1. Introduction

This Privacy Policy describes how All of Us collects and uses Personal Data about you through the use of our Website and through email, text, and other electronic communications between you and All of Us.

All of Us Financial Inc. (“All of Us” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit www.allofusfinancial.com (the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Our Website permits you to interact with other members of the investment community who also use our Website and its features, including to access and trade using your All of Us Securities brokerage account.

This policy applies to information we collect:

on our Website; and
in email, text, and other electronic messages between you and our Website.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by All of Us or any third-party (including our affiliates and subsidiaries);
your brokerage account with All of Us Securities; or
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

The All of Us Financial Inc. partners with All of Us Securities LLC, an independent registered brokerage firm in the United States, to provide you with the brokerage functionality accessed through our Website, including any trading of securities you may perform through our Website. All of Us Securities is responsible for providing you with certain notices of its privacy practices describing its collection and use of your non-public financial information. Your use of the Website is also governed by the All of Us Master Customer Agreement and the All of Us Securities Customer Agreement. If you do not agree to be bound by those terms, you are not authorized to access and use our Website, and you must promptly exit our Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices (including those in the All of Us Master Customer Agreement and the All of Us Securities Customer Agreement), your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy, and by registering for an account on this Website, you also agree to the All of Us Master Customer Agreement and the All of Us Securities Customer Agreement. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Children Under the Age of 18

Our Website is not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Website. We will remove any information about a child under the age of 18 if we become aware of it.

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us using the contact information provided below.

3. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

A) Generally:

We collect several types of information from and about users of our Website:

by which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, financial profile, financial account information, beneficiary information, age, income range, level of education, financial holdings, and information related to trading you may conduct in your brokerage account accessible through our Website (“Personal Data”);
that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and/or
about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

directly from you when you provide it to us;
from your brokerage account you have with All of Us Securities;
from other affiliates in the All of Us family;
automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies;
with your authorization to link to your other financial institutions, we may receive data from banks, card issuers, and card networks;
other third party service providers that we use to manage our Website, connect to other financial institutions, run credit and fraud checks, or other background checks to comply with applicable laws and regulations.

B) Information You Provide to Us:

The information we collect on or through our Website are:

information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website and/or signing up for a brokerage account or requesting further services. We may also ask you for information when you report a problem with our Website;
records and copies of your correspondence (including email addresses), if you contact us;
your responses to surveys that we might ask you to complete to better understand our customers and the communities you may be interested in;
details of transactions you carry out through our Website. You are required to provide financial information before placing an order through our Website;

If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to provide you with access to certain areas of our Website and you may not be able to perform some of the functions available on it.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile and joining/leaving our user communities, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

C) Information We Collect Through Automatic Data Collection Technologies:

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

details of your visits to our Website. We collect traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and
Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Website according to your individual interests;
speed up your transactions; and
recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

i. Cookies.

A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

ii. Web Beacons.

Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit All of Us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

iii. Third Party Cookies.

Some content or applications, including advertisements, on our Website are served by third-parties, content providers, application providers, and social media sites. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you access our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising and other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about advertisement or other targeted content, you should contact the responsible provider directly.

4. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

· provide our Website to you;

· provide you with information you request from us;

· enforce our rights arising from contracts;

· notify you about changes; and

· provide you with notices about your account

We use information that we collect about you or that you provide to us, including any Personal Data:

to present our Website and its contents to you;
to present relevant news to you based on your stated interests;
to provide you with information about relevant trends in the communities you belong to;
to provide you with information, products, or services that you request from us or to clarify a request you make from us;
to help process trades you may conduct through our Website;
to provide you with any legally required disclosures related to the securities in your All of Us Securities account, if you elect to receive these electronically;
to provide you with notices about your account;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Website or any products or services we offer or provide though them;
to allow you to participate in the investment communities you join and the interactive features of the on our Website;
to fulfill any other purpose for which you provide it;
in any other way we may describe when you provide the information; and
for any other purpose with your consent.

We may also use your information to contact you about our own services that may be of interest to you or to solicit your feedback. If you wish to opt out of some of our communications, you may do so at any time by logging into the Website and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by contacting us on email as described in the Contact Information section of this Privacy Policy and stating your request. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

· our subsidiaries and our affiliates;

· our third-party service providers that we use to support our business;

· to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;

· to comply with our legal obligations;

· to enforce our rights; and

· with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual (including such types of information from your All of Us Securities brokerage account available on or through the Website), without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

to our subsidiaries and affiliates;
to contractors, service providers, and other third parties we use to support our business;
to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of All of Us Financial Inc’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by All of Us Financial Inc about our Website’s users is among the assets transferred;
to fulfill the purpose for which you provide it. For example, if you give us information to share with your community or communities, we will transmit that information to those communities;
for any other purpose disclosed by us when you provide the information; and
with your consent.

We may also disclose your Personal Data:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our Terms of Use, the All of Us Securities Customer Agreement, the All of Us Master Security Agreement, and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of All of Us Financial Inc, our affiliates, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

All of Us uses Plaid, a service that enables applications to connect with end-user authorized data from financial institutions including banks, card issuers, and card networks. Plaid also structures the data that it receives and returns it to All of Us in a functional format. Plaid’s privacy policy is available here: https://plaid.com/privacy. By using our Website, you acknowledge and agree that your personal information will be treated in accordance with this Privacy Policy and Plaid’s privacy policy. Additionally, you grant All of Us the right, power, and authority to access and transmit your Personal Data and financial institution (such as from third-party banks) as is reasonably necessary for Plaid to provide its services to you.

5. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

A) Tracking Technologies and Advertising.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

B) Soliciting Feedback and Promotional Offers from All of Us.

We may use your contact information to promote our own or third parties’ products and services or to solicit your feedback regarding All of Us’s products or services. If you wish to opt-out of such use, you can check the relevant box located on the form on which we collect your Personal Data. If you wish to change your choice, you may do so at any time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by contacting us through the Contact Information described below. If we have sent you a promotional email, you may ask to be omitted from future email distributions by clicking the unsubscribe link at the bottom of the email. This opt out does not apply to information provided to All of Us as a result of a transaction you conduct on the Website.

6. Accessing, Correcting, and Deleting Your Information

You can access and correct your personal information. You can also request that we delete your information.

A) Access and Correction.

You can review and change your Personal Data by logging into the Website and visiting your “Account” page. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

B) Deletion.

You can request that we delete all of your Personal Data by contacting us through the Contact Information below. We cannot delete your Personal Data except by also deleting your user account (and selling any holdings you may have in your account and distributing the funds to you or transferring your brokerage account to another brokerage). We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

C) Verification of Your Identity.

If you contact us to access, correct, or delete your Personal Data, we may ask you for additional information to verify your identity and to help us prevent fraud and identity theft. We may ask you for this information even if you make your request after you have logged into your account. We reserve the right to limit or deny any request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

7. Your California Privacy Rights

California law requires that we obtain your consent before we share your information with unaffiliated third-parties. We currently do not share any such information.

California law requires that All of Us obtain your affirmative consent before it shares your non-public personal information with non-affiliated third parties. At this time, All of Us does not share information about you with any non-affiliated third party that triggers this consent requirement. Accordingly, there is no need at this time for All of Us to seek your consent for such sharing or for you to take any action to inform All of Us to share or not to share such information with non-affiliated third parties. California residents will receive an additional notice describing the privacy choices available under California law. Please review the California Privacy Notice and if you wish to do so, you may mark to indicate your preferences with regards to sharing of your information, and send it All of Us through the instructions at the bottom of the California Privacy Notice.

8. Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

9. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any transactions you conduct over our Website will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

10. Consent to Processing of Personal Data in the United States

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.

In order to provide our Website and services to you, we may send and store your Personal Data outside of your home country, including to the United States. Accordingly, your personal data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data as in your home country, and your Personal Data may be disclosed to the government where our Website is hosted (including the United States) or other regulators in such countries (including the United States). By using our Website, you represent that you have read and understood the above and hereby consent to the transfer, storage, and processing of Personal Data where our Website is hosted (including in the United States).

11. Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’ home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

12. Contact Information

You may contact us through the contact information below.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may do so at support@allofusfinancial.com