Privacy Policy

FinChirp privacy policy

This privacy policy describes FinChirp’s collection, use and sharing of personal information. As used in this privacy policy, "FinChirp" refers to FinChirp Inc that offer products and services available through this website and mobile applications where this policy appears. FinChirp ("we") may offer products, services and digital offerings that may have different or additional privacy policies made available to you if you choose to use those products, services or digital offerings. Some products and services available on our digital properties may have supplemental privacy policies that pertain to those products and services.

As used in this privacy policy ("policy"), personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy.

This policy is reviewed annually and updated to reflect any changes.

How and why we obtain and use personal information

FinChirp recognizes the importance of maintaining personal information about you and when we use it, we do so with respect for your privacy. We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; operate and manage our business; and fulfill legal and regulatory requirements.

We collect public and non-public personal information from customers and visitors from various sources. Some examples include:

• You or your representative on applications or forms (for example, when you visit our websites or use our applications).
• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our websites).
• Other interactions with FinChirp (for example, discussions with our customer service staff, including telephone or chat, information you enter into our websites, or when you enroll in our authentication services).
• Information from other third-party sources (for example, to verify your identity and to better understand your product and service needs).

Information by which you cannot be identified (for example, anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.

How we protect information about you

We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology. At FinChirp, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you and to operate our business.

How we share information about you with third parties

FinChirp does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at FinChirp's direction).
• Government agencies, other regulatory bodies and law enforcement officials as required by law.
• Other third parties whose products, services and investment offerings are made available through FinChirp, and which you decide to utilize.
• Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena).
• In connection with corporate business transactions, such as a merger or sale of a business.

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by FinChirp. In addition, if you choose to use or indicate your interest in using a product, service or investment offering that is offered by a third party and made available through FinChirp, we may share personal information with that third party in connection with your use or interest of that product, service or investment offering.

How we provide information about you to our affiliates

We may provide personal information about you to various FinChirp corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services or for other business purposes. If you interact with FinChirp directly as an individual investor (including joint account holders), we may provide certain information about you to FinChirp affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Where FinChirp provides services to you under an arrangement with your employer or plan sponsor, to the extent permitted by you or under our agreement with your employer or plan sponsor and as allowed by law, we may provide information about you to FinChirp's affiliates, such as our brokerage and insurance companies, for their use in marketing products and services.

Information collected from investment professionals' customers is not provided to FinChirp affiliates for marketing purposes, except with your or your representatives' consent and as allowed by law.

Your digital privacy

When you interact with us by using our websites, online services or applications (including mobile apps) that are owned and controlled by FinChirp ("our digital offerings"), or via electronic communications, FinChirp manages personal information in accordance with all of the practices and safeguards described in this policy.

When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical, and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience.

Cookies and similar technologies

FinChirp and our third-party service providers may use cookies and similar technologies ("cookies") to support the operation of and maintain our digital offerings. Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. FinChirp cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings, to improve the effectiveness of our online advertising and to understand more about the demographics of our users. You can learn more about Google's practices by visiting their privacy policy and opt‑out resources.

Advertising on and off FinChirp digital offerings

We may use information about your relationship with us to tailor advertisements and communications about FinChirp and third‑party products and services that may be of interest to you. We also advertise on digital offerings not affiliated with FinChirp using third‑party advertising companies that may use cookies or similar technologies to measure campaign effectiveness and deliver interest‑based advertisements.

Connecting via social platforms

We collect information you provide when you interact with us via social media (e.g., photographs, opinions, or social media account ID). Content you post is subject to the terms and privacy policies of those platforms.

Third‑party websites and embedded content

Our digital offerings may contain links to third‑party websites and online services and may include embedded content hosted by third parties. This policy does not address the privacy, security, or cookie practices of those third parties.

Children's privacy

In general, FinChirp's digital offerings are not directed to individuals under the age of thirteen (13). We do not intentionally collect information from those we know are under 13, and we request that these individuals do not provide personal information through our digital offerings. If we provide a digital offering intended for individuals under 13, it will have a separate privacy policy.

Additional information

If you are a former customer, this policy also applies to you; we treat your information with the same care as we do information about current customers. FinChirp offers several options for accessing and, if necessary, correcting your account information. You may also write or call us with your request for information. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

Additional Information for California Residents

This section is provided for purposes related to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA") and applies solely to the personal information and FinChirp companies that are subject to the CCPA.

Your Rights Under the CCPA

• Right to Know/Access – request categories and specific pieces of personal information collected, sources, purposes, and third parties to whom information is disclosed.
• Right to Delete – request deletion of personal information collected from you, subject to certain exceptions.
• Right to Correct – request correction of inaccurate personal information.
• Right to Opt‑Out of Sale/Sharing – opt out if personal information is sold or shared for cross‑context behavioral advertising.
• Right to Limit Use and Disclosure of Sensitive Personal Information – where applicable.
• Non‑Discrimination – no discriminatory treatment for exercising your rights.

Categories of personal information we may collect

Depending on your relationship with us, we may collect identifiers, records information, commercial information, protected classification characteristics, biometric information, internet/network activity, geolocation data, audio/electronic/visual data, professional or employment information, education information, inferences drawn from other data, and sensitive personal information (e.g., account log‑in credentials).

Submitting a CCPA request

If you wish to submit a CCPA request, contact us via the methods provided in your statements or correspondence. We will verify your identity before processing your request and respond within the timeframes permitted by law.