END USER PRIVACY POLICY

Last modified: September 26, 2023

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES, DOWNLOAD, OR REGISTER AN ACCOUNT WITH THE APP (AS DEFINED BELOW). BY DOWNLOADING, REGISTERING WITH, OR USING THIS APP, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS SET OUT IN THIS PRIVACY POLICY, PLEASE DO NOT DOWNLOAD, ACCESS, OR USE THE APP, CHECK ANY OF THE BOXES IN CONNECTION WITH THIS PRIVACY POLICY. IN ORDER TO ACCESS AND USE THE APP YOU MUST BE AT LEAST EIGHTEEN (18) YEARS OLD.

Introduction:

Link Financial Wellness, LLC, ("Company", "we", "our", or "us") respect and is committed to protecting the privacy of users of our App ("User," "you," or "your").

This Privacy Policy describes:

  1. The type of information we may collect or that you may provide when you download, install, register an account with, access, or use our mobile application, Link (the "App").
  2. Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy does not apply to information that:

  1. we collect offline;
  2. we collect on any other of Company's apps or websites, including websites you may access through this App;
  3. you submit to us through email, text message or other electronic message;
  4. you provide to or is collected by any third party, including, but not limited to, any third party websites, applications or services that you may access through the App.

Our website and these other third parties may have their own privacy policies. Users and visitors who link to third party websites, applications and services from the App should check the privacy and security policy statements of such third party websites, applications and services, to understand the policies and practices of such third-party websites, applications and services, as we are not responsible for those policies and practices. If you disclose your information to third parties on the App or other websites on the internet, you do so at your own risk as different rules may apply to their use or disclosure of such information.

Users Under the Age of 18:

The App is not intended for persons under 18 years of age, and we do not knowingly collect Personal Information of persons under 18 years of age. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. If you believe we might have any information from or about a person under18, please contact us as described at the end of this Privacy Policy.

Information We Collect and How We Collect It:

We may collect information about you, that you provide, when you:

  1. create an account to use the App, we may collect contact and registration information, such as: your name, last four digits of your account number with your Financial Institution (as defined below), email address, username, password, and other profile information you upload to your account;
  2. access or use the App, such as: information you upload or provide, postal address, telephone number, Internet Protocol (IP) Address, account balance, descriptions of financial transactions, investment interests, budget names and amounts, information about associated persons (e.g., family, friends, children), and credentials to facilitate integrations with third party service providers (e.g., Plaid);
  3. provide any information in connection with your outreach if you contact us with questions, comments, or for customer service, such as: name, email, phone number, address and other information that you choose to provide during the outreach.

We may also collect information about you that your designated financial institutions and credit card providers ("Financial Institutions") provide to us, such as descriptions of your credit rating using generic descriptors (such as "excellent," "very good," "good," "fair," or "poor"). We will never share this information in any form with any third party. 

How We Share Your Information:

  1. Plaid: Our App offers account linking and aggregation services through Plaid, Inc. ("Plaid") with respect to your accounts with your Financial Institutions. By using our App to utilize Plaid's services, you acknowledge and agree that the terms of Plaid's Privacy Policy (located at https://plaid.com/legal/#end-user-privacy-policy) will govern Plaid's use of your information to provide Plaid's services, and you consent to Plaid's Privacy Policy. Additionally, you grant Plaid the right, power, and authority to act on your behalf to access and transmit your information to and from your Financial Institutions as reasonably necessary for Plaid to provide its services.

    By using our App to utilize Plaid's services, you agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with Plaid's Privacy Policy.

    When you use third-party services (like when you connect your account on the App with your bank account) or websites that are linked through our services, the providers of those services or products may receive information about you that the Company, you, or others share with them. Please note that when you use third-party services or our affiliate services which are not governed by this Privacy Policy, their own terms of uses and privacy policies will govern your use of those services and products.
  1. Service Providers: We may share information with select third parties who provide services to us, such as customer service, interfacing with Financial Institutions, analytics, website management, app management, information technology and other similar services.
  1. Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose your information as we believe to be necessary or appropriate to: comply with applicable law and legal processes; respond to requests from public and government authorities, including public and government authorities outside your country of residence; enforce our Terms of Use located at: ("Terms of Use"); protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and allow us to pursue available remedies or limit the damages that we may sustain.
  1. Corporate Transactions. We reserve the right to transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
  1. With Your Consent or At Your Direction. We may share information with third parties when you direct us to do so or if you have consented to additional sharing of your information (including as set out in this Privacy Policy).

How We Use Your Information:

We use your information in a variety of ways to provide the App. We may use your information to:

  1. provide you with the App and its contents, and any other information, products, or services you request;
  2. provide you with effective customer services;
  3. personalize your experience and our communications with you;
  4. Customize the information and services provided by the App to you and your circumstances;
  5. engage in transactions with you, including contacting you about your account;
  6. contact you with operational information and notices related to your use of the App;
  7. invite you to participate in surveys and provide feedback to us;
  8. analyze use of the Services and improve the content, functionality and usability of the App;
  9. secure the App and investigate and help prevent fraud, security issues, and abuses;
  10. fulfill any other purpose for which you provide it;
  11. comply with procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others;
  12. establish, exercise, or defend our legal rights where necessary for our legitimate interests or the legitimate interests of others, including the enforcement of our Terms of Use, other usage policies, and other legal terms or controls, or to engage in other legal matters;
  13. understand and resolve app crashes and other issues being reported;
  14. notify you when App updates are available, and of changes to any products or services we offer or provide through it; and
  15. for any other purpose with your consent.

We do not sell, rent, or trade any personal information that you provide to us through your use of our App or electronic forms. We do not use the information you provide to make any automated decisions that might affect you.

COOKIES

A cookie is a small file placed on your computer, tablet, mobile device or web browser. Web Beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files that can be included on webpages or emails.

We do not use any cookies or web beacons on the App.

Notice to Nevada Residents:

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to info@linkfinancialwellness.com. However, please know that we do not currently sell data triggering that statute's opt-out requirements.

Do Not Track:

We do not track customers over time and across third party websites or apps to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.

Data Storage and Retention:

We will retain your information for as long as your account is active or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect us and our users, and enforce our agreements.

Disclosure of Your Information:

We may disclose aggregated information about our users, without restriction.

In addition, we may disclose Personal Information that we collect or you provide:

  1. to our subsidiaries and affiliates;
  2. to contractors, service providers, and other third parties we use to support our business;
  3. to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about out App users is among the assets transferred;
  4. to fulfill the purpose for which you provide it;
  5. for any other purpose disclosed by us when you provide the information;
  6. with your consent;
  7. to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  8. to enforce our rights arising from any contracts entered into between you and us; and
  9. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data Security:

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. When you create an account, you will be prompted to create a username and password. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password. Where we have given you (or you have chosen) a password for access to our App, you are responsible for keeping this password confidential. If you create an account with us, you are responsible for any activity that occurs under your account. We ask you not to share your password with anyone. If you have reason to believe that your account is no longer secure or believe it is being used by an unauthorized party, you will inform us immediately and comply with any instructions or requests we provide.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Third Party Links and Features:

The App may contain links, banners, or widgets to third-party sites, apps, services, and plug-ins, including Financial Institutions. We may also incorporate third-party software (including open source software) in the App.

These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators. We are not responsible for the practices of such third parties. Any information you provide to third parties on their websites or services is covered under their privacy and data collection policies, and is not covered by this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

Changes to Our Privacy Policy:

We reserve the right to modify, amend or cancel this Privacy Policy from time to time, consistent with applicable data privacy laws. Any changes to this Privacy Policy will be posted here. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically viewing this Privacy Policy to check for any changes. Your use of the App following any such change constitutes your agreement that all information collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy.

Contact Information:

To ask questions or comments about this Privacy Policy and our privacy practices, contact us at:

info@linkfinancialwellness.com

ND:4887-0823-4087, v. 8