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Privacy Policy

Effective date: 14th of November, 2025

Last Updated: [Date]

Introduction: Welcome to our Privacy Policy. This policy explains how Zealth Planning, LLC (“we”, “us”, or “our”) collects, uses, shares, and protects your personal information when you use our services (the “Service”). We are committed to safeguarding your privacy and ensuring that you understand our data practices.

FIDUCIARY CONFIDENTIALITY STANDARD

Notwithstanding anything to the contrary in this Privacy Policy, Zealth Planning, LLC’s collection, use, and disclosure of personal information 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 Privacy 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.

PERSONAL INFORMATION WE COLLECT

We collect several types of personal information from you. The categories of data we collect include:

  • Identifiers and Contact Information: Your name, postal address, date of birth, phone number, and email address. (We do not collect sensitive identifiers like Social Security numbers.)
  • Financial Information: Details necessary for providing our service, such as financial account information or payment details.
  • User Credentials: If you create an account, we collect the login credentials (like username and password) you set up for the Service.
  • Usage Data: Information automatically collected about how you use our Service. This can include your IP address, device type, browser type, pages or features you access, and the dates/times of your visits. We also collect data through cookies and similar tracking technologies (see Cookies & Tracking below).
  • Non-Public Personal Information: For purposes of this Privacy Policy, personal information collected in connection with Zealth’s advisory services constitutes “non-public personal information” as defined under Regulation S-P and is subject to heightened confidentiality and protection requirements.

HOW WE COLLECT YOUR DATA

We gather personal data in the following ways:

  • Directly from You: 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.
  • Automatically: When you use our Service, we automatically collect Usage Data through cookies, web beacons, and similar technologies. This helps us understand how you interact with the Service and enables features like remembering your preferences.
  • From Third Parties: In general, most data we collect comes directly from you or your use of the Service. We do not currently obtain personal data about you from third-party sources (unless you explicitly connect a third-party service to our platform). If in the future we receive personal data from third parties (for instance, if you use a social login or link an external account), we will handle it according to this policy.

COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience and gather information:

  • What Cookies Are: Cookies are small text files stored on your device that allow us to recognize your browser or device and remember certain information. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain for a set period or until you delete them).
  • How We Use Cookies: We utilize cookies to remember your preferences, keep you logged in, and collect Usage Data (such as pages viewed, links clicked, and other actions on our site/app). Cookies also help us and our partners provide personalized content or advertisements and analyze how our Service is used.
  • Third-Party Cookies: We may allow third-party service providers (like analytics or advertising partners) to set cookies on our site. These cookies can track your browsing behavior across websites and apps over time for purposes such as analytics, ad targeting, or connecting with social media.
  • Your Choices: Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or alert you when cookies are being sent. However, please note that if you disable or reject cookies, some features of our Service might not function properly. For more details or to manage your cookie preferences, you can refer to your browser's help documentation or our separate Cookie Policy (if applicable).

HOW WE USE YOUR PERSONAL DATA

We use the collected information for various legitimate business purposes, including:

  • Analytics and Operational Use Only: Zealth may 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.
  • Providing and Improving the Service: To 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.
  • Customer Support and Communications: To 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).
  • Personalization: To 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).
  • Marketing and Advertising: To send you promotional communications about new features, products, or offers that may interest you. We may also use your data to show you targeted advertisements on our Service or on third-party platforms. This includes using cookies and advertising partners to deliver ads based on your browsing activities and interests.
  • Sharing with Third Parties for Marketing/Monetization: We may share certain personal information with third-party partners for their own marketing or business purposes. In some cases, this sharing may be considered a "sale" of personal data under certain laws. However, if you are using our Advisor Pro service, we will NOT sell your personal information to any financial services firms. We respect user choices, and you can opt out of marketing communications or certain data sharing as described in Your Rights & Choices below.
  • Analytics and Product Development: To analyze usage trends and metrics in order to understand how users interact with the Service. This helps us develop new features and improve the user experience. For example, we may use analytics tools to see which features are most popular or identify areas of the Service that need improvement.
  • Legal Compliance and Protection: To 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.
  • Other Purposes with Consent: If we intend to use your information for any purpose not listed above, we will explain it to you at the point of collection or obtain your consent as required. We will not use personal data in ways that are incompatible with the purposes for which it was collected without notifying you and/or obtaining your consent.

WHEN WE SHARE YOUR INFORMATION

We may share your personal data with the following categories of recipients, and only as necessary for the purposes described:

  • Permitted Disclosures to Service Providers: Zealth may disclose personal information only to third-party service providers that perform services on Zealth’s behalf and solely as necessary to (i) provide investment advisory services to clients, (ii) comply with legal or regulatory requirements, or (iii) maintain the security, integrity, and functionality of Zealth’s systems and Platform. All such service providers are contractually obligated to maintain the confidentiality of personal information, to use such information solely for the purposes specified by Zealth, and to refrain from any independent use, disclosure, marketing, profiling, or monetization of personal information.
  • Service Providers (Subprocessors): We employ trusted third-party companies and individuals to perform certain services on our behalf. These service providers only receive the personal data necessary to fulfill their functions, and they are contractually obligated to protect it and use it only for our specified purposes. For example:
    • Hosting and Infrastructure: We use Google Cloud Platform (GCP) to host our platform and store data securely in the cloud.
    • Customer Relationship Management: We rely on a third-party CRM (Customer Relationship Management) platform to organize user information and communications.
    • Analytics: We may use analytics services such as PostHog (or similar tools) to monitor and analyze usage of our Service.
    • Payment Processing: If our Service involves payments, we use a third-party payment processor (e.g., a credit card processing service) to handle your payment transactions securely. (These processors are responsible for your financial data related to payments; we do not store full payment card details on our own servers.)
  • Advertising and Marketing Partners: We may share certain personal and/or aggregated information with marketing partners, advertisers, or data analytics companies who help us with advertising and promotional efforts. For example, we might provide hashed (coded) portions of your data or certain demographic information to an advertising network in order to serve you tailored advertisements. These partners may use cookies or similar tracking technologies on our site to collect data about your online activities over time and across different services.
  • Business Transfers: If we undergo a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed to the prospective or actual successor or new owner as part of that transaction.
  • Legal and Compliance: We may disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to (i) comply with a legal obligation, subpoena, or court order; (ii) protect and defend our rights or property; (iii) prevent or investigate possible wrongdoing, fraud, or security issues; (iv) protect the personal safety of users or the public; or (v) protect against legal liability.
  • With Your Consent: In cases where you have given us consent to share your information with third parties, we will do so according to the terms of that consent. For example, if you opt-in to a feature that involves sharing data with a partner, we will share your data as needed to provide that feature.
  • Aggregated or De-Identified Data: We may share information that has been aggregated or anonymized with third parties for research and analytics purposes, provided such information cannot reasonably be linked back to any individual.
  • Aggregated or De-Identified Data: We may also share information that has been aggregated or anonymized (so it no longer identifies you personally) with third parties for research, marketing, analytics, or other purposes. Such information cannot be linked back to you.

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. We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. 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 & 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 & CHOICES

You have rights and choices regarding your personal information. 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 in Data Retention above). Also, note that it may take some time to fully delete information from our backup systems.
  • Withdraw Consent: If you have given consent for a specific processing activity (for example, receiving marketing emails), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.
  • 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.
  • Opt-Out of Marketing Communications: If you prefer not to receive promotional emails or newsletters from us, you can opt out at any time by clicking the "unsubscribe" link in those emails or by contacting us directly. Even if you opt out of marketing messages, we may still send you essential service or account-related communications.
  • Opt-Out of Data Sharing/Sale: If you do not want us to share your personal information with third parties for their direct marketing purposes, you can object or opt out. Please contact us (as described in Contact Us below) to request this. If applicable laws (such as California's privacy laws) provide you the right to formally opt out of the "sale" of your personal information, we will honor such requests.
  • 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.
  • Lodging Complaints: If you believe your privacy rights have been violated, you have the right to lodge a complaint with a supervisory data protection authority. For instance, if you are in the European Economic Area (EEA) or the UK, you can contact your local data protection authority with any concerns. We would appreciate the chance to address your concerns directly, so please consider reaching out to us first.

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.

Please note that some rights may not be absolute. There may be instances where we cannot fulfill a request due to legal requirements or other legitimate grounds. In such cases, we will inform you about the specific reasons if we have to decline the request.

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.

SECURITY OF YOUR INFORMATION

We take the security of your personal data seriously. We implement appropriate technical and organizational measures designed to protect your information from unauthorized access, loss, misuse, or alteration. These measures include access controls, encryption of data in transit (e.g., using HTTPS), and encryption of sensitive data at rest. We also regularly review our security practices and update them in line with industry standards.

However, please be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You share and transmit data at your own risk, and it is important to also protect your account credentials and devices.

INTERNATIONAL DATA TRANSFERS

Our Service is operated from and data is primarily stored in the United States. If you are accessing the Service from outside of that region, be aware that your information may be transferred to, stored, or processed in a country different from your home jurisdiction. The data protection and privacy laws of that country might not be as comprehensive as those in your own country.

Nonetheless, whenever we transfer personal data across borders, we will take steps to ensure it is protected in accordance with this Privacy Policy and applicable law. For example, for users in the European Economic Area (EEA) or other regions with data transfer restrictions, we may rely on legal mechanisms such as standard contractual clauses or your consent to transfer information to the United States of America. By using our Service or providing us with your information, you consent to the transfer of your personal data to other countries as described here.

CHILDREN'S PRIVACY

Our Service is not intended for children under the age of 13, and we do not knowingly collect personal information from anyone under 13. If you are under 13, 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 13 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 13 may have provided personal information to us, please contact us so that we can delete the data.

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.

CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:

  • Email: support@zealth.io
  • Address: [Street Address, City, State/Province, Zip Code, Country]

We will do our best to address your inquiry promptly and thoroughly. Your privacy is important to us, and we welcome your feedback.