GoodFin, Inc. and its affiliates (collectively, "Goodfin", "we", "us", "our") are committed to your privacy and security online. This policy describes the ways we collect, use, share and protect your personal information in connection with your use of www.goodfin.com, www.goodfin.co, and any subdomains (collectively, the “Site”) and the products and services offered on the Site by Goodfin and other third parties that Goodfin has partnered with.

By accessing, using our service, or registering on the Site, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

Our Services

Goodfin collects, uses, stores and shares your personal information (as defined below) in connection with its products and services. We reserve the right in our sole discretion to make changes to how we operate and provide our services, including adding new services, modifying existing services, or suspending, discontinuing, or terminating your access to any or all portions of our services.

What Is “Personal Information?”

As used in this Privacy Policy, “personal information” refers to any information that can be used to identify you as an individual. Information that has been deidentified so that it does not identify a specific user is not considered personal information.

How We Collect Personal Information

Goodfin collects personal information in a variety of ways. For example, we may store the personal information you provide in relation to signing up for the Site, subscribing to a given investment opportunity on the Site, or sending Goodfin’s proprietary AI a message.

What Information We Collect

The types of personal information we collect depends on the products and services you use. The information may include:

• Your name, address, phone number, email, date of birth, social security number and documents or other media that verifies your identity such as your driver’s license, passport and video calls you make at our request;

• Information such as your investment history on our Site or what you disclose about your investments more generally;

• Information about your Goodfin account and your payment history;

• Information we receive from third party data partners for verification purposes including to verify your identity and other information you may provide us, such as income, and to manage risk;

• Information about you in your social media profiles, including your education, such as your degree, your college, and your major(s);

• Your bank information such as your bank, your account numbers, bank account credentials, and transaction information;

• Information about your employer, current income, assets and certain expenses, including with respect to your current employment;

• Information about your computer, mobile phone or other access device and anonymous information about your web request, Internet Protocol (“IP”) address, geolocation data, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Site, domain names, landing pages, pages viewed, your use of third-party applications, and other information that assists us in analyzing and improving our products and services.

• Any other information that you provide to us.

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;

• Managers of investments of underlying funds or companies, only as needed and to the extent required to comply with regulatory or contractual requirements;

• 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.

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. 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.

Data Retention

The personal information that we collect will typically only be stored for as long as it requires to fulfill the purposes for which it was collected. However, certain circumstances may require us to retain your personal information for longer periods of time.

Your personal information will be deleted or deidentified once it is no longer needed. If deletion or deidentification is not possible, then we will ensure that your personal information is safely secured and isolated from further processing.

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.

Your Choices

If any of the personal information that we collect is inaccurate, you have the ability to correct, update, or ask us to delete it by contacting us as set forth below. We will use commercially reasonable efforts to update your information as quickly as possible. However, it may not be possible for us to update certain information that we have collected, and we may need to retain outdated information for regulatory reasons.

You may also choose whether to receive and/or continue receiving marketing communications from Goodfin by choosing to “unsubscribe” to them. Please note that there are certain communications, such as transaction-related communications, that cannot be opted out of.

Additionally, you are able to manage the cookies used by your web browser. If you wish to remove or reject cookies, follow the instructions in your browser settings. To opt out of cookies, you must do so on each device you use. Please note that disabling cookies on your web browser may impact your ability to use Goodfin’s Site and services.

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 privacy@goodfin.com.

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 updating the “last modified” date at the top 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 privacy@goodfin.com, or by writing to us via regular mail at GoodFin, Inc., 1223 Wilshire Blvd. #106, Santa Monica, CA 90403.