FINMASON, INC.

Last Updated: June 12, 2017

FinMason, Inc. (“FinMason,” “we,” or “us”) respects the privacy of its users and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully. By using our free website, mobile application, platforms, tools, products and/or services (collectively, the “Platform”), you are accepting the practices described in this Privacy Policy. Premium fee-based products and/or services are covered under separate agreements.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

1. Information we collect about you

   In General.
   We may collect information that can identify you such as your name and email address (“personal information”) and other information that does not identify you. When you provide personal information through our Platform, the information may be sent to servers located in the United States and other countries around the world.

   • Information you provide.
     We may collect and store any personal information you enter on our Platform or provide to us in some other manner. This includes identifying information, such as your name, address, email address, and telephone number.
   • Information from other sources.
     We may periodically obtain both personal and non-personal information about you from third parties and add it to our account information or other information we have collected.
   • Account Credentials and Account Information
     In order to benefit from the full functionality of the Service, you also must provide your third-party account credentials (“Account Credentials”) to allow FinMason to access your account data at those other financial institutions (“Account Information”) for your use.

   Use of cookies and other technologies to collect information.
   We use various technologies to collect information from your computer and about your activities on our Platform.

   • Information collected automatically.
     We automatically collect information from your browser when you visit our Platform. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see “Cookies and Similar Technologies” below), and the referring website address.
   • Cookies and Use of Cookie Data.
     When you use our Platform, we may assign your computer one or more cookies, to facilitate access to our Platform and to personalize your online experience. Through the use of a cookie or similar technologies, we also may automatically collect information about your online activity on our Platform, such as the web pages you visit, the time and date of your visits, the links you click, and the searches you conduct on our Platform. During your visits to other websites where we advertise, we (or third parties) may use certain data collected on our Platform to show you the type of advertisements likely to be of greater interest to you. Although you may not opt out of receiving online advertisements generally, you may control the collection of data on our Platform used for targeted advertising during your visits to other websites. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Platform.
   • Other Technologies.
     We may use standard internet technology, such as web beacons and other similar technologies, to track your use of our Platform. We also may include web beacons in advertisements or email messages 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 our visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
   • Information collected by third-parties.
     We may allow third-parties, including our authorized service providers, advertising companies and ad networks, to display advertisements on our Platform. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our Platform does not provide any personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).
2. How we use the information we collect

   In General.
   We may use information that we collect about you to:

   • deliver the services that you have requested;
   • manage your account and provide you with customer support;
   • perform research and analysis about your use of, or interest in, our services or content, or services or content offered by others;
   • communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
   • develop and display content and advertising tailored to your interests on our Platform and other sites;
   • enforce or exercise any rights in our terms and conditions;
   • manage our business;
   • provide FinMason advertisements to you when you visit other sites; and
   • perform functions as otherwise described to you at the time of collection.

   Please review “Your choices about collection and use of your information” below.

3. With whom we share your information

   Personal information.

   We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:

   • Service providers:
     We may share your personal information, which may include your name and contact information (including email address) with third parties that perform certain services on our behalf. These services may include providing customer service and marketing assistance, performing business analysis, member screenings, supporting our Platform functionality, and supporting other features offered through our Platform. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
   • Business partners:
     When you register on our Platform or click-through our advertisements offered on third party websites, we may share personal information with the businesses with which we partner to offer you the applicable products, services or any advertisements. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant. To opt-out of cookies that may be set by third party data or advertising partners, please go to http://www.aboutads.info/choices/.
   • Other Situations.
     We also may disclose your information, including 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.
     • When 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 users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Platform terms and conditions or other agreements or policies.
     • In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

     Aggregated and/or non-personal information.
     We may share non-personal information we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on our Platform and on websites of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other business purposes.

4. Third-party websites

   There are a number of places on our Platform where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement on our website, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy” link typically located at the bottom of the webpage you are visiting.

5. How you can access your information

   If you have an online account with us, you have the ability to review and update your personal information online by logging into your account and clicking on your account settings. More information about how to contact us is provided below. If you have an online account with us, you also may close your account at any time by visiting the “Account Settings” page for your account. After you close your account, you will not be able to sign in to our Platform or access any of your personal information. However, you can open a new, separate account at any time or re-activate your previous account by following instructions we will give you at the time you close your account. If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Platform or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

6. Your choices about collection and use of your information
   • You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Platform because such information may be required in order for you to register as a member; use certain products and/or services; or initiate other transactions on our Platform.
   • When you register on our Platform, you will consent, or be given a choice as to whether you want, to receive email messages from us about special offers. You also will be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future. It may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship email communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party (such as a service provider) before you have changed your preferences or updated your information, you may have to change you preferences directly with that third party.
   • You can also control information collected by cookies. See “Cookies and Similar Technologies” below for information about declining or deleting cookies.
7. How we protect your personal information

   We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information, Account Credentials and Account Information from unauthorized access and disclosure. We want you to feel confident using our Platform. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

8. Information you provide about yourself while using our service

   We provide areas on our Platform where you can post information about yourself and others and communicate with others or upload content. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

9. Children’s privacy

   Although our Platform is a general audience site, we restrict the use of our service to individuals age 18 and above. We do not knowingly collect personal information from children under the age of 13.

10. Visiting our Platform from outside the United States

    If you are visiting our Platform from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.

11. No Rights of Third Parties

    This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Platform.

12. Changes to this Privacy Policy

    We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check our Platform from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

13. Linked information:

    Cookies and Similar Technologies:

    For example, when you sign in to our Platform, we will record your user or member ID and the name associated with your user or member ID in the cookie file on your computer. We also may record your password in this cookie file, if you indicated that you would like your password saved for automatic sign-in. For security purposes, we will encrypt any usernames, passwords, and other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our Platform to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our Platform, content and advertising.

    You may delete or decline cookies by changing your browser settings. (Click “Help” in the toolbar of most browsers for instructions.) If you do so, some of the features and services of our Platform may not function properly.

    We may allow third-parties, including advertising companies, and ad networks, to display advertisements on our Platform. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our Platform does not provide any personal information to these third parties, but they may collect information about where you, or others who are using your computer, saw and/or clicked on the advertisements they deliver (such as click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, etc.), and possibly associate this information with your subsequent visits to the advertised websites. They also may combine this information with personal information they collect from you to provide advertisements about goods and services likely to be of greater interest to you. The collection and use of that information is subject to the third-party’s privacy policy. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies and provides information about this behavioral advertising practice ( www.networkadvertising.org). This policy covers the use of cookies by FinMason only and does not cover the use of cookies by any advertisers.

    Opting-Out of Advertising Cookies.
    You may opt out of our data collection for use by third party ad companies to provide targeted advertising to you when you visit other sites. Cookies are unique to each computer. Therefore, you must opt out separately on all computers you use. If you delete all of your cookies (specifically, the “Opt-Out” cookie), you will have to go through the opt-out process again to reactivate your opted-out status.

    Web Beacons:

    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 the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in email) 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 users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our Platform from an online advertisement displayed on a third-party website. Third parties may use anonymous information about your visits to our Platform and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you.

    This website uses Google AdWords

    This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the FinMason, Inc. website. Of course, any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.

    You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

    How to contact us

    If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us by mail as follows:

    FinMason, Inc
    One Boston Place
    26th floor
    Boston, MA 02108