Cookie Policy

Last Updated: [Date]

Introduction

Welcome to the Cookie Policy for Zealth Planning, LLC (“Zealth,” “we,” “us,” or “our”). This policy explains how we use cookies and similar tracking technologies on our website and mobile application (collectively, the “Services”). We are committed to protecting your privacy and complying with applicable U.S. laws, including the California Consumer Privacy Act (CCPA). In this policy, we describe what cookies and trackers we use, why we use them (for functionality, performance, and essential operations), and how you can manage your preferences. Importantly, we do not use any third-party advertising or third-party analytics trackers on our Services at this time. All cookies and tracking data we collect are used for our own purposes to provide and improve the Services, as explained below.

By using our website or mobile app, you agree to the use of cookies and similar technologies as described in this policy (to the extent permitted by law). If you do not agree, you can disable cookies or adjust your tracking preferences as outlined in the Your Choices section. Please note, however, that some cookies are essential for our Services to function properly, so disabling them might affect your experience.

Fiduciary Confidentiality Standard

Notwithstanding anything to the contrary in this Cookie Policy, Zealth Planning, LLC’s use of cookies and similar tracking technologies is governed first and foremost by Zealth’s fiduciary duties under applicable federal and state securities laws, including Regulation S-P under the Investment Advisers Act of 1940. This Cookie Policy applies only to the extent it is consistent with those fiduciary and regulatory obligations. In the event of any inconsistency, Zealth’s fiduciary and regulatory obligations shall control.

What Are Cookies and Tracking Technologies?

Cookies are small text files that websites place on your computer or mobile device when you visit a site. They allow the site to recognize your browser or device and remember information about you. For example, cookies can remember your login status or site preferences. Cookies can be “session” cookies (which expire and are deleted when you close your browser) or “persistent” cookies (which remain on your device for a set period of time or until you delete them).

Tracking technologies similar to cookies are also used in our Services, especially in our mobile app. These include technologies such as web beacons (tiny graphics that monitor page views or email opens), local storage and session storage in your browser (which store data on your device), and device identifiers on mobile devices (unique IDs that can identify your app or device). These tools help us recognize you and collect information when you use our website or app. They do not give us access to your device or files, but they do allow us to remember certain details and understand how you use our Services.

Cookies and Trackers We Use and Why

We use cookies and similar trackers to make our website and app work smoothly, to remember your choices, and to improve our Services. Below are the types of cookies and tracking technologies we use, and their purposes:

• Essential Cookies: These cookies are necessary for the essential operations of our Services. They enable core functions like security, network management, and accessibility. For example, essential cookies keep you logged into your account as you navigate between pages, enable you to load pages faster, and help us prevent fraudulent activity. Without these, the Services may not function properly.
• Functional Cookies: These cookies allow us to remember your preferences and enhance the functionality of our site/app. They aren’t strictly necessary for operation, but they make your experience better. For instance, functional cookies might remember your username so you don’t have to re-enter it, recall your preferred settings (such as language or display options), or enable other convenient features. Using these cookies, we can provide you with a more personalized and seamless experience.
• Performance/Analytics Cookies: These cookies (sometimes called performance cookies) help us understand how users interact with our Services so we can improve them. They collect information about usage, such as which pages or features are most popular, how often certain features are used, and whether users encounter errors. This data is used internally for analytics to improve our product’s performance and design. For example, we may track aggregate usage statistics or error logs to identify areas of the app that need optimization. All analytics data collected is used by Zealth for our own analysis, and is not shared with third-party analytics providers. We do not currently use any external analytics services (such as Google Analytics) that would place their own cookies on your device.
• Advertising/Targeting Cookies: We do not use any advertising or targeting cookies. Zealth’s Services currently do not incorporate third-party advertising networks, marketing cookies, or social media trackers that profile you. This means you will not see third-party ads on our site/app and we are not tracking you for advertising purposes. All of the cookies and tracking technologies in use are for the operational purposes described above, and not for advertising. If we ever introduce advertising or third-party tracking cookies in the future, we will update this policy and obtain any necessary consents at that time.

Third-Party Cookies: As noted, at this time we are not using any third-party cookies on our website or app for advertising or analytics. All cookies in use are set by Zealth (first-party cookies) or by our service providers for core functionality (for example, a cookie to process payments or ensure security, if applicable). In other words, no external advertising networks or analytics companies are collecting data about your browsing through cookies on our site. Should this change, we will clearly inform you and update our practices.

Cookies and Tracking in Our Mobile App

Using cookies in a mobile app is a bit different than on a website, but our Zealth mobile application uses similar technologies to achieve the same purposes described above. For example, our app may store small pieces of data on your device to remember your in-app preferences or login session (this is analogous to a cookie in a web browser).

The Zealth mobile application does not use advertising identifiers or tracking technologies for marketing, advertising, or profiling purposes. Any device identifiers used are limited to security, authentication, and internal performance monitoring and are not shared with third parties for advertising or marketing.

The app may also utilize unique mobile identifiers provided by your device’s operating system (such as Apple’s Identifier for Advertisers or Google’s Advertising ID) to distinguish your device for things like user authentication and internal analytics. Additionally, we might collect usage and performance data through the app to understand how the app performs (for instance, tracking if a feature is working or if the app crashes, so we can fix issues quickly).

However, just like our website, our mobile app does not include any third-party advertising or analytics trackers. We have not embedded any third-party advertising SDKs or external analytics SDKs in the app. This means the app is not sending your data to third-party marketing companies or analytics platforms. Any tracking within the app is done solely to support core functionality (like remembering you are logged in or measuring app performance) and is handled by Zealth or our service providers acting on our behalf. Your mobile data is treated with the same care and under the same privacy principles as your web data.

Your Choices: Managing Cookies and Tracking

You have the right to control or limit how cookies and trackers are used when you interact with our Services. Below, we outline ways you can manage your preferences on both web browsers and mobile devices.

• Web Browser Settings: Most web browsers allow you to manage or disable cookies through the browser’s privacy settings. You can typically set your browser to refuse all cookies, to accept only certain types, or to notify you when a cookie is being set. For example, in common browsers you can find these options as follows:
  • Google Chrome: Go to Settings > Privacy and Security > Cookies and other site data, and choose your preferred cookie settings (e.g., block third-party cookies or clear cookies on exit).
  • Mozilla Firefox: Go to Options/Preferences > Privacy & Security, then under Cookies and Site Data adjust your settings (you might use Enhanced Tracking Protection or custom settings to block cookies).
  • Apple Safari (Desktop): Go to Preferences > Privacy, where you can block all cookies or select how Safari handles cookies and website data.
  • Microsoft Edge: Go to Settings > Cookies and site permissions > Manage and delete cookies and site data, then set your preferences (such as blocking third-party cookies).
• You can also delete cookies that have already been set through your browser’s settings. For more detailed instructions, refer to your browser’s help documentation or support website. Additionally, tools like browser extensions or privacy modes (incognito/private windows) can limit or block certain cookies and trackers.
• Mobile Device Settings: On mobile devices, you can limit tracking through your device’s privacy settings. While mobile apps don’t use cookies in the same way websites do, they do use device identifiers that you can control. For example:
  • Apple iOS: On an iPhone or iPad, go to Settings > Privacy & Security > Tracking. Here you can prevent apps from tracking you across apps and websites by disabling the “Allow Apps to Request to Track” option. You can also reset your device’s advertising identifier by going to Settings > Privacy & Security > Apple Advertising and turning off personalized ads.
  • Android: On Android devices, go to Settings (or Google Settings) > Privacy > Ads and enable “Opt out of Ads Personalization” (this may be worded as “Delete/Reset Advertising ID” on some versions of Android). This will tell apps not to use your advertising ID to build profiles or show you personalized ads. Additionally, you can reset your advertising ID from the same menu, which clears the past identifier.
• For both iOS and Android, you can also manage permissions on an app-by-app basis (for example, denying a finance app access to your location or contacts if those aren’t necessary). Adjusting these settings can help limit the data that apps (including ours) can collect or share via device identifiers.
• Global Privacy Control and “Do Not Track”: Some web browsers and extensions allow you to send a “Do Not Track” (DNT) signal or utilize a Global Privacy Control (GPC) to indicate your preference not to be tracked. Currently, there is no universal standard for websites to honor DNT signals, and our website does not respond to DNT signals in a standardized way. However, because we do not use third-party advertising cookies, your browsing on our site is not being tracked for advertising purposes regardless of DNT. We still recommend using the other methods described above to control cookies and trackers. If industry standards around DNT/GPC emerge, we will adjust our practices accordingly.

Please note: If you choose to disable or block cookies (especially essential cookies), some features of our website or app may not function properly. For instance, you may not be able to stay logged in, certain secure areas might not be accessible, or some preferences might not be saved. We recommend keeping essential cookies enabled to ensure the Services work as intended. You can always opt out of non-essential tracking without affecting basic functionality.

California Consumer Privacy Act (CCPA) Notice

If you are a California resident, you have specific privacy rights regarding your personal information, including data collected through cookies and trackers. Under the CCPA (as amended by the CPRA), you have the right to know what categories of personal information we collect and how we use it, the right to request deletion of personal information (subject to certain exceptions), and the right to opt out of the sale or sharing of your personal information. In accordance with these laws, we want to reassure you that we do not sell or share your personal information, including information collected via cookies and tracking technologies, for monetary value or for cross-context behavioral advertising. This means the opt-out right is generally not applicable to our use of cookies, since we aren’t exchanging your data with third parties for advertising or similar purposes.

We also respect your right to non-discrimination under CCPA: we will not treat you differently (for example, deny you services or charge a different price) because you exercised any of your privacy rights. For more details on our data practices and a full explanation of your rights under California law (and how to exercise them, such as requesting data access or deletion), please see our full Privacy Policy. California residents may also contact us as described in the Privacy Policy if they have any questions or requests related to their personal information.

All California privacy rights described above apply only to the extent they are consistent with Zealth’s fiduciary duties and confidentiality obligations under applicable securities laws.

Updates to This Policy

We may update this Cookie Policy from time to time to reflect changes in our technology or business practices, or to comply with new legal requirements. If we make material changes, we will notify users by posting the updated policy on our website (and in our app, if appropriate) with a new “Last Updated” date. We encourage you to review this policy periodically to stay informed about how we use cookies and tracking technologies. Your continued use of our Services after any update constitutes your acceptance of the revised Cookie Policy.

Contact Us

If you have any questions about this Cookie Policy or how Zealth uses cookies and similar technologies, please contact us at support@zealth.io or refer to the contact information provided in our Privacy Policy. We will be happy to assist you and address any concerns you may have regarding your privacy and our use of cookies.