This Privacy Notice describes the policy by which Eyeballs Financial, LLC and its affiliates (collectively “Eyeballs”) will collect and process your personal information through the Eyeballs websites, devices, products, services, and smartphone or tablet applications (the “App”) that reference this Privacy Notice (together “Services”). By using the Services, you are consenting to the practices described in this Privacy Notice.

What Personal Information About Customers Does Eyeballs Collect?

We collect your personal information in order to provide and continually improve our products and services. We receive information about your financial accounts in the following manners:

• • • Information You Give Us:We receive and store any information you provide in relation to Services.
    • Information from Other Sources:We also receive information about you from other sources, such as account custodians, investment product sponsors/issues, data aggregators, or your financial advisor. We will only receive data from other sources when authorized by you. See the Eyeballs End License User Agreement for more information on how and when we collect data.

For What Purposes Does Eyeballs Use Your Personal Information?

We use your personal information to operate, provide, develop, and improve the Services. These purposes include:

• • • Recommendations and personalization.We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with Services. Information provided may also be shared with your financial advisor to facilitate the services provided by your financial advisor. This information may include without limitation your inquiries about account holdings, balances, or other information provided through the Services.
    • Provide voiceservices.When you use our voiceservices, we use your voice input, and other personal information to respond to your requests, provide the requested response to you, and to improve our services.

Examples of Information Collected

The types of personal information we collect depends on the Services requested or provided. We only collect information about you as authorized by you.  We collect information when you give it to us, or when you give us permission to obtain it (such as when you give us permission to access your financial resources that contain your personal information, including but not limited to, your account custodian, another technology service provider, or other data sources or websites with that information)

Personal Information – We may collect personal information that generally falls within one or more of the following categories:

• • Identifiers— real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, e-mail address, account name, telephone number, signature, or other similar identifier.
  • Financial and Transactional Information—financial information about you such as custodial or bank account number, transactional information, and account holdings . and account authentication details.
  • Protected Classifications—age, citizenship, marital status, or sex/gender
  • Investment Information—investment information, financial goals, assets, and income information
  • Geolocation Data—information regarding your physical location
  • Communications—audio, electronic, visual, or similar information when you communicate with us via phone, video, or otherwise, or when you use the Eyeballs voice activated app on your smartphone or tablet.
  • Professional or Employment Information—current or previous job history, or information about your business or profession
  • Household Information—household age, income, persons in household, and other information which could be linked to a consumer, household or your financial accounts.
  • Inferences—information reflecting your preferences
  • Publicly Available Information—information that is in public records or otherwise made publicly available
  • Technical Information – We also collect information regarding how you interact with our system or our Services, which information may include questions submitted to the Eyeballs App, the pages you view, links you click or hover over, selections you make on websites, features you use, preferences you set, the internet protocol (IP) address of the device you are using to access the Services (or any portion thereof), computer browser type, and average time spent on certain pages

Cookies

To enable our systems to recognize your browser or device and to provide and improve Services, we use “cookies” and other identifiers. Cookies are small files used by websites to store information on your computer that provide technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our website. Eyeballs cookies contain information that identifies you duringa session and allows the web page or app to function, to facilitate site navigation, and to personalize your experience.

Cookies are used to:

• • Recognize you when you sign-in to use our Services.
  • Keeping track of your specified preferences
  • Conducting research and diagnostics to improve Eyeballs’ content, products, and services.
  • Preventing fraudulent activity.
  • Improving security.
  • Reporting. This allows us to measure and analyze the performance of our services.

Does Eyeballs Share Your Personal Information?

Information about our customers is an important part of our business, and we are not in the business of selling our customers’ personal information to others. We share customers’ personal information only as described below.

• • • Third-Party Service Providers:We employ other companies, vendors, and individuals (“third-party services providers”) to perform functions on our behalf. Examples include analyzing data,and developing and maintaining the Eyeballs website and app. These third-party service providers have access to personal information needed to perform their functions but may not use it for other purposes.
    • Protection of Eyeballs and Others:We release account and other personal information when we believe release is appropriate to comply with the law.
    • Anonymized Date: Eyeballs may use your data to provide or create other products or services. When using your data, Eyeballs will “anonymize” the data so that any information specific to you or your account is removed and cannot be associated back to you.

Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

How Secure Is Information About Me?

• • • We work to protect the security of your personal information during transmission by using encryption protocols and software.
    • We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of data. Our security procedures mean that we may ask to verify your identity before we disclose personal information to you.
    • Our devices offer security features to protect them against unauthorized access and loss of data.
    • It is important for you to protect against unauthorized access to your password and to your computers, devices, and applications.

What Information Can I Access?

You can access your information, including your name, address, account information, profile information, and household settings (accounts associated with your use of the App) in the profile setting of the App.

Are Children Allowed to Use Services?

Our Services are not intended for use by children.  Except as provided by you when using the App or receiving services relevant to a child’s account, we do not collect personal information from or about children.

How long is my information kept?

We retain your information in our server logs, our databases, and our records for as long as necessary to provide the Services. We may need to retain some of your information for a longer period, such as in order to comply with our legal or regulatory obligations, to resolve disputes or defend against legal claims, or to enforce our End User License Agreement.

California Consumer Privacy Act

Notice to California Residents

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know, access, delete, and limit sharing of Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.  Due to the nature of our Services, much of the information we collect is exempt from the CCPA because it is covered by federal or state financial and/or data privacy laws.

To the extent that we collect Personal Information that is subject to the CCPA, your rights as a California resident to request access and deletion of that information are as described in this Policy and as further set forth below.

We do not sell Personal Information. However, as described in this Privacy Policy, we may share Personal Information with a third party as directed or consented to by you or your financial advisor as necessary for you to receive the benefit of such third party’s services.

As a California resident, you have the following rights listed below. However, these rights are not absolute, and in certain cases we may decline your request or comply with it in a more limited way than you anticipated, as permitted by law.

You may request the following information about how we have collected and used your Personal Information during the past 12 months:

• • Categories of Personal Information we have collected
  • Categories of sources from which we collected Personal Information
  • The business or commercial purposes for collecting Personal Information
  • Categories of third parties with whom we share Personal Information
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient
  • You may request a copy of the Personal Information that we have collected about you during the past 12 months.
  • You may request in certain circumstances that we delete Personal Information that we have collected directly from you.
  • If we change our current policy and later decide to sell your Personal Information, you will have the right to opt-out prior to any such sale.
  • You are entitled to exercise the rights described above free from discrimination.

In order to process a request to know about or delete Personal Information we collect or disclose, we must verify your request.  We reserve the right to confirm your California residency to process your requests and will need to verify your identity to process your requests.

Conditions of Use, Notices, and Revisions

If you choose to use our Services, your use and any dispute over privacy is subject to this Notice and our End User Licensing Agreement. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.

For questions about this policy or the Services provided, please contact us at [email protected].