We collect information (including personal information and Traffic Data) when you use and interact with the MasterFi Services, and in some cases from third party sources. Such means of collection include:

• When you access, use, or contact us through the MasterFi Services.
• When you voluntarily provide information through the MasterFi Services.
• If you use a location-enabled browser, we may receive information about your location and device.
• Through Cookies, Web Beacons, analytics services, and other tracking technologies (collectively, “Tracking Tools”).

If you connect a financial account to MasterFi, MasterFi will obtain information from that account, including but not limited to, account balance, transaction information, and loan details. MasterFi facilitates our customers to use Plaid to retrieve information from relevant accounts, and we keep and use that information to provide you with the MasterFi Services. To connect an account, MasterFi requires you to use a service offered by Plaid Inc. (“Plaid”). By connecting an account using Plaid, you are agreeing to their Privacy Policy. Review Plaid’s Privacy Policy to learn more.

If you connect to MasterFi via your employer, MasterFi may receive information from your employer about your eligibility for benefits programs.

We may use tools outlined below in order to provide the MasterFi Services, advertise to, and better understand users.

• Cookies: “Cookies” are small computer files transferred to your device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the MasterFi Services. We use Cookies to: (i) improve and tailor the MasterFi Services, (ii) customize advertisements, (iii) measure performance, (iv) store authentication so re-entering credentials is not required, (v) customize user experiences, and for (vi) analytics and fraud prevention. For more information on Cookies, including how to control your Cookie settings and preferences, visit http://www.allaboutCookies.org. You can also manage Cookies in your web browser (for example, Edge, Explorer, Chrome, Safari). If you choose to change your settings, you may find that certain functions or features of the MasterFi Services will not work as intended. The following details the types of Cookies we use and why we use them:

• • Absolutely necessary Cookies. These Cookies are essential to enable you to move around a website and use its features. Without these Cookies, services you have asked for, like adding items to an online order, cannot be provided.

• • Performance Cookies. These Cookies collect information about how you use the MasterFi Services. Information collected includes, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These Cookies do not collect information that personally identifies you and only collect aggregated and anonymous information. Performance Cookies are used to improve the user-friendliness of a website and enhance your experience.

• • Functionality Cookies. These Cookies allow the MasterFi Services to remember choices you make (such as your username, language preference, or the area or region you are in) and provide enhanced, more personal features. These Cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of the MasterFi Services. The information these Cookies collect may be anonymized, and they cannot track your browsing activity on other websites.

• Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of the MasterFi Services. The information collected by Web Beacons allows us to analyze how many people are using the MasterFi Services, using selected publishers’ websites, or opening emails, and for what purpose.

• Web Service Analytics:  We may use third-party analytics services in connection with the MasterFi Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the MasterFi Services. We use the information collected from these services to help make the MasterFi Services easier to use and as otherwise set forth in Section 5 (How We Use Your Information). These analytics services generally do not collect personal information unless you voluntarily provide it.

• Mobile Device Identifiers:  As with other Tracking Tools, mobile device identifiers help MasterFi learn more about our users’ demographics and Internet behaviors in order to personalize and improve the MasterFi Services. Mobile device identifiers are data stored on mobile devices that may track activities occurring on and through it, as well as the applications installed on it.  Mobile device identifiers enable collection of personal information (such as media access control, address, and location) and Traffic Data.

We may use a type of advertising commonly known as interest-based or online behavioral advertising.  This means that some of our partners use Tracking Tools to collect information about a user’s online activities to display MasterFi ads to the user based on the user’s interests (“Behavioral Advertising”). Our partners may include third-party advertisers and other third-party service providers, and such partners may collect information when you use the MasterFi Services, such as IP address, mobile device ID, operating system, and demographic information. These Tracking Tools help MasterFi learn more about our users’ demographics and Internet behaviors.

If we process Cookies based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any point in time by contacting us at privacy@masterfi.ai. Please note, if you exercise this right, you may have to provide your consent on a case-by-case basis to enable you to utilize some or all of the MasterFi Services.

You may be able to reject Cookies and/or mobile device identifiers by activating the appropriate setting on your browser or device. Although you are not required to accept MasterFi’s Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the MasterFi Services.

• You may opt out of receiving certain Cookies by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) opt out page, or by installing the DAA’s AppChoices app (for iOS; for Android) on your mobile device. When you use these opt-out features, an “opt-out” Cookie will be placed on your device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete Cookies on your device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.

• Even after opting out of Behavioral Advertising, you may still see MasterFi advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that MasterFi is no longer using Tracking Tools. MasterFi still may collect information about your use of the MasterFi Services even after you have opted out of Behavioral Advertising and may still serve advertisements to you via the MasterFi Services based on information it collects through the MasterFi Services.

This Privacy Policy does not cover the use of Cookies and other Tracking Tools by any third parties, and we are not responsible for the privacy practices of any third party. Please be aware that some third-party Cookies can continue to track your activities online even after you have left the MasterFi Services.

Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have their online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including MasterFi, do not proactively respond to DNT signals.  For more information about DNT signals, visit http://allaboutdnt.com.

New standards are being developed for a Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC), which allow users with GPC-enabled browsers and devices to send a signal that will communicate the user’s request to opt-out of sales of their personal information and to opt-out of certain sharing of their personal information. The CPRA and other laws allow for the acceptance of Opt-Out Preference Signals such as the GPC, as an option for users to transmit an Opt-Out of selling/sharing personal information. If we detect and recognize such a signal from your device or browser, we will honor it.

We may use your personal information (including information that has been de-identified and/or aggregated) to better understand who uses the MasterFi Services and how we can deliver a better user experience. We use information, including personal information, to provide the MasterFi Services and to help improve the MasterFi Services, to develop new services, and to advertise our services. Specifically, such use may include:

• Providing you with the products, services, and information you request.
• Corresponding with you.
• Providing, maintaining, administering, or expanding the MasterFi Services, performing business analyses, and for other internal purposes.
• Combining information received from third parties with information that we have from or about you and using the combined information for any of the purposes described in this Privacy Policy.
• Showing you advertisements, including interest-based or online behavioral advertising.
• Fulfilling our legal obligations, such as preventing, detecting, and investigating security incidents, fraud, and potentially illegal or prohibited activities.
• Enforcing our Privacy Policy and other agreements.

By providing your e-mail and/or phone number and checking a box, clicking the “Accept” button, or some other affirmative act, you are consenting to receive e-mails and/or calls and text messages, including live, prerecorded, and/or automated calls and messages, to that email or phone number. After signing up, you will receive a confirmation e-mail or text message from MasterFi on your mobile number. This agreement is not entered into as a term or requirement of any purchase or promotion. Normal message and data rates may apply. Message frequency may vary. Neither we nor the participating carriers guarantee that messages will be delivered.  We may discontinue these programs at any time without notice.

We do employ artificial intelligence (AI) technologies (“AI Systems”) to enhance the performance and functionality of the MasterFi Services which includes tailoring your experience through automated processing based on your activity using the MasterFi Services. The AI Systems work by analyzing your voluntary inputs, usage patterns, preferences, and other interactions within our services to provide relevant information and discern your interests and preferences. The insights gathered allow us to improve our service offerings, provide personalized content and advertising, and enhance user satisfaction. By using the MasterFi Services, you consent to the use of AI as described in this Privacy Policy.

Our AI Systems may make automated decisions including:

• Content curation and personalized recommendations based on voluntary information you provide, user preferences and historical activity in order to better serve your needs regarding personal finance matters.
• Fraud detection and prevention through behavior analysis to identify and flag unusual activity that deviates from typical usage patterns.

You have the right to:

• Obtain an explanation of any automated decision and challenge its basis.
• Opt-out of certain uses of your data, including profiling activities for personalized content or advertising.
• Access the personal data that the AI Systems use or contribute to, and request rectification or erasure of such data.
• Receive information about the logic involved in any automated decisions, as well as the significance and the envisaged consequences of such processing for you.

We are committed to using AI responsibly. To this end, we implement the following safeguards:

• Regular auditing of our AI Systems for accuracy, fairness, and effectiveness.
• Human oversight to monitor AI decision-making and intervene as necessary to address anomalies or biases.
• Compliance with privacy regulations, ensuring that data used by AI is processed lawfully, transparently, and securely.

We encourage you to review your privacy settings regularly to ensure they continue to reflect your preferences. For more information on your rights and how we use AI, or if you have any concerns about automated decision-making processes, please contact us at privacy@masterfi.ai.

In certain circumstances, and in order to perform the MasterFi Services, we may share certain information about you as described in this section:

• We may sell your personal information to third parties who may offer you goods and services based upon input you provide to us.
• We may share your personal information with our partners to customize or display our advertising.
• We may share your personal information and/or Traffic Data with our partners who perform operational services for us (such as hosting, billing, fulfillment, data storage, security, insurance verification, web service analytics, or ad serving).
• We may share your personal information and/or Traffic Data with our partners to analyze device activities and generate targeted advertisements.
• We may transfer your personal information to another company in connection with a proposed merger, sale, acquisition or other change of ownership or control by or of MasterFi (whether in whole or in part). We will make reasonable efforts to notify you before your information becomes subject to different privacy practices.
• We also may need to disclose your personal information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with or fulfill our obligations under applicable law; (2) protect the rights, property or safety of you, MasterFi or another party; (3) enforce this Privacy Policy or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.

We have collected the following categories of sensitive personal information from consumers within the last twelve months:

• Mail, email, or text message contents
  • MasterFi Services leverage your message contents associated with MasterFi in order to personalize the MasterFi Services for you as they relate to personal finance matters.

We do not use or disclose sensitive personal information for purposes other than those specified.

Any information you send to us electronically, while using the MasterFi Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.

You can choose whether or not to provide personal information through the MasterFi Services. We will not discriminate against you for exercising any of your rights relating to your personal information and will not (i) deny you goods or services, (ii) provide you with a different level or quality of services, or (iii) charge you different prices for services for doing so.

If our processing of your personal information is subject to GDPR, UK GDPR, and/or PIPEDA, and unless subject to an exemption, you may have the following rights with respect to your personal information:

• Right of Access: You have the right to view and request copies of your personal information.
• Right to Rectification: You have the right to request that your inaccurate or outdated personal information be updated or corrected.
• Right to be Forgotten/Right to Erasure: You have the right to request your personal data be deleted, upon providing verification to us.
• Right to Restrict Processing: You have the right to request the restriction or suppression of our processing of your personal information.
• Right to be Informed: You have the right to be informed about the collection and use of your personal information.
• Right to Data Portability: You have the right to ask for your personal information to be transferred to you or to another controller.
• Right to Withdraw Consent: You have the right to withdraw previously given consent to process your personal information.
• Right to Object: You have the right to object to the processing of your personal information.
• Right to Object to Automated Processing: You have the right to object to decisions being made with your personal information solely based on automated decision making or profiling.

We will need to verify your identity to process any requests described in this Section and may deny your request if we are unable to verify your identity. Government or other identification may be required.

If you are a resident of the European Economic Area (“EEA”), when we process your personal information, we will only do so in the following situations:

• We need to use your information to perform our responsibilities under our agreement with you.
• We have a legitimate interest in processing your personal information. For example, we may process your personal information to send you marketing communications, to communicate with you about the MasterFi Services, and to provide and improve the MasterFi Services.
• We have your consent to do so.

If your personal data is subject to GDPR or UK GDPR, we will transfer personal data from the EEA to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.

We retain personal information about you for as long as necessary to provide you the MasterFi Services. In some cases, we retain personal information for longer, if doing so is necessary to comply with our legal obligations, or as otherwise permitted by applicable law. Afterwards, we retain some information in a de-identified and/or aggregated form but not in a way that would identify you personally.

The MasterFi Services are not intended for use by children. Individuals under the age of 18 may not use the MasterFi Services. MasterFi does not knowingly collect any information from children. If you are under 18, do not attempt to register for the MasterFi Services or send us any personal information. By accessing, using and/or submitting information through the MasterFi Services, you represent that you are not younger than 18 and that you have authority to do so. If you are a parent or legal guardian of a minor child, you may, in compliance with this Privacy Policy, use the MasterFi Services on behalf of such minor child. Information you provide through the MasterFi Services on behalf of a minor child will be treated as personal information as provided herein. If you use the MasterFi Services on behalf of another person, regardless of age, you represent and warrant that you have authority to do so.

The MasterFi Services may contain links or content from third party websites. A link or content from a third-party website does not mean we endorse that website, the accuracy of information presented, or the persons or entities associated with that website. If you visit a third-party website, you are subject to the privacy policy of the applicable third party and we are not responsible for the policies and/or practices of any third party. We encourage you to ask questions before you disclose your information to others.

The effective date of this Privacy Policy is set forth at the top of this webpage. We will notify you of any material change by posting notice on this webpage. Your continued use of the MasterFi Services after the effective date of any amendment to this Privacy Policy constitutes your acceptance of the amended Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. Any amended Privacy Policy supersedes all previous versions. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE MASTERFI SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

The data controller for the purposes of GDPR, UK GDPR, PIPEDA or other data protection laws is MasterFi. If you have any questions about this Privacy Policy, please contact us at privacy@masterfi.ai or at:

MasterFi, Inc.

Attn: MasterFi Privacy

Address: 1 Brunswick Ave,

Gardiner, ME 04345