Privacy Policy

Last Updated: May 27, 2026

Zealth Planning, LLC ("Zealth") recognizes that our relationships with current and prospective clients are based on integrity and trust. We work hard to maintain your privacy and to preserve the private nature of our relationship with you. We place the highest value on the information you share with us. We want our clients to understand what information we collect, how we use it, and how we protect your personal information. This policy explains how Zealth collects, uses, shares, and protects your personal information when you use our services and/or application (the "Service").

Zealth maintains and protects nonpublic personal information in accordance with applicable federal and state privacy laws governing registered investment advisers, including Regulation S-P under the Securities Exchange Act of 1934 and applicable state securities regulations.

Why We Collect Your Information

We gather information about you so that we can:

• Help design and implement the investment and financial planning related services we provide you;
• Comply with the Federal and State laws and regulations that govern us;
• Use personal information in aggregated or de-identified form, or on a limited identifiable basis where necessary, solely for operational, security, compliance, risk-management, and service-improvement purposes. Zealth does not use personal information for cross-context behavioral advertising, third-party marketing, or advertising profiling;
• Operate the Service, create and manage user accounts, authenticate you, and process transactions. We also use data to debug and improve the functionality and performance of our platform;
• Communicate with you about your account, respond to your inquiries, provide customer support, and send important service-related notices (such as changes to terms or security alerts); and
• Tailor the content and information we send or display to you, and to otherwise personalize your experience with our Service (for example, showing you content that is relevant to your interests).
• Comply with applicable laws, regulations, legal processes, or governmental requests. Also, to enforce our Terms of Service or other agreements, investigate potential fraud, security issues, or violations of our policies, and protect the rights, property, or safety of our users, our company, or others.

You provide personal information when you register an account, fill out forms on our site/app, enter information into our Service, or communicate with us. For example, you give us your contact details and financial information when signing up or using certain features.

Financial planning recommendations are generated based on information provided by users and may include automated or algorithm-assisted analysis. The completeness and accuracy of recommendations depend on the accuracy and completeness of information provided by users.

We also collect certain data automatically when you use the Service, including device type and identifiers, IP address, operating system, session activity, app usage events, and crash or error reports. This data is collected through our technical infrastructure providers described below.

What Information We Collect and Maintain

We may collect the following types of "nonpublic personal information" about you:

• Information from our initial meeting or subsequent consultations about your identity, such as your name, contact information, date of birth, and financial information;
• Information that we generate to service your financial needs; and
• Information that we may receive from third parties in connection with the services we provide you.

Our analytics tools (PostHog) collect usage data within the Zealth app only. We do not track users across third-party apps or websites, and we do not use Apple's Advertising Identifier (IDFA) for any purpose.

What Information We Disclose

We are permitted by law to disclose nonpublic personal information about you to unaffiliated third parties in certain circumstances. Zealth may disclose client's nonpublic personal information: (1) to individuals and/or entities not affiliated with Zealth, including, but not limited to third-parties that assist in the supervision or management of your account(s) (i.e., sub-advisers, account custodian, record keeper, attorney, etc.); (2) to service providers contracted by us in order for us to perform the duties in furtherance of the client's engagement with Zealth (i.e. client management systems, archiving technology vendors, cloud service providers, etc.); (3) to your authorized representative or power of attorney; (4) when we receive your prior consent; (5) in connection with a proposed or actual sale, merger, or transfer of all or a portion of our business; and (6) as otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. Such third parties act solely as service providers or approved partners engaged to facilitate, implement, or support client-requested advisory recommendations or account servicing. They are not permitted to use personal information for their own marketing or independent commercial purposes.

We will not sell your personal information. No contact information, including phone numbers and email addresses, will be shared with third parties or affiliates for marketing or promotional purposes. In the event that Zealth has a change to its client privacy policy that would allow it to disclose nonpublic personal information not covered under applicable law, Zealth will allow its clients the opportunity to opt-out of such disclosure.

How We Protect Your Personal Information

We restrict and limit access to client information only to those who need to carry out their business functions. We safeguard client information by preventing its unauthorized access, disclosure, or use. We maintain physical, electronic, and procedural safeguards to protect your confidential personal information. Arrangements with companies or independent contractors not affiliated with Zealth will be subject to confidentiality agreements.

Data Retention

Zealth retains personal information for as long as necessary to provide advisory services and as required under applicable securities laws, books-and-records rules, and regulatory obligations. Certain records must be retained for prescribed periods regardless of account closure. In practice:

• If you maintain an account with us, we will keep your account information for as long as your account is active or as needed to provide you services.
• Even if you request deletion of your data (see Your Rights and Choices below), we may retain certain information for a limited period of time to comply with legal obligations or legitimate business purposes. For example, financial records and any data related to transactions may be kept for at least seven (7) years to meet accounting, tax, or regulatory requirements.
• We also retain some usage data in aggregate form. Aggregated data (which does not identify individuals) may be retained indefinitely for analytics and improving our services.
• Once personal information is no longer necessary for our business or legal obligations, we will securely delete or anonymize it.

Your Rights and Choices

We are committed to providing you with reasonable access and control over your data. Subject to applicable law, your rights may include:

• Access and Portability: You can request details about the personal information we hold about you and get a copy of it in a common portable format.
• Correction: If any of your personal data is inaccurate or incomplete, you have the right to request that we correct or update it.
• Deletion: You can ask us to delete your personal information. When you request deletion, we will remove or anonymize your data from our active databases. However, we may retain certain information as required by law or for legitimate purposes (as noted above). Also, note that it may take some time to fully delete information from our backup systems. Deletion requests will not apply to information required to be retained under applicable federal or state securities laws, regulatory examination requirements, or books-and-records obligations applicable to registered investment advisers.
• Withdraw Consent: Where processing is based on consent and not required for advisory, legal, or regulatory purposes, you may withdraw such consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal. Consent-based processing does not apply to advisory records or information subject to regulatory retention requirements.
• Service Communications: Zealth may send clients communications that are necessary to provide advisory services, comply with legal or regulatory requirements, or inform clients about material updates to their accounts or the Platform. Zealth does not use client information for third-party marketing or advertising purposes.
• Object or Restrict Processing: In certain situations, you have the right to object to or ask us to limit the processing of your data — for example, if you believe our processing is based on our legitimate interests and you have a particular reason to object, or you want to restrict processing while a complaint is being resolved.
• Account Deletion: You may delete your Zealth account at any time directly from within the app via Settings - Account - Delete Account. Upon deletion, your personal data will be removed from active systems subject to our retention obligations under applicable securities laws.
• Lodging Complaints: If you believe your privacy rights have been violated, we would appreciate the chance to address your concerns directly. Please contact us at support@zealth.io with any privacy concerns.

Exercising Your Rights: You may exercise these rights by using available tools in your account settings (if provided) or by contacting us via email at support@zealth.io. For certain requests, we may need to verify your identity (for example, by asking you to provide information or identification) to ensure that these rights are exercised securely by the correct person. We will respond to your request within the timeframe required by law (if applicable) or otherwise as soon as reasonably possible.

California Privacy Rights

Where applicable, California residents may have certain rights under the California Consumer Privacy Act and California Privacy Rights Act. These rights apply only to the extent they are consistent with Zealth's fiduciary duties and obligations under applicable securities laws. Certain information may be exempt from deletion or disclosure where retention is required to comply with legal, regulatory, or professional obligations applicable to investment advisers.

Zealth primarily serves U.S. residents. Our Service is operated from and data is primarily stored in the United States. Where personal information is processed outside the United States, Zealth takes reasonable steps to ensure such information is protected in accordance with U.S. law and this Privacy Policy.

Third-Party Service Providers and Technical Infrastructure

We use the following third-party providers to operate our platform:

1. Firebase (Google LLC) — authentication, database, and cloud storage;
2. Sentry — crash reporting and error monitoring, which may receive device information and anonymized stack traces;
3. PostHog — product analytics, which collects usage events and session data in aggregate.

Children's Privacy

Our Service is not intended for children under the age of 18, and we do not knowingly collect personal information from anyone under 18. If you are under 18 please do not use the Service or provide any personal information to us. In the event we learn that we have inadvertently collected personal data from a child under 18 without appropriate consent, we will take steps to delete that information promptly.

If you are a parent or guardian and believe that your child under 18 may have provided personal information to us, please contact us so that we can delete the data.

Former Clients

Even if we cease to provide you with financial services, our Privacy Policy will continue to apply to you, and we will continue to treat your nonpublic personal information with strict confidentiality. We maintain all records regarding all former clients for the retention period required by law.

Contact Us

Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Gabriel Shahin, Chief Compliance Officer of Zealth. Please contact:

• Gabriel Shahin at 855-269-3258
• Email: support@zealth.io
• Address: 3400 Inland Empire Blvd., Ste 101, Ontario, CA 91764, United States

Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you by (for example) prominently posting a notice on our website or sending an email notification, and we will indicate at the top of this policy when it was last updated.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Service after any changes to this Privacy Policy constitute your acceptance of those changes.

This Privacy Policy is incorporated into and forms part of Zealth's Terms and Conditions. In the event of any inconsistency, the Terms and Conditions and Zealth's fiduciary obligations under applicable securities laws shall govern.