Effex.io Privacy Statement

Last Updated: January 13, 2021

Scope of this Privacy Statement and our role

As a services technology company, we’re providing this Privacy Statement (which we’ll refer to as “Privacy Statement”) to explain how we collect, use, and share information when you interact with us and our offerings, services and experiences. This Privacy Statement is global in nature, meaning that it is applicable to all websites and offerings at Effex.io Inc., and it describes our privacy practices when we process:

a) Personal information for the purposes of providing the benefits of the Effex.io platform, which is collectively, all of Effex.io’ services, sites, experiences and software (including through our mobile applications) by Effex.io Inc. and its affiliates and subsidiaries (the “Effex.io Platform”); and/or

c) Personal information as necessary to manage, run and improve our business.

Effex.io Inc. determines the purposes and means of the processing of personal information (“Information Controller”). Effex.io Inc. may share your personal data with other affiliate companies to process as joint controllers for the purposes set out in this Privacy Statement. If you have any questions about the processing of your personal data, please contact us in the section “How to Contact Us” below.

This Privacy Statement does not apply where Effex.io processes personal information as a service provider on behalf of a customer or entity who acts as the Information Controller, for example, the customers of our communications partner. When we act as a service provider, the privacy statement of the relevant Information Controller and our agreements with such business or entity will govern our processing of personal information.

In certain circumstances, there may be more than one Information Controller processing your information. For example, your employer or a financial partner may also act as an Information Controller. In these situations, we act as an independent Information Controller over our processing activities – meaning that we make determinations over how your personal information will be processed independently from the other Information Controller. The other Information Controller may have their own obligations under

applicable information privacy law, and you may need to speak with the other Information Controller directly for questions on how they process your personal information.

The Effex.io Platform

The Effex.io Platform and your information

When we say “platform” we mean that when you choose to share data with us, or bring over information from third parties (like a bank), we use that data together, not just within the individual offering(s) you’re using.

The personal information we use in this centralized way is all the information that Effex.io knows about you. It includes your credentials; your name and contact details; payment information; information about your activities, your interests and preferences; insights about your finances or your business; the content you place in our Platform; and information we have collected about you from third-party sources.

Information we collect

Information we receive from you

The personal information that we receive about you depends on the context of your interactions with Effex.io, how you configure your account and the choices that you make, including your privacy settings. Personal information that you provide may also depend upon what services or experiences you use, your location and applicable law.

• Creating an account. We collect information when you create an account, interact with the Effex.io Platform or activate a subscription. Personal information may include your contact information (such as your name, address, phone number and email), profile photo, billing information (your payment information), usernames and credentials.
• Identification information. We collect information to verify your identity, including your name, phone number, email address and physical address along with other personally identifiable information.
• Customer support, product research, training and feedback. We may collect personal information when you reach out to us for support, give us feedback, participate in optional surveys, product research or training and you choose to share.
• Social and community content. We receive content you post on our social media pages and our community pages.
• Device information. We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
• We may receive information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers or vendors or employees, income and wage information, and/or investment information.
• Third-party service content. We receive information about you when you sign into a third-party service with your account or when you connect your account to a third-party service.
• Usage information. We may collect usage information such as the pages you viewed, the features you use, your browser type and details about any links with which you interact.
• Location information. Certain features in the Effex.io Platform may collect your precise location information, device motion information, or both, if you grant permission to do so in your device settings.
• Expert advice. The Effex.io Platform provides many opportunities for you to connect with live experts, including, for example, accountants or tax preparers. When you interact with these experts, we may receive information about the questions you ask, the details of your accounts and the guidance provided to you.
• Camera and contacts. Certain features may have access to your camera and contacts if you grant permission in your device settings.
• Information from cookies and other technologies. io and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experience. You have control over some of the information we collect from Cookies and how we use it.
• Information stored locally. Some of our web-enabled desktop services and offerings synchronize with the information on your computer. In doing so, we may collect information such as device information, product usage, and error reports. We may also store personal information locally on your device.

Information provided by others

Our platform is designed to help you connect with other people and organizations. As a result of those connections, others may be able to input information about you. For example, your employer may input information about your salary and work activity in order to process their payroll. You may also be able to input or process information about others, for example, if you are an account administrator. If you input information about others into our platform, you must only do so if you have first received the appropriate rights and permissions to do so, including by getting advanced written consent, if required by applicable law.

Other information sources

We may also get information about you from others where permitted by applicable law. We protect and process information obtained from those parties as described in this Privacy Statement, consistent with any additional restrictions imposed by the source of the information. Our sources may vary over time and depend upon how you use the Effex.io

Platform. For example, we receive information from:

• Supplemental information and identity verification providers. Service providers who help us verify your identity, the specifics of your business and/or supplement the information you have provided and ensure the accuracy of your information. For example, we use third-party service providers to validate your mailing address, phone number or provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider or email provider.
• Customer Support providers. Service providers who provide us with information about you or your interaction with the Effex.io Platform for troubleshooting purposes. For example, we may obtain support information or technical issues you have raised with these third parties.
• Risk management, cybersecurity & anti-fraud providers. We may receive information from service providers who help us assess risks associated with our offerings, including to help combat fraud, illegal activity and to help protect your personal information.
• Content providers. We may receive information from software providers that make user-generated content from their service available to others, such as local business reviews or public social media posts.
• Communication providers & social networks. If you give us permission, we may collect information from email providers, communication providers and social networks.
• Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
• Publicly-available sources. We collect information from publicly available sources, such as open government databases.
• Government agencies. We receive information from government agencies, including from various tax agencies.
• Required information. Some services and experiences in the Effex.io Platform require you to provide information for it to function. If you do not wish to provide the required information, you may not be able to use certain features.

How we use personal information

We collect and process personal information from you only where:

• We have your consent to do so;
• We need the personal information to perform a contract with you or provide a

service to you;

• Provide you with the benefits of the Effex.io Platform and operate our business;
• The processing is in our legitimate business interests in those jurisdictions where legitimate business interest is a legitimate basis for processing; or
• We need to comply with legal requirements, including applicable laws and regulations.

Personal information is used to operate our business for the following purposes that are required to originate and maintain our relationship with you, including but not limited to:

• Provide you with the Effex.io Platform and create your account
• Improve our products and services
• Run and manage our business, including resolving billing and financial disputes
• Evaluate your eligibility for financial offers, products and services
• Provide features to you, such as your free credit reports and scores
• Connect you with experts and other users
• Communicate with you, such as sending you electronic notifications concerning your financial privacy
• Advertise and market our services and experiences
• Personalize your experience and tailor recommendations and offers presented to

you, including through the development of insights about you and your needs

• Provide you with support and resolve disputes
• Conduct research, including by partnering with academic institutions
• Comply with our legal and regulatory requirements
• Authenticate your identity, including through the use of Biometric Data
• Protect the rights, property, safety or security of the Effex.io Platform, our

customers, employees or others and prevent fraudulent or illegal activity

• To exercise our rights in the course of judicial, administrative or arbitration proceedings
• To enforce, remedy or apply our Terms of Service or other agreements and/or
• For other purposes that are compatible with the disclosed purposes if and where

this is permitted by applicable law.

Automated Processing

To provide you with valuable personalized advice, recommendations and experiences, we may process your personal information using automated and manual (human) methods. Our automated methods include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience in the Effex.io Platform.

How we share your information

We may share your information in the following circumstances:

With your consent. Except for as outlined below, we only share your information with third parties when you have directed us to do so.

When you connect with an Effex.io Platform partner. You may be provided with offers, products, and services from third-party companies who integrate with our Effex.io Platform (“Platform Partner”). If you choose to interact with a Platform Partner, apply for their services or offerings or otherwise link or sync your account to a Platform Partner’s product or service, you consent and direct Effex.io to share your information, including personal information, to the Platform Partner providing the service or offering. For example, when we send your personal information to partners in order to generate offers for you to review, when we send your application information directly to our partners, or

when we send you to the partner’s site for you to provide the information directly to them.

In some cases, if you click through to go to a Platform Partner’s site, you will automatically be sending your personal information to that Platform Partner. When this happens, you will still have to submit your application on the Platform Partner’s site. Remember that any information you provide to a Platform Partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.

When you connect to your social media account. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Statement). You should take care only to share information on social media that you are comfortable sharing.

For research. With appropriate controls, we may share information with third-parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that would not allow any individual to be identified.

For joint features, sales, promotions and events. We may share your information with third-parties companies who are jointly providing features, sales initiatives, promotions or events with us.

With financial services providers. We may share personal Information with collection agencies, credit bureaus and loan service providers, and payment card association members. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.

When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include personal information, such as your name or user name. Anything you share in a public forum is public, and you should think carefully before you decide to share.

With service providers or agents. We share personal information with our service

providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Statement. Service providers or agents may include companies that assist us with our advertising, marketing and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business.

For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.

No sale of personal information to third parties. We do not and will not sell personal information to third parties. We do share personal information with third parties for the business purposes described in this Statement.

With our affiliates and subsidiaries and your right to limit information sharing. We may share your information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes. Certain laws may provide you with the right to limit our information sharing activities in certain circumstances.

Cookies and other tracking technologies. You can find information on changing your browser settings to opt-out of cookies in your browser settings. In certain countries, you may also be able to make changes to your cookies settings by using our cookie preferences tool. If you disable some or all of the cookies the service, or parts of the service may not work.

For advertising and analytics. Effex.io may use advertising networks and other providers to display advertising on our Effex.io Platform or to manage our advertising on other sites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements.

The Effex.io Platform is not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted.

For legal reasons. We may share your information with third-parties for legal reasons without your consent, and as permitted by law, including:

• When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process
• To protect the rights, property, or safety of Effex.io and our customers or others
• To protect or defend against attacks
• To enforce, remedy, or apply our Terms of Service or other agreements
• To prevent fraud, cybersecurity attacks or illegal activity
• For debt collection
• With regulatory agencies, including government tax agencies, as necessary to help detect and combat fraud and/or protect our customers, users and/or the Effex.io Platform, or in required institutional risk control programs.

Your information rights and choices

Your rights

At Effex.io, we believe that you have rights to information that pertains to you, your household and/or your business. If another person has input or processed information in the Effex.io Platform on behalf of you, your family or your business (and we are processing such information as an Information Controller), you may ask to receive a copy of your information, even if you do not have an account with us.

Depending on where you live, you may have certain state- or nation-specific rights with respect to your personal information that we collect and process.

• Verification

To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to us exercising your data rights. If we are unable to verify your identity or ownership rights to the data, we may not be able to provide you with data rights until you are able to provide us with proper documents.

• Information retention

Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of the Effex.io Platform. However, even if you request a deletion, we may be required to maintain your information for as long as necessary to:

1) comply with our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us);
2) to exercise, establish or defend legal claims; and/or
3) to protect against fraudulent or abusive activity on our service.

This means we may keep different information for different periods. If your account is canceled because you’ve not used it in a long time, we may delete this information straight away.

There may be occasions where we are unable to fully delete, anonymize, or de- identify your information due to technical, legal, regulatory compliance or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

• International data transfers

You agree and Effex.io reserves the right to store and process your personal information in the United States and in any other country where Effex.io or its affiliates, subsidiaries, or service providers operate facilities in accordance with and as permitted by applicable laws and regulations. Some of these countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).

When we transfer, store or process personal information outside of your

jurisdiction, we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Statement and applicable law.

Security of your personal information

We use physical, technical and organizational safeguards designed to protect your information. However, despite these controls, we cannot completely ensure or warrant the security of your information.

Changes to our Privacy Statements

From time to time we may change or update our Privacy Statement. We reserve the right to make changes or updates at any time. If we make material changes to the way we process your personal information, we will notify you by posting a notice in our platform or on a community post; by sending you a notification; or by other means consistent with applicable law.

You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement. Please review this Privacy Statement periodically to stay informed about how Effex.io protects your privacy.

Collection and use of children’s personal information

Our services are not intended for or directed to children. We do not knowingly collect personal information from children. If you believe we may have information from a child, please contact us.

Correct your personal information. You can edit and correct your personal information at any time by changing it directly in our products and services.