Privacy Policy

Last Updated: August 13, 2026

Privacy Policy

Introduction

This Privacy Policy (“Policy”) tells You how Financial Wellness Labs, Inc. (“Financial Wellness Labs”, “we,” “us,” or “our”) collects, uses, shares, secures, and eventually deletes, information collected from and about visitors to our Website, and from our Customers. This Policy is intended to comply with all applicable federal and state privacy laws, including but not limited to the GLBA, CCPA/CPRA, and other state privacy laws. We respect Your privacy and are committed to protecting the Personal Information that You may share with us.

Remember that your use of Financial Wellness Labs’s Services is at all times subject to our Terms and Conditions, which incorporate this Privacy Policy. Any capitalized terms we use in this Policy without defining them in the Definition section below will have the same meaning that has been given to such terms as provided for in the Terms and Conditions.

Scope Of This Policy

This Policy covers both our online and offline data collection activities, including information that we collect through our Website and/or App, as well as offline with our 1-on-1 financial coaching. This Policy also applies when You access or use our Services through an embedded interface, web view, widget, or integration within a third-party partner’s platform or application (e.g., through Your employer’s benefits portal or workforce management system). In such cases, the partner’s own privacy policy may also apply to Your use of the partner’s platform. By continuing to visit and use our Website or access our Services through any of these methods you are agreeing to the terms of this Policy. If You do not agree, then please exit this Website and close Your browser.

Additionally, if You sign up for our coaching or other individualized programs, in which You share Your Personal Information with us directly either offline or via virtual meeting, You are consenting to the terms of this Policy as well. If You do not consent to share Your Personal Information with us via these programs, then please do not participate in the same and do not share any of Your Personal Information with us.

Definitions

“App” means our mobile application(s), including the Finley mobile application, available for iOS, Android, or other platforms through which You may access our Services. Except where the context requires otherwise, references to the “Website” in this Policy include the App.

“Customer” means a natural person who signs up for our services.

“Personal Information” means any information relating to an identified or identifiable individual that is collected from our Customers and Users via our Website and/or App or offline at one of our in-person events or programs. Personal Information may include a Customer’s or a User’s: full name, physical address, email address, IP address, or other identifier such as from a Cookie. Personal Information does not include any aggregate or anonymized data that may have been created from Personal Information but can no longer be used to identify, relate to or could reasonably be linked to a Customer or a User. Personal Information also includes information referred to as “personally identifiable information” or “personal data” under applicable data privacy laws, rules, or regulations. For California residents, “Personal Information” includes all categories defined under Cal. Civ. Code § 1798.140(v).

“Sensitive Personal Information” means any Personal Information that reveals a racial or ethnic origin, political opinion, religious belief, philosophical belief or trade union membership. It also may include a natural person’s genetic and biometric data, financial information, and data concerning their health, sex life or sexual orientation.

“User” means a natural person that visits and interacts with our Website and/or App.

“You” or “Your” means a Customer or User.

“Website” means https://www.questis.co/, https://financialwellnesslabs.com and https://getfinley.com and all other websites owned or controlled by us from time to time, and any embedded interfaces, web views, or integrations through which our Services are accessed.

Financial Wellness Labs’ Information Collection Practices

Overview

Financial Wellness Labs offers a range of services, both via our Website and offline and via virtual meeting via our coaching sessions. It is our policy to only obtain the Personal Information that is necessary to provide our products and services to You and to limit the access to customer Personal Information to only those individuals who need it to serve our Customers’ and Users’ needs.

Additionally, as we strive to provide the best service and experience, certain information may also be used to maintain and improve our customer service to You; be used to create and develop new products, offerings, and events; and otherwise support the provision of our services to our Customers. We have outlined all of the different ways that we share and use Your information in this Policy.

Information that We Collect from You when You visit Our Website

We collect certain Personal Information from You in order to operate our Website effectively and provide You with the best experiences when You visit and use it.

Information Provided by You

When You register for a Customer account online or sign up for a subscription with us, we will collect certain Personal Information about You such as Your name, address, e-mail address, date of birth or age range, telephone number, general geographic location (such as Your zip code or city and state), hobbies and interests, information about your job and employer, or other lifestyle information.

We may also collect Your Sensitive Personal Information, such as Your gender, Your financial information (such as details of Your financial accounts, salary information, and tax information), and information about your financial goals. Please note that we utilize Plaid, Inc. (“Plaid”) to collect, process, and store this information for You via our platform. Please note that information provided via Plaid is for informational purposes only and does not represent an official record of your account information. You have the option to modify certain demographic information stored under Your account profile. You are able to disconnect information sharing from any or all of your third-party accounts from Plaid at any time through your account.

Account Removal and Exclusion Feature

Our platform allows You to remove or exclude specific financial accounts from appearing on Your dashboard. It is important for You to understand what this action means for Your data:

What “Removal” or “Exclusion” Means. When You choose to remove or exclude a financial account from Your dashboard, the account will no longer be visible in Your account interface and will not be reflected in any aggregated financial views, reports, or calculations displayed to You. However, this action does not, by itself, delete the account data from our systems or terminate the underlying connection to that financial institution.

Plaid Connection Status. Unless You take additional steps to revoke access, the Plaid connection associated with an excluded account may remain active. This means that Plaid may continue to have authorized access to retrieve data from that financial institution on our behalf, even while the account is hidden from Your dashboard.

You may revoke Plaid’s access to any connected financial institution at any time by visiting Plaid’s consumer portal at https://my.plaid.com/ or by contacting us at help@getfinley.com to request disconnection.

Data Retention for Excluded Accounts. When You exclude a financial account from Your dashboard, the data previously collected for that account (including transaction history, account balances, and related information) may remain stored in our systems for 12 months. During this retention period, the data will not be displayed to You but may be used for the purposes described in this Policy, including service improvement, fraud detection, compliance with legal obligations, and internal analytics. If You submit a data subject access request during the retention period, we will include the data from Your excluded accounts in our response unless You specifically request otherwise.

Re-enabling Excluded Accounts. You may restore a previously excluded financial account to Your dashboard at any time by accessing Your account settings and selecting the option to re-enable the account. When You re-enable an excluded account, all previously collected data for that account (including transaction history and account balances stored during the exclusion period) will again be visible on Your dashboard and reflected in Your aggregated financial views. If the Plaid connection for the excluded account remained active, the restored account will display up-to-date information. If You previously revoked Plaid’s access to the excluded account, You will need to re-authorize the connection to retrieve current data.

Full Deletion of Plaid Connection and Associated Data. Full deletion of a Plaid connection and the associated data stored in our systems occurs when: (i) You submit a verified request to delete Your Personal Information pursuant to applicable data protection laws; (ii) You close or delete Your account with us; (iii) You specifically request deletion of a particular Plaid connection and its associated data by contacting us at help@getfinley.com. Upon full deletion, we will disconnect the Plaid integration for the applicable financial institution(s) and remove the associated data from our active systems within 45 days, subject to any legal or regulatory retention requirements that may require us to retain certain records for a longer period.

Legal Basis for Continued Retention. Our legal basis for retaining data associated with excluded accounts includes: (i) our legitimate business interests in maintaining accurate records and providing You with the ability to re-enable excluded accounts without requiring reconnection; (ii) compliance with applicable legal and regulatory requirements, including recordkeeping obligations under the Gramm-Leach-Bliley Act; (iii) the establishment, exercise, or defense of legal claims. During the retention period for excluded accounts, we may continue to share such data with our authorized service providers as described in the “Who We Share Your Personal Information With” section of this Policy, but only to the extent necessary to fulfill the purposes for which the data is retained. We will not use data from excluded accounts to send You marketing communications or display targeted advertising related to those accounts. If You have questions about how we process Your data or wish to exercise Your rights under applicable law, please contact us at help@getfinley.com.

We will also collect certain Personal Information about You if You sign up to receive our marketing communications or if You provide us with a review or feedback about our products, we may collect certain Personal Information from You along with that feedback and in certain cases Your Sensitive Personal Information as well.

If You are a Customer and make a purchase with us directly online, we also need to collect Your financial information, which is also considered Sensitive Personal Information. We would also need to collect any information that You use to make a purchase, such as Your credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). This also includes the billing name and address associated with Your form of payment.

If You choose, You can have Your payment information stored as well (along with Your account history and other related preferences). Please note that we utilize a third-party payment processor (the “Payment Processor”) to facilitate all online payments and thus when You make a payment and if You choose to store Your payment information on Your account, such information will be collected, processed, and stored by the Payment Processor not with us directly. Please see our Payment Processing section below for more information.

Information collected on Our Website

We also may use various technologies and methods to collect information directly from You or from Your computer or device and about Your activities on our Website.

Information collected automatically: We may automatically collect information from You when You visit Our Website. This information may include Your IP address, location data, Your browser type and language, access times, the content of any undeleted cookies that Your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information.

We use Google Analytics to collect information about Your use of Our Website as well. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at: https://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please see: https://policies.google.com/technologies/partner-sites.

We may also collect information from You automatically through any site or web application that we may develop and run on a third-party social network such as Facebook. This could also include any site or application that we specifically design for use on a cell phone or other mobile device, such as a mobile-enabled site (i.e., WAP site) or mobile application (e.g., iPad/iPhone app).

Cookies: When You visit our Website, We may assign Your device one or more cookies to facilitate access to our site and to personalize Your online experience. Through the use of a cookie, we also may automatically collect information about Your online activity on our site, such as the web pages You visit, the links You click, and the searches You conduct on our site.

Most browsers automatically accept cookies, but You can usually modify Your browser setting to decline cookies. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when You close Your browser and is used to make it easier for You to navigate our website. A persistent cookie remains on Your hard drive for an extended period of time.

We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about Your use of Our site with Our social media, advertising and analytics partners, who may combine it with other information that You’ve provided to them or that they’ve collected from Your use of their services.

When You first visit our site, we provide You with a choice to either accept or deny certain cookies. If You choose to decline cookies, please note that some of the features and services of our Website may not function as well as intended. Even if You choose to accept cookies, You are always free to change Your mind and revoke that consent. Also, to optout from third-party cookies that are used for advertising purposes, You can do so on the NAI website at: https://www.networkadvertising.org/managing/opt_out.asp.

Technical computer information is not typically associated with Your personal contact information.

Customer Surveys and Feedback Forms

We may ask You to voluntarily share with us comments on and aspects of Your experience in using our services, including coaching services and our Website, via customer surveys online and feedback forms that we may e-mail to or solicit from You. We may also collect comments and suggestions about our services and Website, testimonials, or other feedback You send us about what You may have liked (or disliked) about Your experience in using our services.

Other Technologies

We may use standard Internet technology, such as web beacons, pixels, and other similar technologies, to track Your use of our Website. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to Customers and Users of our Website, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming, or other activities.

Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on Your device, web beacons are embedded invisibly on the web pages (or in emails) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count visitors to certain pages, and to understand usage patterns. We also may receive an anonymous identification number if You come to our Website from an online advertisement displayed on a third-party website.

Information Collected from You from Your Employer or the Referring Organization

When You receive access to our services from Your employer or an organization you are a member of, we need to collect certain Personal Information about You such as Your name and work e-mail address or other email address or Personal Information to enable You to claim Your membership via Your employer or the referring organization.

Please note that we do not share any Personal Information that our Customers provide directly with their employers or their referring organization. We only receive Your eligibility information from such third party and will only share the minimum amount of information necessary to provide the services such as confirmation of enrollment and only with Your consent where required by law. If You do not agree to such sharing, please contact us at help@getfinley.com to discuss Your options. Please note that certain services may not be available if You withdraw Your consent.

Third-Party Partner Data Integrations

We may receive Personal Information and Sensitive Personal Information about You directly from third-party partners with whom we integrate, such as workforce management platforms, payroll providers, or employer benefits portals, via application programming interface (API) or other data integration methods. The categories of data we may receive from these partners include:

• Payroll information (e.g., pay frequency, gross and net pay amounts, pay dates, deductions);

• Employment information (e.g., employment status, job title, hire date, employer name);

• Compensation details (e.g., salary, hourly rate, bonus information); and

• Other information necessary to provide our Services to You through the partner’s platform.

• We use data received from third-party partners to provide and personalize our Services to You, including to generate financial insights, alerts, and recommendations; to verify Your eligibility for employer-sponsored programs; and for the other purposes described in the “Why We Collect Your Information” section of this Policy. Such data is retained in our systems subject to the data retention terms described in the “How Long Do We Store And Maintain Your Personal Information?” section of this Policy. Your use of our Services through a third-party partner’s platform may be subject to the partner’s terms of service and privacy policy in addition to this Policy.

Information Collected from You Over via Phone, Live Chat, and E-Mail

Live Chat with Customer Service Team: If You use the Live Chat feature on our Website, we will collect certain information from You such as Your name, email address, and information about why You are chatting with us. Some of that information may be considered Sensitive Personal Information as it may reveal Your gender and race.

We only collect this information in order to communicate with You, address why You are chatting with us, and ensure that You have a great customer experience. We may also record the live chat and/or keep a transcript of the same for our business purposes and as needed for any follow-ups You may have about the issue You contacted us about. If You do not consent to the recording of Your live chat conversation, please contact us via email at help@getfinley.com.

Additionally, we may use a bot or other automated tool to collect certain information from You or to provide You with certain information when You interact with our Live Chat feature on our Website.

Call Center and Customer Service: If You contact us over the phone or by mail to speak with our Customer Service department, we will collect certain Personal Information from You, such as Your name, home address, e-mail address, and phone number. We may also need to use Your Personal Information to sign You up for our services, and/or further contact You to respond to Your inquiry or request.

Why We Collect Your Information

We collect Your Personal Information and Sensitive Personal Information for various reasons, which are described below:

To Service Our Website and/or App

We use information collected to ensure that our Website and/or App are working as intended and for analytics purposes, to understand how our Website and/or App are operating and learn how they can be improved. We also use this information as needed for auditing purposes as well.

To Provide Our Products and Services to You and Facilitate any Customer Service Issues

We use information collected to provide our services to you, and to follow up with You about Your satisfaction with the ordered products.

To Maintain Your Account

We may use information collected to maintain Your account(s) with us, including administering any programs associated with such account(s).

For Our Marketing Purposes

If You have filled out a contact form with us, signed up to receive our alerts or newsletter, or have otherwise signed up to receive our direct communications, we may use this information to send You marketing communications, such as email communications, mobile messages (including text and/or push notifications), and postal mailings.

These communications may inform You about new products, special discounts and offers, and other news related to our Services. On occasion, these communications may also contain information or offers about third-party products. In some instances, we may use technical information or precise geo-location information obtained from Your mobile device to send You messages directly to Your mobile device, including offers based on Your location.

To Evaluate and Improve our Customer Service

We may use this information to ensure we are providing the highest level of customer service, and to identify any potential gaps or potential improvements to the same. Customer service may be provided through various forms of communication, such as email correspondence and call center support.

To Evaluate, Improve, and Customize Our Products and Services

We may use information collected to improve our products and services, tailor them to Your needs, and come up with new product ideas.

To Administer Contest and Promotions

We may use information collected to administer a contest, giveaway, competition, or other similar marketing campaign or promotion. For more information about our contests and other promotions, please see the official rules or details that will be posted with each promotion.

In Order to Respond to Requests from You

If You have requested further information or in any other way requested that we contact You, we will use Your Personal Information to respond to such a request.

To Provide a Personalized and Convenient Website Experience for You

We may use information collected to personalize Your experience and save You time when You visit our Website. For example, we might remember Your login ID or username so You can quickly login the next time You visit our site. Based on this type of information, we might also show You specific Financial Wellness Labs content or offers that are more relevant to Your interests.

For Our Other General Purposes

We may use information collected other general business purposes, such as to maintain the day-to-day operation and security of our Website and/or App, and to conduct internal marketing and demographic studies.

For Our Legal Purposes

We also collect information in order to comply with certain legal rules and regulations that we are subject to.

AI, Machine Learning, and Analytics

We may use the Personal Information and Sensitive Personal Information we collect, including information received from third-party partners, for the following purposes related to artificial intelligence, machine learning, and data analytics:

• To train and improve our internal machine learning models and algorithms to enhance our Services; To conduct data analytics, research, and statistical analysis to understand user behavior, financial trends, and service effectiveness; To develop and improve our products, services, and features; and To generate aggregated and de-identified datasets for business purposes, including benchmarking and industry analysis.

Where we use Sensitive Personal Information for these purposes, we will de-identify or aggregate the data where feasible. We will not use data processed for machine learning or analytics purposes in a manner that would result in decisions that produce legal or similarly significant effects on You without appropriate safeguards, including human review where required by applicable law.

How Long Do We Store And Maintain Your Personal Information?

We only store and maintain Your Personal Information for as long as is necessary to fulfill the purpose for which it was collected. For example, if You sign up to receive Our newsletters or to receive job alerts, We will store and maintain Your Personal Information to continue to send You these materials until You opt out of receiving such communications.

With regards to Your Personal Information collected for our analytics purposes and used to help maintain and improve Our Website, we only store and maintain that information until it is aggregated and used to create a new anonymous data set that no longer contains Your Personal Information, and then delete the underlying Personal Information once that new data set has been created.

If You are one of our valued Customers and have created an account with us, we store Your Information as long as Your account remains active or as otherwise necessary to provide You with our services or operate our business. In some cases, we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. If You request that we remove your Personal Information from our systems, we will do so within 45 days, if permitted by our legal and regulatory obligations. Please note that using the account exclusion feature described above does not constitute a deletion request and will not trigger this 45-day deletion timeline; excluded accounts remain stored in our systems as described in the “Account Removal and Exclusion Feature” section until You submit a verified deletion request or take other action resulting in full deletion.

If You are a Customer and You do not have an account, we only store Your information as long as needed to support Your purchase and relationship with us. When we no longer have a legal need, or You close or delete Your account with us, or otherwise ask us to delete Your account, we will do so securely.

We Do Not Sell Your Personal Information

Financial Wellness Labs does not sell Your Personal Information that it has collected via Our Website to any third parties. We do not sell Your Sensitive Personal Information to any third parties and only use Your Sensitive Personal Information to provide our products and services to You.

Who We Share Your Personal Information With

Generally, we share Your Personal Information as necessary to provide the services or products You request, including sharing information with certain third parties, such as service providers. We also may share Your Personal Information when required to by law; to protect Your rights and safety, and with Your consent. Specifically, we may share Your Personal Information with third parties, including:

Authorized service providers

We may share Your Personal Information with our authorized service providers that perform certain services on our behalf. These services may include relationship management software; website hosting; evaluators, contractors and auditors; email marketing providers; customer service providers; providers that perform business and operations analysis for us; and providers that support and maintain our Website, including providing analytics services for us.

Payment Processor

We need to share Your Personal Information and Your Sensitive Personal Information with Stripe, Inc. (“Stripe”), our Payment Processor, in order to complete Your purchases online. You may also be able to store Your payment information with Stripe via Your profile with us. Stripe collects, processes, and stores Your payment information directly for us. You can learn more about Stripe’s privacy practices here: https://stripe.com/privacy.

We do not store any of Your financial information directly and any such storage or remembering of the same will be facilitated by Stripe.

For a Legal Reason

We may have to share Your Personal Information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

To Prevent Fraud or Illegal Conduct

We may have to share Your Personal Information in situations where we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property, or safety of our company, our consumers, our employees, or others; or to enforce our Terms of Service or other agreements or policies.

For Corporate Reasons

All of Your Personal Information that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). After such a transfer, the acquiring party will make decisions regarding the use and protection of Your Personal Information. To the extent required by applicable law, Your Personal Information will remain subject to the terms of the Privacy Policy under which it was collected until You are notified of any changes to those terms by the acquiring party.

With Your Consent

To other third parties that You provide consent to share Your information with or that You have requested that we share Your information with.

When You access our Services through a third-party partner’s platform, we may generate and transmit certain information about You back to the partner’s system via API or other data integration in connection with the Services the partner makes available to You. This information may include:

• Financial wellness status indicators (e.g., progress toward savings goals, budget adherence, or financial health scores);Predictive financial alerts (e.g., notifications that You may have insufficient funds to cover upcoming expenses, projected negative cashflow, or upcoming bill payment risks);Engagement or participation indicators (e.g., whether You have activated Your account or completed onboarding); and/or Aggregated or de-identified usage data for program reporting purposes.

The scope of information shared with a partner depends on how You access our Services and the terms of our agreement with that partner, as described further below. Where insights, alerts, or notifications about You are shared with a partner as part of the Services that Finley has agreed to provide to that partner (for example, Your employer or program sponsor) under our agreement with them, that sharing is a required part of the program the partner has made available to You and cannot be disabled through Your account settings. Where a self-service preference is available for a particular integration, we will describe that option in Your account settings, and choosing to opt out of an available preference may limit the functionality of the Services available to You through the partner’s platform.

How We Share Information Through Partner Integrations

In-App or Embedded Delivery. When You receive an insight or recommendation (for example, a suggestion that You could save money by using a specific benefit) within an embedded interface, web view, or widget that is presented through a partner’s platform but rendered by us, the partner does not receive the details of that insight; it is displayed only to You, and the underlying insight data is not transmitted to the partner.

Insight-Level Data Shared via API Integration. When we integrate with a partner’s system via API or similar data integration (for example, with a payroll provider or an employer’s own human resources information system), we may transmit the details of a specific insight or recommendation about You directly to that partner’s system so that the partner can process, display, or otherwise act on that information as part of the Services it makes available to You.

Aggregate Engagement Reporting. We may also share aggregated or de-identified engagement information with a partner that is not tied to Your identity, such as the percentage of a partner’s population that was eligible for a given insight and the percentage that acted on it. We may make this aggregate information available to the partner within our platform, in a report that we prepare, or through another method we determine from time to time, and it will not identify You individually.

How Do We Secure And Protect Your Personal Information

Financial Wellness Labs maintains a comprehensive Information Security Program that employs commercially available physical, administrative and technical safeguards designed to protect your information, including but not limited to:

• Commercially available and sufficient firewalls

• Segmented Data Storage

• Encryption

• Multi-factor authentication

• Policies providing for least privileged access to data across our organization

Unfortunately, however, there is no way to completely eliminate the risk of a data security incident. If we do suffer one that affects any of Your Personal Information, we will report the same to You as per applicable data breach notification laws.

We also ask that You do Your part to keep Your account information safe and secure, by asking that You create a sufficiently complex password for Your account and not share it with third parties, as outlined in our Terms of Service. If You have any questions about the cybersecurity for our Website, You can send an email to help@getfinley.com.

Children’s Personal Information

We do not knowingly collect or solicit Personal Information about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Information. If we learn we have collected Personal Information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Information to us, please contact us at help@getfinley.com.

Do Not Track (“DNT”) Settings

DNT is a setting on some web browsers or mobile devices that can be turned on to instruct websites to disable tracking of Your web browsing activities. DNT is not currently widely adopted and does not have clear standards or guidelines as to how websites are to interpret it. Additionally, its signals can affect the functioning of certain websites. As such, we do not generally respond to these signals.

Third-Party Tracking On Our Website

Third Parties may be using Cookies or other technologies to collect Your personal information as You navigate through the internet including from Our Website. As described above, You may decline these third-party Cookies by changing Your browser settings.

Third-Party Applications And Sites

Our Website may provide links to, or features from, other third-party sites (such as social networks) that we do not own or control. When You visit these third-party sites and decide to share Your Personal Information with them, You are assuming the risk of doing so.

Financial Wellness Labs is not responsible for nor assumes any liability for the privacy practices of websites operated by any third parties, including those that may be linked to our Website, and including the content of those sites. You should check the applicable privacy notice and/or policy of the third-party website or application to understand how it collects and manages any information they collect from You.

As noted in our Terms of Service, Financial Wellness Labs does not endorse or control any other websites or applications besides Our Website, nor does the act of providing a link to a third-party website or application constitute an endorsement, promotion or approval of such website or application.

State Law Privacy Rights

Depending on where You live, Your state may provide You with additional rights relating to Your Personal Information. For example, certain U.S. state laws grant residents rights to access, delete, correct, data portability, and to opt out of “sale,” “sharing,” or “targeted advertising.” As we have described, we may disclose Personal Information to third parties to provide analytics and advertising services. Under some state laws, such disclosures may be a “sale” or “sharing.” You can opt out by using a cookie settings tool or via a GPC signal. Please note that if You exercise Your right to delete Your Personal Information under applicable state privacy laws, we will fully delete Your data from our systems (subject to any legal retention requirements), which is different from simply excluding an account from Your dashboard. Excluding an account hides it from Your view but does not delete the underlying data. To ensure full deletion of Your Personal Information, You must submit a verified deletion request as described in this Policy.

California Shine The Light Law

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.

We do not sell, rent, or otherwise share Your data to any third party in exchange for monetary or other valuable consideration under any circumstances. If You are a California resident and want submit a request, please contact us at help@getfinley.com. We will verify Your identity before processing Your request and may require additional information to do so. You may also designate an authorized agent to make requests on Your behalf.

Nevada Residents’ Privacy Rights

We do not sell, rent, or otherwise share Your data to any third party in exchange for monetary or other valuable consideration under any circumstances unless You specifically consent to such disclosure. Pursuant to Section 603A of the Nevada Revised Statutes, residents of Nevada may, at any time, submit a request to an operator of a website in Nevada directing the operator not to make any sale of any personal information the operator has collected or will collect about the consumer.

If You are a Nevada resident and want to opt out of the sale of any personal information, please submit an email request to help@getfinley.com. In Your request, please specify that You want to “Opt-Out of Sale of Personal Information in Nevada.” Please allow 60 days for a response.

New York Residents’ Privacy Rights

We have implemented a cybersecurity program which includes reasonable administrative, technical, and physical safeguards to protect the private information of New York residents, as required by the NY SHIELD Act and will comply with all applicable data breach notification requirements.

Other States’ Residents’ Privacy Rights

Depending on Your state of residence, You may have additional rights regarding Your personal information. We will comply with all applicable state privacy laws, including those in Colorado, Connecticut, and Virginia.

How To Opt Out

You can always opt out from receiving marketing communications by following the unsubscribe instructions provided in each communication. If You have an online account with us, You may be given the option to change some of Your communication preferences under the relevant “My Account” section of our site or by calling Customer Service.

Please note that even if You opt-out from receiving marketing communications, You may still receive other communications from us, such as notifications about account activities (e.g., account confirmations, password changes, etc.) and other important announcements (e.g., privacy policy changes, security notices, etc.).

You can also opt out of our Marketing Communications and otherwise exercise Your privacy rights by emailing us at: help@getfinley.com.

Changes To This Policy

We’re constantly improving our Services, so we may need to update this Privacy Policy from time to time. We will alert You to any material updates by sending You an email. For non-material updates we will place a notice on our Website. Please note that if You’ve opted not to receive legal notice emails from us (or You haven’t provided us with Your current email address) we will be unable to provide you with email notice. The updated Privacy Policy will still govern Your use of the Services, and You are still responsible for reading and understanding it. If You use the Services after any updates to the Privacy Policy have been posted, that means You agree to all of the updates. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected

Contact Us

If you have any questions or comments about this Policy, the ways in which we collect and use your Personal Information or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Email: help@getfinley.com

Phone: 855-843-5233

Mail: Financial Wellness Labs, Inc., 4 W Palisade Ave #1210, Englewood, NJ 07631