Privacy Policy

Last updated: January 6, 2026

INTRODUCTION

At Zestyplan Inc. ("Zestyplan," "our," "us," or "we"), protecting your privacy is very important to us. We value the trust of those who participate in our plant-forward eating challenges and programs (collectively, "Zestyplan Challenges" or "users," "you," "individuals," or "participants") and have created this Privacy Policy (the "Policy") to inform you of our policies and procedures regarding the collection, use, and disclosure of Personal Information.

This Policy applies to all Zestyplan Challenges, including our challenge platform, associated websites, mobile applications, and services (collectively, the "Platform"), as well as our social media platforms and offline activities related to any Challenge. Zestyplan Challenges may be offered directly to the public or in partnership with organizations, events, universities, corporations, or other entities (each, a "Partner Organization").

This Policy forms part of our Terms of Use. Unless otherwise defined in this Policy, terms used in this Policy have the same meanings as in our Terms of Use.

By accepting this Policy and participating in any Zestyplan Challenge, you consent to the collection, use, and disclosure of your Personal Information in accordance with this Policy. If you provide Personal Information about another individual (such as family members participating together), you agree that you have obtained their consent to our collection, use, and disclosure of their Personal Information as described in this Policy.

OBJECT OF THE POLICY

This Policy describes the Personal Information that we collect from you when you participate in any Zestyplan Challenge, including when you register, use the Platform, submit meal photos, interact with our social media platforms, or attend any related events, and what may happen to that information. Generally, you can browse portions of the Platform without revealing your identity. However, to participate in most Challenges you will be required to provide Personal Information to us and will no longer be anonymous to us.

PERSONAL INFORMATION COLLECTION AND USE

We collect, use, and disclose Personal Information via our Platform, social media, and through Challenge-related activities. We may collect Personal Information when you register for a Challenge, submit meal completion photos, participate in surveys, attend live cooking classes or events, or when you voluntarily share information with us.

Program Registration and Participation

Registration: When you register for any Challenge, we collect your name and email address. Depending on the specific Challenge, we may also collect location information, organizational affiliation (if participating through a Partner Organization), or other relevant information needed for Challenge administration.

Organizational Affiliation: Some Challenges are restricted to specific groups such as employees, students, or members of Partner Organizations. For these Challenges, we may collect information verifying your affiliation, which may include employee identification numbers, student numbers, membership status, or authentication through single sign-on (SSO) systems.

Meal Completion: When you submit photos of your completed plant-forward meals, we collect the images and any accompanying information you provide. We use this information to track your progress, calculate environmental and cost impact, unlock rewards, and may feature completed meals (with your consent) in program promotion and education. For Challenges involving Partner Organizations, meal completion data may be included in aggregate reports provided to those organizations.

Impact Tracking: We collect information about which recipes you choose and complete to calculate individual and collective environmental impact, health benefits, and cost savings. This data helps us measure overall Challenge impact and provides participants with their personal metrics. Aggregate impact data may be shared with Partner Organizations.

Live Class and Event Participation: When you attend live cooking classes or other Challenge events, we may collect information about your attendance and participation to improve the program experience, provide recordings or follow-up materials, and measure engagement.

Location Data: We may collect location information to provide region-specific content and resources or to verify eligibility for geographically restricted Challenges.

Team Participation: Some Challenges include team-based or competitive features. If you join or create a team, we collect information about your team affiliation, team name, and team progress to facilitate these features. Team names and standings may be visible to other Challenge participants.

Communication and Engagement

Email Communications: We collect your email address to send you information about recipes, program progress, meal prep tips, and related content. With your consent, Zestyplan may also send you updates about future initiatives and sustainable eating resources. You may unsubscribe at any time using the "Unsubscribe" link in our emails.

Social Media Sharing: If you choose to share your Challenge participation or completed meals on social media platforms, we may collect your social media details for recognition and community building purposes.

Surveys and Feedback: We may collect information through surveys to understand your program experience, recipe preferences, behavior change progress, and suggestions for improvement.

Contact Communications: If you use our Contact Us feature, we collect your name, email address, and the content of your communication to respond to your inquiries and provide support.

Platform Usage and Analytics

Website Usage: When you visit the Platform, we collect information about your usage patterns, pages visited, recipes viewed, and interactions with Platform features. This helps us improve the user experience and understand program engagement.

Device Information: We may collect information about the device you use to access the Platform, including device type, operating system, and browser information for security and optimization purposes.

Progress and Rewards: We track your recipe completions, program progress, and earned rewards to provide personalized program experiences and recognize achievements.

HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Information for the following purposes:

Program Administration

• To register you for Challenges and maintain your participation record • To verify meal completion through photo submissions • To calculate and track individual and collective environmental impact, health benefits, and cost savings • To provide program updates, recipe information, and educational content • To facilitate live cooking classes, events, and provide recordings or follow-up materials • To track progress through program phases or Shifts and unlock program features • To recognize achievements and provide rewards • To facilitate team-based or competitive features where applicable • To generate aggregate reports for Partner Organizations on program participation and outcomes

Communication and Engagement

• To send you program-related communications and updates • To respond to your questions and provide customer support • To send newsletters and educational content about plant-forward eating and sustainable living • To recognize and celebrate participant achievements • To build community among participants • To facilitate team communications where applicable

Platform Improvement and Analytics

• To analyze Platform usage and improve user experience • To understand program engagement and optimize features • To conduct research on plant-forward eating behaviors and sustainable food choices • To generate reports on program impact and outcomes • To improve recipe offerings and educational resources

Marketing and Promotion

• To promote Zestyplan Challenges and their benefits • To share success stories and participant achievements (with consent) • To develop future initiatives and programs • To support Zestyplan's mission to democratize sustainable eating • To support Partner Organizations' wellness, sustainability, or engagement goals and demonstrate program return on investment

Legal and Compliance

• To comply with legal requirements and respond to legal processes • To protect our rights, privacy, safety, and property, and those of our users • To enforce our Terms of Use and prevent fraudulent or harmful activities

PERSONAL INFORMATION SHARING AND DISCLOSURE

We will only disclose your Personal Information with your consent or if we have legal authority to do so, including in the following contexts:

Service Providers

We may employ third-party companies and individuals to facilitate or provide services related to the Platform (including hosting, data processing, email communications, analytics, video conferencing for live classes or events, payment processing, and customer support). These third parties only have access to Personal Information needed to perform their tasks and are contractually required not to disclose or use it for any other purpose.

Partner Organizations

When you participate in a Challenge offered in partnership with an organization, certain information may be shared with that Partner Organization:

Aggregate Data Shared with Partner Organizations: • Total number of participants affiliated with the organization • Collective environmental impact (CO2 saved, water conserved, meals logged) • Program engagement metrics (average recipes completed, attendance rates, overall participation levels) • Anonymous survey feedback and program insights • Team participation and competition results (team names and standings, not individual identities)

Partner Organizations Do NOT Receive: • Individual names linked to specific recipes, photos, or participation details • Personal contact information (unless you separately provide it to the Partner Organization) • Individual-level data that could identify specific employees, students, or members • Any information that would reveal individual dietary choices or behaviors

Data shared with Partner Organizations is used solely for program reporting, wellness or sustainability goal tracking, program improvement, and demonstrating return on investment for their participation, in accordance with applicable privacy laws including employment and student privacy regulations.

If you are participating through a Partner Organization, we encourage you to review that organization's privacy policy to understand how they handle aggregate program data.

Recipe Contributors and Program Partners

With your consent, we may share certain information with:

• Recipe Contributors: Aggregate, anonymized data about recipe popularity and feedback • Program Partners: Information necessary to facilitate partner benefits and recognition such as rewards programs or promotional offers

Legal Requirements

We may disclose your Personal Information to meet legal, regulatory, or audit requirements, to respond to legal processes, to enforce our Terms of Use, to respond to claims of rights violations, or to protect the safety and security of our users and the public, as permitted or required by law.

Aggregated and Anonymized Data

We may share aggregated, anonymized information that cannot identify individual participants for research, reporting, and promotional purposes, including environmental impact reporting and sustainable eating research. This data may be shared publicly or with research institutions, media, or other organizations to advance understanding of plant-forward eating and sustainable food systems.

INTERNATIONAL STORAGE AND TRANSFER OF PERSONAL INFORMATION

To provide our services, we may collect, use, disclose, store, or process Personal Information on servers located in various jurisdictions, including the United States, for the purposes described in this Policy. Privacy laws in such jurisdictions may differ from those where you reside. By participating in any Zestyplan Challenge, you consent to such transfer and storage of your Personal Information outside your jurisdiction of residence.

DATA SECURITY

Zestyplan employs reasonable physical, technological, and administrative security measures to protect your Personal Information. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We will make any legally required notifications of security breaches involving your Personal Information via email or conspicuous posting on the Platform in the most expedient time possible, consistent with law enforcement needs and measures necessary to determine the scope of the breach and restore system integrity.

Partner Organizations may maintain separate security measures for any data stored in their systems. Please refer to Partner Organization privacy policies for information about their data protection practices.

COOKIES AND TRACKING TECHNOLOGIES

When you use the Platform, we automatically collect information through cookies and similar technologies, including:

Information Collected

• IP address and general location information • Device type, browser type, and operating system • Pages visited, time spent on pages, and clickstream behavior • Date and time of visits and Platform usage patterns • Referring websites and exit pages

How We Use Cookies

We use cookies to:

• Enable Platform functionality and maintain your session • Personalize your experience and remember your preferences • Analyze Platform usage and improve our services • Measure program engagement and participation patterns • Provide security features and prevent fraudulent activity

Third-Party Analytics

We use analytics services such as Google Analytics to better understand Platform usage and program engagement. These services may collect information about your activities across different websites over time. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

Managing Cookies

You can control cookies through your browser settings, but disabling cookies may limit your ability to use certain Platform features. Most browsers allow you to:

• View and delete cookies • Block third-party cookies • Block all cookies (though this may impact functionality)

DATA RETENTION

We retain your Personal Information only as long as necessary to fulfill the purposes for which it was collected, including:

• For the duration of your Challenge participation • To meet legal, accounting, or reporting requirements • To resolve disputes and enforce agreements • As required for legitimate business purposes • For Partner Organization reporting and program evaluation needs (in aggregate form only)

We may anonymize your Personal Information so that it can no longer be associated with you, and use this anonymized information for research, analysis, and reporting purposes to support sustainable eating initiatives and plant-forward eating research.

YOUR RIGHTS AND CHOICES

Access and Correction

You have the right to request access to and correction of the Personal Information we hold about you. To make such requests, please contact us at contactus@zestyplan.com.

For questions about how a Partner Organization uses aggregate data from a Challenge, please contact that organization directly.

Withdrawal of Consent

You may withdraw your consent to certain uses of your Personal Information, though this may affect your ability to participate in Challenges. We will explain the consequences of withdrawal to help you make an informed decision.

Communication Preferences

You can opt out of marketing communications at any time by:

• Using the "Unsubscribe" link in our emails • Contacting us directly at contactus@zestyplan.com • Updating your preferences in your account

Data Deletion

You may request deletion of your Personal Information, subject to legal requirements and legitimate business needs. Some information may need to be retained for legal compliance or to complete program participation and impact reporting.

Note that if you request data deletion, aggregate data (which cannot identify you individually) may still be included in reports provided to Partner Organizations or used for research purposes.

Account Deactivation

You may deactivate your Challenge account at any time by contacting us. Upon deactivation, we will cease using your Personal Information for program communications and activities, though some information may be retained as described above.

LINKS TO OTHER WEBSITES

The Platform may contain links to third-party websites or services, including those of our partners. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to read the privacy policies of any websites you visit through links from our Platform.

CHILDREN'S PRIVACY

Some Zestyplan Challenges are designed to be family-friendly, and families may participate together. However, we do not knowingly collect Personal Information from children under 13 without parental consent. If you believe we have inadvertently collected information from a child under 13, please contact us immediately so we can take appropriate action.

Challenges offered through workplaces or educational institutions may have age restrictions as determined by the Partner Organization.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of material changes by posting the updated Policy on the Platform and updating the "Last updated" date. Your continued participation in any Challenge after such changes constitutes your acceptance of the updated Policy.

CONTACT INFORMATION

We welcome your questions and comments about privacy and data protection. Please send any questions, comments, or complaints to the attention of our Privacy Officer:

Email: contactus@zestyplan.com Address: Zestyplan Inc., 14 DeGrassi Street, Toronto, ON, M4M 2K3

For questions specific to a Partner Organization's use of aggregate program data or that organization's data privacy policies, please contact the Partner Organization directly.

By participating in any Zestyplan Challenge, you acknowledge that you have read, understood, and agree to this Privacy Policy.