Our Commitment to Privacy

At InvestiFi Inc. (“InvestiFi”), including our subsidiaries and affiliates (hereinafter collectively referred to as “our,” “we,” or “us”), our client and customer relationships are our most important asset. InvestiFi is dedicated to respecting and protecting the privacy of your information. We maintain customer information to provide the most effective and convenient access to the Services (defined below). This privacy policy (“Privacy Policy”) is designed to provide details on how we collect, use, and share your information and applies to all websites and mobile applications linking to or posting this Privacy Policy (collectively, the “Platform”) that are operated by InvestiFi and our affiliates, AdvisiFi LLC, an SEC-registered investment adviser, and/or CDS1 Securities LLC, an SEC-registered broker-dealer and a member of FINRA/SIPC.

By using our Platform, you agree to the terms and conditions of this Privacy Policy. You may access any of the investment services that are made available by third parties, such as qualified custodians, clearing firms, and liquidity providers, who may or may not be affiliates or subsidiaries of ours (“Service Providers”), in whole or in part, through our Platform (each, a “Service” and collectively, the “Services”).  Please refer to the various websites of the Service Providers for more information on each of the Services generally. Our Platform is only available to individuals aged 18 or older, and we do not knowingly collect personal information from any person under the age of 18. In the event an individual under the age of 18 has provided us with personal information, a parent or guardian of such individual may contact us and request that the individual’s information be deleted. Upon receipt of such a request, we will endeavor to delete the applicable information from our databases. InvestiFi does not provide the Services.

Why We Collect Personal Information

InvestiFi is a technology service provider to banks and credit unions. To provide a seamless end-user experience, we collect nonpublic personal information in order to coordinate with your financial institution, i.e., banks and credit unions (each a “Financial Institution”), their existing mobile application technology providers, as well as the Service Providers. Information sharing between all parties involved is a necessary component of providing the Services to you.

Information We May Collect

Customer and Financial Information: When you sign up through your Financial Institution to participate in the Services, certain nonpublic personal information may be collected and shared between and among us and the Service Providers. The personal information may include, among other things, first name, middle name, last name, address, email address, phone number, date of birth, tax identification number, nationality, government-issued identity document(s), background information (employment and income), funding bank account, investment profile, and transaction-related information. All personal information provided must be true, complete, and accurate, and you must notify your Financial Institution of any changes to such personal information. We also collect data analytics information related to active users, such as the number of active users and information regarding the nature, volume and frequency of transactions and use of the Platform and Service generally.

Communications: If you contact us directly, we may request additional information about you. When you contact our customer service and support team, we will request your name, email address, phone number, contents of messages or attachments that you may send to us, and other information you choose to provide.

Your Financial Institution may contact InvestiFi for the purpose and intent of assisting them with end-user support, troubleshooting, or general knowledge and education. We will request additional information about the business operations, technical components, and/or your information to provide appropriate customer support. The sharing of information is deemed necessary to efficiently offer assistance in resolving customer service inquiries.

When you access our Platform, we may collect information through automated means, such as cookies, web beacons, and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs, operating system version, language preferences, referring URLs, and information about the usage of our Platform. Please see our Cookie Policy posted on our Platform.

If you do not want information collected using cookies, most browsers have a simple procedure that allows you to automatically decline cookies or choose to decline or accept the transfer to your computer of a particular cookie(s) from a particular site.

When you access the Services via your Financial Institution’s digital or online banking application, the providers of those applications may collect information through automated means. The information collected from these providers may or may not be shared with InvestiFi and depends on each provider’s technical specifications.

How We Collect Your Information

We may obtain information about you through your Financial Institution, through our Service Providers, public blockchain data, and/or directly from you. For example, when you provide your wallet information to us, we may track transaction information from public blockchain records. Additionally, when you create an account and/or use a Financial Institution for certain financial services, the Financial Institution may provide your personal information to us so that we may provide our Services.

How We Use Your Information

We use nonpublic personal information to operate, maintain, enhance, and provide features of the Services, to provide services and information that you request, to respond to comments and questions, and to otherwise support you and your Financial Institution.

We may use your information to analyze usage trends and preferences of end users to improve Services and to develop new products, services, features, and functionality. These insights will be shared with your Financial Institution.

We may use your information for administrative and informational purposes and to personalize your experience or to enforce our legal rights. This may include customer service and support or sending communications.

How We Share Your Information

We will never sell or rent personal information for any purpose. We only disclose information that we collect through our Platform to third parties in the following circumstances:

• To our affiliates and subsidiaries, Service Providers, Financial Institutions, and third-party service providers who provide services such as payment processing, data analysis, information technology, and related infrastructure provision, customer service, email delivery, and other necessary services to maintain operations.
• If required by law or in good faith, believe that such action is appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations or those of our partners; (f) to protect our rights, privacy, safety or property; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Security

InvestiFi maintains physical, electronic, and procedural safeguards to protect your nonpublic personal information with. Security measures are in place for detecting possible data breaches. In accordance with applicable laws, we will provide notice of a data breach to Financial Institutions, you, and any applicable regulatory body. Nonpublic personal information is encrypted in transit and at rest. Firewalls, IP whitelisting, and individual access keys secure access to this nonpublic personal information. We may mask non-public or sensitive data for reporting and exportable screenshots to our contracted Financial Institutions. Adherence to this privacy policy continues whether user accounts are active or closed. We restrict access to nonpublic personal information to only employees and contractors with a genuine business purpose.

We cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of user information will not occur. Users play a vital role in protecting their own information. When registering for the Services through your Financial Institution, you should choose a password of sufficient length and complexity, not reveal this password to any third parties, and immediately notify your Financial Institution if unauthorized access is suspected or identified. The security protocols offered through digital banking applications that you use to trade and view account information are dependent on the digital banking credentials, which are maintained and monitored by the Financial Institution and their technology partners and providers, which are independent and not affiliated with us.

Personal information that we receive in connection with providing products and services to Financial Institutions is subject to our policy on the privacy and security of consumer financial information, which is in compliance with the Gramm-Leach-Bliley Act (GLBA) and other applicable data privacy laws and regulations.

Your Rights

You have certain rights regarding personal information. For example, you may have the right to access or receive certain data about the personal information we process, have your personal information rectified, object to the processing of personal information, or ask us to restrict processing, delete personal information, or withdraw consent to processing. You have the right to instruct the removal of personal information; however, InvestiFi’s processes require users to first notify their Financial Institution. Please be aware it is not possible to remove all records of information provided for the Services as there may be retention requirements.

Please contact your Financial Institution or applicable Service Provider to correct your account information with your Financial Institution or Service Provider or to opt out of their information sharing.

CCPA Privacy Notice

Under the California Consumer Privacy Act of 2018 (CCPA), we are required to provide certain information to California residents about how we collect, use, and share personal information and about the rights and choices California residents may have concerning their personal information.

The California Code of Regulations defines a “resident” as (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California for a temporary or transitory purpose. All other individuals are defined as “non-residents.”

Effective January 1, 2023, the California Privacy Rights Act (“CPRA”) allows for more protections for California residents (consumers, employees, and contractors). The CPRA amends and extends the CCPA. As a California resident, you have the right to ‘opt out’ of not only selling but the sharing of your personal information (data that does or can identify you). We do not sell or share your personal data with third parties unless related to a Service you request. The CPRA expands your right to request and obtain information about categories of personal information we disclosed to our third-party providers from January 1, 2022, and onward. If you wish to “Opt-Out,” of our selling or sharing of your personal information, please contact us at optout@investifi.co.

California residents have the right to 1) request a business to disclose the categories and specific pieces of personal data the business collected; 2) request the business delete any personal data about them that the business has previously collected; and 3) request the business not to sell their personal data.

Consumers may designate an authorized agent to make the request under the CCPA on their behalf. The authorized agent must submit proof that the consumer gave them power of attorney pursuant to Probate Code sections 4000 – 4465. We may deny a request from the authorized agent who does not provide sufficient proof of authorization to act on the consumer’s behalf.

California residents may opt out of the “sale” of their personal information and have the right not to be discriminated against for exercising their rights. We do not sell consumers’ personal information and will not discriminate against a California resident for exercising rights under the CCPA.

CONNECTICUT DATA PRIVACY ACT (CDPAC) & COLORADO
PRIVACY ACT (CPA

Connecticut Data Privacy Act (CDPAC) and the Colorado Privacy Act (CPA), both effective July 1, 2023, provide residents of these states with the following rights:

• The right to access personal data collected.
• The right to correct inaccuracies in personal data.
• The right to delete personal data, including personal data that a controller collected through third parties.
• The right to obtain a copy of their personal data in a portable and readily usable format that allows residents to transfer the data to another controller with ease.
• The right to opt-out of (1) the sale of their personal data; (2) the processing of personal data for the purposes of targeted advertising; (3) profiling that may have a legal or other significant impact.
• The right to designate another person to serve as the consumer’s authorized agent and act on such consumer’s behalf, to opt out of the processing of such consumer’s personal data for one or more of the purposes specified. A consumer may designate such authorized agent by way of, among other things, a technology, including an internet link or a browser setting, browser extension, or global device setting, indicating such consumer’s intent to opt out of processing personal data.

If you are a resident of Connecticut or Colorado and wish to exercise your rights described above, please contact us at optout@investifi.co. InvestiFi shall respond no later than forty-five (45) days after receipt of the request. We may extend the response time by an additional forty-five (45) days when reasonably necessary and is dependent on the number of consumer requests. As a Connecticut or Colorado resident and consumer, you will be notified of such an extension. If we decline to take action regarding your request, we will inform you without delay but no later than forty-five (45) days after receipt of the request with justification for declining to take action and will provide instructions on how to appeal the decision. To submit an appeal, please contact us at  optout@investifi.co.

All information provided to Connecticut or Colorado consumers in response to a request will be provided free of charge once per consumer during any twelve-month period. If excessive or repetitive requests are received, we may charge a reasonable fee to cover administrative costs associated with the request or decline to act on the request. If we are unable to authenticate a request to exercise any of the rights afforded and referenced above using commercially reasonable efforts, we shall not be required to comply with a request and shall provide notice to you that we are unable to authenticate the request to exercise such rights until you provide additional information reasonably necessary to authenticate.

UTAH CONSUMER PRIVACY ACT (UCPA)

The Utah Consumer Privacy Act (UCPA) was enacted on March 24, 2022, and became effective December 31, 2023. Utah consumers are granted new rights over the personal data previously provided to us. Under the UCPA, consumers have the right to (1) know or confirm processing activity; (2) access their personal data; (3) obtain a copy of their personal data in a portable and readily usable format; (4) ability to request for deletion of personal data; (5) opt out of targeted advertising and sales of personal information; and (6) avoid discrimination as a result of exercising consumer rights under the UCPA. To exercise your rights as described above, please contact us at support@investifi.co.

VIRGINIA CONSUMER DATA PROTECTION ACT (VCDPA)

The Virginia Consumer Data Protection Act (VCDPA), effective January 1, 2023, provides Virginia consumers with rights related to their personal data. Under the VCDPA, these rights include (1) the right to know, access, and confirm personal data; (2) your right to request deletion of your personal data; (3) your right to correct inaccuracies of your personal data; (4) the right to portability (obtain a copy of your personal data in a portable format); (5) the right to opt out of processing of personal data for targeted advertising purposes; (6) your right to opt out of sale of your personal data; (7) your right to opt out of profiling based on your personal data; and (8) your right not to be discriminated against for exercising our consumer rights under the VCDPA. To exercise your rights described above, please contact us at support@investifi.co. 

Retention Period

We will only retain personal information for as long as necessary to fulfill the purposes for which your personal information was collected, including but not limited to the purpose of satisfying any legal, accounting, recordkeeping or reporting obligations or resolving disputes. We may retain personal information for accounting, contractual obligations with Financial Institutions, and security purposes even after our business relationship has ceased. At a minimum, our data retention policy is five (5) years.

Privacy Policy Changes

We may amend our Privacy Policy as we deem necessary. Our policy is to post changes made with notice the policy has been updated on the Platform. If we make material changes to how we treat users’ personal information, these changes will be communicated through a notice on the Platform. The date the Privacy Policy was last revised is at the top of the page. We encourage review of this Privacy Policy frequently to be informed of how we are protecting your nonpublic personal information. The amended Privacy Policy will be deemed effective immediately upon posting on the Platform.

For questions and comments about privacy rights, email us at support@investifi.co or contact us by mail or telephone:

InvestiFi Inc.

8 The Green, Suite 7529

Dover, DE 19901

Telephone: 888-526-2149 Opt. 2