or other third parties in the United States or in other countries - this may involve the transfer of your personal data to countries which have different data protection standards to those which apply in the European Economic Area, Switzerland or the United Kingdom. Some of these countries are subject to a European Commission and/or UK government adequacy decision. For other countries, BudgetWills has put in place the relevant European Commission or UK government-approved standard contractual clauses with the relevant third parties to ensure that your personal data is protected with appropriate safeguards.

Your Data Subject Rights.
You may have certain statutory rights relating to your personal data. Subject to applicable law, you may have the right to access and rectify your personal data, to require us to erase your personal data or to transfer it to other organizations, and to object to the processing of your personal data. Where we process your personal data because we have a legitimate interest in doing so (as explained above), you may have a right to object to this. You may also have the right to restrict processing of your personal data in certain circumstances. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes. You may withdraw your consent at any time for any processing of your personal data which we do based on consent you have provided to us. To exercise any of these rights, please contact us at contact@budgetwills.com. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.

15. Additional Disclosures for Individuals Located in Canada

Your Rights and Choices.
Subject to limited exceptions under applicable Canadian law, you may have the right to access, update, correct inaccuracies in, and withdraw consent (subject to reasonable prior notice and applicable legal and contractual restrictions) to the collection, use and disclosure of your personal information. If you withdraw your consent, we may not be able to provide our Website, Services or other aspects of our Business. To exercise any of these or other rights applicable to you under Canadian privacy laws, please contact us at contact@budgetwills.com.

Governance Policies and Practices
We are committed to protecting personal information and have implemented policies and practices that govern our treatment of personal information, including:

• policies and procedures regarding the protection, retention and disposition of personal information, including with respect to the implementation of security safeguards designed to protect personal information against loss or theft and unauthorized access, disclosure, copying, use, and modification;
• a framework that sets out roles and responsibilities of our personnel in connection with the handling of information in our possession and control;
• processes for responding to data subject requests and complaints in a timely and effective manner; and
• employee data protection training and awareness.

Please click here to return to the home page.