Privacy Policy

Date Last Revised: July 15, 2017

This Privacy Policy describes how Pefin (“us”, “we”) our website Pefin.com (the “Site”),and services offered through the Site (the “Service”) ensures the privacy and security of your data. “Pefin” represents Pefin, Inc. and its subsidiaries and affiliates including Pefin Advisors, LLC and Pefin Technologies, Inc., who jointly adhere to these Privacy standards.

Given the sensitive, financial nature of the data you provide us, we understand you trust us to keep your information safe from theft and misuse and outof the hands of marketers, promotional agents, and anyone else you don’t authorize to access this information.

Here are the steps we take to ensure that happens.

The Information We Collect

The information we collect can be divided into the following categories:

User Provided Information: When you use the Service, you may provide and we may collect what is referred toas“personally identifiable” information. This includes data such asyour name, email address, and mailing address. You may also provide and we may collect demographic information such as your age, zip code, and marital status. This information isused to provide you with an account to use the Service and for enabling features of the Service tobe available to you.

Cookies and Tracking: Like many websites, we use technology, such as cookies, tags, and local shared objects that allow usto recognize you when you come to the Site andprovide a better experience. We may use third party service providers to help us understand how you are using the site and navigating through the site. This information enablesustoimprove the Service and create a better experience for you.

Financial Institution Aggregation: In order for you to benefit from the full functionality ofour Services, our Services request access to your financial institution (“FI”) account data, including transactions, balances, holdings, and other account information. We use one or more well-reputed third-party service provider to facilitate the collection of your FI account data from your FIs. Pefin doesnot store or have access to your financial institution account login information. You authorize usto access, retrieve and store your information on your behalf via the third-party aggregation service providers in the Service Agreements that you sign.

System Details: Like many web sites, we gather certain information about your computer and machine and store it. This information may include your IP address, browser type, andoperating system. We may combine this automatically collected information with other information about you. This information is primarily used for project planning and site improvements.

Mobile Device Information:: When you download and use our Services on a mobile device, we automatically collect information on the type of device you use, operating system version, and the device identifier (or "UDID").

We use mobile analytics software to allow usto better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and from where the application was downloaded.

To enable multi-factor authentication where we can verify your identity by sending you an SMS, we may collect and retain your mobile device number.

Our Site and Services are not intended for children under the age of18, or for anyone unable to legally form a binding contract. We do not knowingly collect personal information from these individuals.

Marketers Are Not Given Your Information

We do not sell, publish, or share your personal information to third parties for their marketing purposes. We may in the future aggregate information in clusters across large groups of individuals for purposes of improving our AI, as well as to facilitate partnerships to offer better AI analytics.

Pefin Employees Cannot Access Your Information

All user provided information and any FI data that uniquely identifies you such as last four digits of account numbers and account names, are encrypted and stored on our systems using military-grade encryption (AES 256 standard) using multiple encryption codes. No employee at Pefin can access your unencrypted personal information or your unencrypted financial account information without your explicit permission and only in cases where a customer support issue requires such permission.

For information on employee and infrastructure controls, please read our Security Policy.

We Limit the Use of Your Information

The information we collect is first and foremost used to provide the Service to you. This includes:

To provide you complete Services – We often partner with third parties to efficiently provide you services and may need to provide select personal information to these third parties, for the purposes of account opening, and/or identity verification, amongst others. Wewill share this information only as deemed necessary by us, in order to provide services that you request. For example, if you wish to open and investment account through Pefin Advisors, select information will be shared with Apex Clearing Corp, LLC, our custodian and Broker/Dealer.

To confirm your identity – As a firm, Pefin is required to ensure that you are, who you say you are. We are required to ensure, to the best ofour ability, that no-oneis accessing your information and transferring money without your authorization. This is a standard approach used by financial services, anditis required under Anti-Money Laundering (AML) policies and Know-Your-Client (KYC) regulations, andin accordance with the USA Patriot Act. Pefin also uses the services of Plaid as ACH provider.Please see Plaid’s Privacy Policy https://plaid.com/legal/#privacy-policy.In acknowledging the Pefin Advisors Privacy Policy, you are further acknowledging and agreeing that your information will be treated inaccordance with Plaid’s policy.

To Send You Content – Pefin may send you content such as articles, financial news, reports, etc. that provide pertinent and relevant information to you.

Regulators – We are obligated to provide regulators information about our clients in our regulated entities, as they request. We will do this only if required to do so, in order to comply with required regulations.

For Customer Support – In order to provide customer support to you, employees of Pefin may require access to your personal information with your explicit permission. Our systems and support process has multiple access controls which ensure that your information or identity is not compromised. Pefin reserves the right use third party support personnelto manage customer support. In this event, these third parties will be held to the same privacy standards as outlined in this document.

For Payment Processing – Pefin uses a third-party payment processing providers to process and manage your subscription payments and to transfer funds into and out of an investment account. These companies are authorized to use your personally identifiable information only as necessary to provide this service.

Co-Brands – In addition, we have business partners that provide our Services via a co-brand. We clearly identify co-branded services and sites. In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner.

Aggregate Data – We make certain automatically collected and other aggregate non-personally-identifiable information available to third parties to (i) comply with reporting obligations (ii) for business or marketing purposes (iii) to assist such parties in understanding Site and Service usage patterns.

Blogs and Social Media – Any information, including personally identifiable information that you voluntarily choose to make publically available, such as the comment area of a blog or other public forum on our Site, will be available to anyone who has access to that content. Our Site may include Social Media Features and Widgets such as the Facebook Like and Facebook Share button. Your interactions with these Features are governed by the privacy policy of the company providing it.

Law Enforcement – We reserve the right, at our sole discretion, to disclose your information if required to do so by law, to prevent illegal activities, or to enforce our rights against you or in connection with a breach by you of this Privacy Policy or the Terms of Use.

Company Restructuring – If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us. Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Sites and such third parties will assume the rights and obligations regarding such information as described in this Privacy Statement.

You Can Delete Your Data

You can delete your data anytime you want. If you request that we delete your account for the Service, your account data will be permanently deleted from our primary production servers and further access to your account will not be possible. We will also delete your account credentials as well as any connection to your financial institution accounts. However, aggregate data derived from your personal information that does not personally identify you may remain on our production servers indefinitely and we reserve the right to use such aggregated and anonymous data. Your data may also remain on a backup server or media. Like many companies, Pefin keeps these backups to ensure we can continue to provide the Service to you if an issue with our production servers should arise.

We may however have regulatory requirements to save certain data, as per the SEC regulations, and we will save information securely to meet these requirements. Furthermore, Pefin will save any personally identifiable data necessary to ensure we can monitor your ongoing compliance with the Non-Disclosure Agreement you signed as part of joining the Service.

Please note, if you delete your account, you will have to setup a new account with Pefin as if you were a new user. It is not possible to restore your account after it is deleted.

How We Protect Your Data

For information on how we protect your data, please review our Security Standards.

Feel free to Contact us if you have any questions or concerns.