Policy Effective Date: May 1, 2023

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1. INTRODUCTION

This Privacy Policy sets forth how personal information is collected, used, processed and disclosed, in conjunction with your access and use of the web site located at www.finhabits.com and our mobile application (collectively, “Services”). Unless otherwise indicated, this Privacy Policy only applies to personal information collected through Services by Finhabits Inc., Finhabits Advisors, LLC, Finhabits Insurance Services, LLC, or any of their respective affiliates (together, for purposes hereof, “Finhabits”).

2. BOUNDING TO PRIVACY POLICY

By using the Services, you agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future. If you do not agree to any of the terms in this Privacy Policy or the Terms of Use, you may not access or use the Services. This Privacy Policy applies to visitors to the website and our mobile application, who view publicly accessible content (“Visitors”) and customers who have signed up to access and use the Services offered by Finhabits (“Customers”).

3. CATEGORIES OF PERSONAL INFORMATION

• Your name, alias, date of birth, gender, Tax ID number, citizenship and passport number, visa information, home address, telephone number, email address, social security number, bank account number, bank routing number, bank account login credentials, bank name, employer name, employment status, and job position.

• Certain features of the Services will allow you to link your credit card, debit card, and bank accounts (collectively the “Financial Accounts”). Financial data such as information you authorize us to collect from the Financial Accounts.

• Whether you are a “politically exposed person,” whether you are a “control person” (pursuant to FINRA Rule 3210), annual income range, total net worth range, and other information as appropriate for our legitimate business needs.

• Non-Public Personal Information means (i) any information you provide to us to obtain a financial product or service from us, (ii) any information about you resulting from any transaction involving a financial product or service between us and you, (iii) any information about a transaction, purchase or sale you are seeking to execute through through the Services, or (iv) any information we otherwise obtain about you in connection with providing a financial product or service to you (collectively, the “Non-Public Personal Information”). We may also collect Non-Public Personal Information from Visitors.

• Geolocational Information means certain features and functionalities of the Services are based on your location. In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocation information from your mobile device, wireless carrier, or certain third-party service providers. Such information is collectively called the «Geolocational Information.» Collection of such Geolocational Information occurs only when the App is running on your mobile device. You may decline to allow us to collect such Geolocational Information, in which case Finhabits will not be able to provide certain features or functionalities to you.

4. HOW WE COLLECT PERSONAL INFORMATION

• Your Personal Information may be collected when you register to become a Customer.

• We may collect information derived or resulting from voluntary surveys.

• We may record any customer service calls and maintain such recordings to better improve our Services.

• We may also collect Personal Information when you voluntarily provide us with Personal Information as a Visitor, such as when you use our “Contact Us” form.

• We may automatically collect or receive information about you, your use of our Services, your interactions with us and our advertising, as well as information regarding your computer or other devices used to access our Services, such as:

• Online Identifiers: browser fingerprint, operating system, browser name and version, and/or personal IP addresses.

• Device information: type of device, Universally Unique Identifier, advertising identifiers (“IDFA” or “AdID”), operating system and version, wireless carrier, and network type.

• Usage data: authentication data, security questions, click-stream data, public social networking posts, and other data collected via web beacons, pixel tags, embedded links, cookies, and other similar tracking techniques.

• Cookies: Our cookies help provide additional functionality to the Services and help us analyze the Services usage more accurately. In all cases in which we use cookies, we will not collect Personal Information unless we obtain your permission.

• Third-Party analytics: We may use third-party analytics services (for example, we use Google Analytics, and others) to evaluate your use of the Services, compile reports on activity, analyze performance metrics, and collect and evaluate other information relating to the Services and mobile and Internet usage. For more information on these third parties, including how to opt out from certain data collection, please visit www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.

5. INFORMATION COLLECTED BY OR RECEIVED FROM THIRD PARTY SOURCES

We may also collect Personal Information about you from third-party sources, such as banking verification services, consumer reporting agencies, unaffiliated third parties, brokers, banks, or government databases. We may combine data we collect about you from third-party data sources with data we collect from you and may use and share such data as described in this Privacy Policy. All information we collect or receive from such third-party sources is referred to as “Third-Party Information.”

Finhabits uses Plaid Inc. (“Plaid”) for account linking services and to gather your data from financial institutions. This data may include information from all your sub-accounts (e.g., checking, savings, and credit card) accessible through a single set of account credentials, even if only a single sub-account is designated by you. By using our Services, you grant us, Plaid, the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal/#end-user-privacy-policy).

6. INFORMATION COLLECTED BY OR THROUGH THIRD-PARTY ADVERTISING

We may share information about you with third parties that Finhabits has selected and approved for ad distribution and ad optimization (including tailoring, behavioral or contextual targeting or retargeting, analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags, and other technologies to collect information about you for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive information about you from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

7. HOW THE INFORMATION IS USED

Your Personal Information is used to:

7.1. Provide, improve, and develop the Services, including, for example:

• To enable you to access and use the Services.

• To fulfill our contractual obligations to you or any requests by you for support.

• To provide you personalized suggestions and recommendations about trade recommendations, budgeting, saving money, spending, or other financial products, services or offers that we believe may help you, based on information about your transactions, purchases, or account balances.

• To maintain or service Customer accounts, process or fulfill orders and transactions, verify Customer information, or process payments.

• To engage other companies to perform certain functions on our behalf, including, for example, website hosting, mailing information, maintaining databases, ID verification, processing applications, processing payments and completing transactions.

• To operate, protect, improve, and optimize the Services, such as by performing analytics and conducting research, such as by compiling aggregated and anonymized information about our Customers’ demographics, interests and behaviors, in order to better understand our Customer base and to develop new products, features or services.

We process your Personal Information for these purposes given our legitimate interest in improving the Services and our Customers’ experience with it, and where it is necessary for the adequate performance of our contractual obligations with you.

7.2. Create and Maintain a Trusted and Safe Environment

We may use Personal Information to create and maintain a trusted and safe environment, including, for example:

• To comply with our legal obligations, including to detect and prevent fraud, spam, abuse, security incidents, and other harmful or illegal activity, or to conduct security investigations and risk assessments.

• To verify or authenticate information or identifications provided by you, or to conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.

• To ensure compliance with and enforce our Terms of Service, Privacy Policy, or other policies, agreements or terms and conditions.

• To resolve any disputes with any of our Customers and enforce our agreements with third parties.

• To conduct debugging to identify and repair errors.

• To share your Personal Information with any of our parent companies, affiliates, subsidiaries, joint ventures, or other companies that we control, are controlled by, or are under common control with us.

• To comply with our obligations in the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event. If your Personal Information is part of the transferred assets, you will be notified via email and/or a prominent notice on our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

• To comply with a court order or other lawful request or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Finhabits, (iii) act in urgent circumstances to protect the financial security of users of the Services or the public against fraud or other harm, or (iv) protect against legal liability.

We process your Personal Information for these purposes given our legitimate interest in protecting the Services, to measure the adequate performance of our contractual obligations with you, and to comply with applicable laws.

7.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing

We may use Personal Information to provide, personalize, measure, and improve our advertising and marketing, including, for example:

• To send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Finhabits or partner campaigns and services).

• To personalize, measure, and improve our advertising.

• To administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Finhabits or its third party partners.

• To conduct profiling on your characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

• To share your Personal Information with third parties, including but not limited to third-party market research firms for analysis purposes and to help such third parties generate anonymized and aggregated market research data for us. However, under no circumstances will we ever sell your Personal Information to third parties.

We will process your Personal Information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.

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Finhabits may create aggregated, de-identified and/or anonymized data created from your Non-Public Personal Information and those of other Finhabits customers whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes it possible to identify you from the data and aggregating it with that of other customers. The use and disclosure of such aggregated, de-identified and/or anonymized data is not subject to any restrictions under this Privacy Policy.

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8. SHARING OF PERSONAL INFORMATION

We will not share your Personal Information with non-affiliated third parties that may use your Personal Information to market to you, without obtaining your opt-in consent. If you have opted-in for this kind of sharing of your Personal Information, then you may: (i) choose to opt out of such sharing; or (ii) request certain information regarding our disclosure of your Personal Information to such non-affiliated third parties, in each case by contacting us by following the instructions in the “Contact Us” section below.

9. HOW YOU MAY CHANGE OR UPDATE YOUR PERSONAL INFORMATION

If you have provided us with any Personal Information, you may access, review, and/or make changes, by making the changes in your registered account settings page or by contacting us.

10. PROTECTION OF PERSONAL INFORMATION

The security of your personal information is important to us. When you enter sensitive information, such as a credit card number or financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Finhabits Sites, please contact us.

If you know or have reason to believe that your Personal Information or Finhabits account has been stolen, misappropriated, or otherwise compromised, or if you receive an unsolicited email or other electronic communication that appears to be from Finhabits but you suspect it may be from some other source or fraudulent, please contact us by following the instructions in the “Contact Us” section below.

11. RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We will also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If your customer relationship with Finhabits ends, we will not destroy your Information unless required or permitted by law. We will continue to treat your Personal Information in accordance with this Privacy Policy and applicable laws.

Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Finhabits, such as statistics of the use of the Services.

12. COMMUNICATION PREFERENCES

You have choices on the messages you choose to receive.

• As a user of the Services we and/or our custodian(s), will send you administrative and transactional communications that are necessary to provide the Services, such as billing, brokerage, fraud or service notifications. You cannot opt out of receiving such communications.

• When you sign up for our Services or newsletter(s), we will send periodic emails to you regarding the Services or to tell you about services we believe will be of interest to you. To opt out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you.

• By providing your phone number you expressly consent to Finhabits and/or its agents calling or texting you using an automated telephone dialing system and / or prerecorded messages, even if you incur charges for receiving such communications. For example, we may send you informational text messages to your mobile device in order to better service your account. You can revoke your consent to receiving informational text messages at any time by replying “STOP” or following any other instructions included in these text messages.

13. CALIFORNIA PRIVACY RIGHTS

• Right to know: The California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request and subject to applicable exemptions, to request that we give you access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared.

• Right to delete: California residents have the right to submit a request for deletion of information under certain circumstances.

• Right to correct: California residents have the right to request correction of inaccurate Personal Information.

• Right to opt-out of sharing: Finhabits does not share Personal Information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your Personal Information to third parties for their direct marketing purposes by withholding consent. Sharing means the disclosure of personal information to a third party “for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.” Cross-context behavioral advertising is the CPRA’s term for interest-based advertising or retargeting.

• Right to opt-out of selling: We do not sell Personal Information to third parties.  We do allow third parties to collect personal information through our Service and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

• Right to Limit Use and Disclosure of Sensitive Personal Information: California residents have the right to limit the use and disclosure of their sensitive Personal Information, to that use which is necessary to perform the services. Sensitive personal information” means: Personal information that reveals: (i) A consumer’s social security, driver’s license, state identification card, or passport number. (ii) A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. (iii) A consumer’s precise geolocation; (iv) A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership. (v)The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. (vi) A consumer’s genetic data.

• No discrimination: Finhabits will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you a different level or quality of services.

• Requests regarding Data Privacy: To submit a data request, please contact us by following the instructions in the “Contact Us” section below. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification. Your request would be answered, free of charge, within 45 days of receiving the verifiable request. The time period to provide the required information, or to correct inaccurate personal information or delete personal information, may be extended once by an additional 45 days when reasonably necessary, if it is the case you would be provided notice of the extension within the first 45-day period.

• List of third parties: California law permits consumers who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those third parties.

14. CHANGES TO PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on the Services. Your continued access to or use of the Services after we make any changes to this Privacy Policy, will be subject to the revised Privacy Policy.

15. CONTACT INFORMATION

If you have questions or concerns regarding this Privacy Policy, or about Finhabits information handling practices, or if you have a complaint, please contact us by emailing us at support@finhabits.com, or calling us at 1-800-492-1175.

16. PRIVACY DISCLOSURES FOR EMPLOYEES

Employees may exercise their privacy rights by emailing us at support@finhabits.com, or calling us at 1-800-492-1175.