FINEQUITIES PRIVACY POLICY
Reviewed May 8, 2023

This is the Finequities Privacy Policy, which explains how Finequities, LLC (the “Company,” “Finequities,” “we,” “our,” “us”) processes your information with our website and mobile app (collectively, the “Services”) and otherwise.

1. INFORMATION WE MAY COLLECT

Finequities, LLC is not a brokerage firm. Finequities, LLC is a Registered Investment Advisor. We do not store nor ask for social security, date of birth, or gender. The credentials to link your brokerage accounts are not stored by Finequities directly and will not be seen by us. They are transmitted directly to plaid or other third-party services with the express purpose of integrating your accounts into our platform.

We may collect or have access to personal information from you when you use our Services, sign up for an account, request a transaction, connect the Services with a third-party broker or financial institution, enroll in a program, or otherwise interact with the Services. This information may include, depending on the information practices of your broker or financial institution:

– Account Profile: username and password, responses to questionnaires, and interactions with the Services and
with customer support or other representatives or agents of Finequities.

– Identity: name, last name.

– Contact: email address.

– Financial: Finequities, through account linking integrations, will have access to your account details,
positions, transactions, withdrawals/deposits, and net liquidation value.

Additionally, by using the Services, you agree to our capture and storage of information regarding how you use the
Services, your interactions with others, uploads, content you provide, your username, and other content, media,
contacts, and other information on your device, subject to your permission and your device settings. You consent to such disclosure of this information as is required for the operation of the Services or by law or regulation (as so deemed by our best judgment) We also collect some personal information automatically, including:

– Location: we collect data about users’ geographic location and IP addresses used when interacting with the
Services. We use this information to protect against fraud. We may also use the Google Maps API to gather
information about your location. Google uses various technologies to determine your location, including IP
address, GPS, and other sensors that may, for example, provide Google with information on nearby devices,
Wi-Fi access points, and cell towers (see Google’s Privacy Policy to learn more).

– Tracking: For convenience and ease of use, Finequities and our third-party providers may automatically
collect information when you visit or use our Services, read our emails, or otherwise engage with us. We
typically use tracking technologies that include cookies, clear gifs, Flash objects, web beacons, embedded
scripts, and similar technology (collectively, “Trackers”). For example, we may collect information about your
preferences, analytics for the Services, your device and its operating system, your IP address, browser type,
service provider, date and time stamp, and other similar information. We use Trackers to improve your
experience and our Services. We also use Trackers to target advertising. We may also collect the names of
other third-party applications on your device. You may adjust settings on your web browser and in your
email service to change the way certain Trackers work, or to disable them. Changing these settings may limit
the range of features available to you on our Services. Information provided by your browser developer and
email provider will help you understand the limitations of these settings for you.

– Personal Information from Third Parties: We may also obtain personal information from third parties from
time to time, such as connected apps and services, business partners, marketing, and other vendors.

– Account and Services Linking. Finequities offers account linking and aggregation services that will connect
the Services to your brokerage, banking, or other accounts. By linking these accounts, you expressly grant to
us, your other account providers, and our technology partners the right, power, and authority to access, and
transmit any of your information as reasonably necessary for the linked exchange of information and
instructions. 

2. OUR USE OF YOUR INFORMATION.

We use the information we collect for purposes described in this Privacy Policy and as described to you on our
Services and our Terms. This includes using the information to:

– Provide the Services to you, allowing you to use the Services and participate in interactive features and for
Finequities to handle billing and account management, fulfill our legal and regulatory obligations, and to
complete other administrative matters.

– Provide information to you, including transaction confirmations, portfolio updates, technical notices, Services
information and announcements, software updates, security alerts, support and administrative messages,
information about your transactions with us, responses to comments and questions, newsletters or other
content, customer service or feedback information, contact you about amounts owed, conduct surveys,
respond to employment applications, notify you about upcoming events, or any other information related to
the Services.

– Conduct research and review analytics to understand user activity, test, and improve our product offerings.

– Enhance the safety and security of the Services, our business, and our users, and investigate or provide notice of fraud or unlawful or criminal activity.

– Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce
and carry out contracts and agreements; and  Comply with laws, regulations, and legal obligations.

3. DISCLOSURES

Consistent with the collection practices and purposes described in this policy, we may share your personal
information for certain purposes. We do not sell or rent your personal information to third parties, aside from
substantial corporate transactions (described below).

We may share your personal information with:

– Our third-party vendors and service providers. We share personal data with authorized and vetted
contractors, subcontractors, third-party vendors, and service providers who help us run and protect the
Services and our business. This includes messaging, business analytics, marketing, hosting, fulfillment,
reporting, and data processing.

– Our business transactions. We may share personal data in connection as reasonably necessary in the event of
a company business transaction, such as the sale of our assets, a merger, consolidation, reorganization,
financing, change of control or acquisition between our company and another company or third party, an
initial public offering, or bankruptcy or similar proceeding.

– Otherwise, as you agree. We may share personal data for other purposes with your consent.

– As legally required. We will disclose personal data to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Finequities, our related companies and integral third parties, users, or the public.
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual. For further information on your choices regarding your personal information, see the “Control of Your Information” section of this policy, below.

4. SOCIAL PLATFORM

Creating a social profile means you choose to be a part of our social community. A social profile allows you to
participate in our leaderboard. A social profile shall publicly show a picture of your choice, your bio, the users you
follow, posts, likes, comments, and any other content you write to interact with other users in our platform.

With your consent, you may or may not share the performance of your portfolio/ positions on our leaderboard, this portfolio and/or positions shall be reflected in your social profile Finequities does not manage “shared portfolios”, users agree to the privacy policy to be able to participate in the leaderboard. Shared portfolios will only show them stocks, Etfs, crypto or other similar assets you have invested in, your leaderboard ranking and daily/total gain percentages, as well as your investment performance over time. Shared portfolios will not show the amount of money you have invested.

Finequities does not verify the accuracy of any posts or comments by users, however, Finequities constantly monitors content to control what’s being made public. We continually remove posts containing any inappropriate content, such as nudity, hate speech, unlawful, dangerous behavior or anything that violates our privacy policy and terms of service.

5. LINKS AND THIRD-PARTY CONTENT

Some of the Services may contain links to or included content and data provided or maintained by third parties.
These include but are not limited to the issuers of equities, as well as stock exchange data services, and any brokerage or other account providers that you may have. We are not responsible for the privacy practices of these third parties or the content provided by third-party services, and the information practices of these third parties are not covered by this Policy.

Please note that these third-party services have their own privacy policies, and we strongly recommend
that you read their privacy policies as well as terms and conditions of use to understand how they collect, use, and share your information.

6. TRACKING AND ONLINE ADVERTISING

We may participate in interest-based advertising and use third-party advertising companies to serve targeted
advertisements based on your online browsing history and interests. We permit third-party online advertising
networks, social media companies, and other third-party services to collect information about your use of our Services over time so that they may play or display ads on other websites, apps, or services you may use, and on other devices you may use.

For advertising, we may share a common account identifier or other data with our advertising partners
to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online on other platforms more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

We’re not responsible for the privacy practices of third parties, and the information practices of third parties are not covered by this Policy. We may use Google Analytics to recognize you and link your devices. Google Analytics shows us how our users interact with our Services and helps us to tailor our advertisements and content. For information on Google Analytics, as well as how you can control information sent to Google and how these advertising practices affect you and your information, please review the information here http://www.google.com/policies/privacy/partners/ and here https://tools.google.com/dlpage/gaoptout/ and consider the opt-out possibilities here https://google.com/ads/preferences and here http://www.networkadvertising.org/choices

7. CONTROLLING YOUR INFORMATION

You are able to control our access and/or use of your personal information as follows:

– Log in to your account to update your account profile information.

– Control our mobile app’s access to your device information, and data and files stored in your device, in your
device’s settings.

– Stop receiving promotional emails from us by clicking on the provided “unsubscribe” link. (You may not opt
out of service-related or other non-promotional communications such as account verification, transactional
communications, changes/updates to features of the Services, and technical and security notices.

– Control what notifications you receive from us on your mobile device (promotional, non-promotional
notifications or alerts). You may opt-out by deactivating this feature in the notifications section of the app.

For any other questions or privacy-related requests, please contact support@finequities.com. We will do our best to honor your request, within our technical and Service-based limitations.

8. TRANSFER OF PERSONAL INFORMATION

We are based in the United States, and our Services are designed for use only in the United States. If you are using our Services from another jurisdiction, your information collected through our Services may be stored and processed in the United States or any other country in which Finequities or its service providers maintain facilities or conduct business activities. If you are located in other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data-protection laws.

9. CALIFORNIA RESIDENTS

California residents have certain rights under the California Consumer Privacy Act (“CCPA”). Please note that the CCPA does not apply to nonpublic personal information collected by financial institutions, which is regulated by other laws.

The CCPA does not therefore apply to much of the information we collect.

Subject to limitations and exceptions, the CCPA provides California residents the right to request details about the categories and specific elements of personal information we collect, to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. Choices available to you for the collection and handling of your information are addressed throughout this policy.

In the last 12 months, we collected the following categories of personal information subject to the CCPA: identifiers (such as email address and IP address), approximate geolocation information, and Internet or other electronic network activity information (such as browsing history and related usage data).

For more details about the information we collect and the categories of sources of this information, please see the above sections of this policy. We share this information with the categories of third parties described in the “Disclosures” section above.

California residents may make a request for access to certain personal information subject to the CCPA, not otherwise exempted as nonpublic personal information collected by financial institutions, by sending an email to
support@finequities.com. We may verify any such request by asking you to provide information that matches
information we have on file about you.

You can also designate an authorized agent to exercise these rights on your
behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.

10. CHILDREN’S PRIVACY

We do not knowingly solicit or collect information from anyone under the age of 13. In the event that we learn that we have inadvertently collected personal information from someone under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at support@finequities.com.

11. CHANGES TO THIS POLICY

This Privacy Policy will evolve with time, and when we update it, we will revise the “Effective Date” above and post the new Policy. To stay informed of our privacy practices, we recommend you review the Policy on a regular basis as you continue to use our Services.

12. CONTACT US

If you have any questions, comments, suggestions, complaints about this Privacy Policy or the Services provided by Finequities, please contact us at support@finequities.com.