Privacy

Last updated: 16 March 2022

GoodFin, Inc. is a financial technology company, not a bank. Banking services will be offered by our partner banks.

Nothing on this website is, nor should it be construed as, an offer, invitation or recommendation in respect of any securities, or an offer, invitation or recommendation to sell, or a solicitation of an offer to buy, any securities in any jurisdiction. Nothing on this website is intended to be relied upon as advice to investors or potential investors and does not take in account the investment objectives, financial situation or needs of any investor. All investors should consider such factors in consultation with a professional advisor of their choosing when deciding if an investment is appropriate.

Prospective investors will be expected to have conducted their own due diligence investigation regarding all matters pertinent to any investment opportunities set forth on the GoodFin, Inc. website.

All investment involves risk and the possibility of loss, including loss of principal, and past performance is not indicative of future results. They are suitable only for investors able to bear the economic risk of such investment indefinitely.

How We Use the Information We Collect

We collect this information from or about you in order to:

- provide you and other customers with access to the products and services offered through the Site;

- improve our insights so we can tailor our content and advertising, and provide you with offer recommendations and/or insights that are most relevant to you;

- provide notices and other information to you about, or in connection with, these products and services;

- provide customer support;

- detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, fulfill legal requirements and enforce our agreements;

- debug to identify and repair errors that impair existing intended functionality;

- provide, maintain, develop and improve our services, your experience, and to protect GoodFin and its users; and

- improve your experience accessing the products and services offered through the Site by recognizing you as a customer and remembering information you previously provided so that you will not have to re-enter it.

What Information We Share

All financial companies need to share customers’ personal information to run their everyday business. Subject to any applicable legal exemptions including the Gramm-Leach Bliley Act, and/or the California Consumer Privacy Act, we may share your personal information, including non-public personal information with:

- Service providers who help with parts of our business operations such as fraud prevention, servicing, bill collection, financial modeling, marketing and technology services, product development, and nonaffiliated financial institutions that we partner with to market or provide the products or services to you;

- Credit reporting agencies to report account information, at your direction and otherwise as permitted by law;

- Third-party investors or companies that purchase your contract or interests therein;

- Companies that we plan to merge with or be acquired by, or companies we plan to sell, divest or transfer all or a portion of our products and/or services to, including any back-up service provider or back-up administrator we engage in the event we stop operating;

- Law enforcement, government officials, or other third parties when (1) we are compelled to do so by a subpoena, court order or similar legal procedure, (2) we need to do so to comply with law, or (3) if we believe in good faith that the disclosure of your personal information is necessary to prevent physical harm or financial loss or to report suspected illegal activity; and

- Other third parties if you consent or direct us to do so.

As the servicer of your contract, we will also share information we obtain in that capacity, including about your repayments.

GoodFin will not sell or rent any of your personal information to third parties and only shares your personal information with third parties as described above.

Information that has been deidentified so that it does not identify a specific user is not considered personal information.

Federal and state laws allow you to restrict the sharing of your personal information in certain instances such as sharing your information so that third parties can market to you. However, because we will not share your information in these instances without your express consent, there is no need for you to opt-out from the information we share.

How We Protect Your Information

We care about the security of your information and take reasonable measures designed to protect your personal information from unauthorized access and use by maintaining physical, electronic and procedural safeguards in compliance with applicable law. These measures include computer safeguards and secured files and buildings.

You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from us at all times. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information may not be accessed, disclosed, altered or destroyed.

In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Links to or from Other Websites and Services

We are not responsible for the practices employed by any third party, or websites or services linked to or from the Site, including any information or content they contain. Please remember that when you use a link from a third party to visit our Site, or use a link to go from the Site to another website, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on the Site, are subject to that third party’s own rules and policies, including their terms and conditions and privacy practices. In addition, you agree that we are not responsible and we do not have control over any third-parties that you authorize to access your user content. If you are using a third-party website or service and you allow such a third-party access to your user content, you do so at your own risk.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as users. The Site and its content are not directed at children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will delete that information promptly. If you believe that we might have any information from a child under 13, please contact us at [email protected].

Changes to Our Privacy Policy

We may amend this policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. The revised version will be effective at the time we post it. If we make a material change we will notify you of the changes by posting a Policy Update and update the ‘last modified’ date at the bottom of this page.

How You Can Contact Us

If you have questions or concerns regarding this policy, you should contact us by emailing us at [email protected], or by writing to us via regular mail at GoodFin, Inc., 1223 Wilshire Blvd. #106, Santa Monica, CA 90403.