Privacy Policy

Last updated: July 12, 2026

Please read these Terms and Conditions carefully before using Our Service.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application refers to Inflows, the software program provided by the Company.

Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Essayas Investments LLC, 447 Sutter Street, Suite 405, CA 94108.

For the purposes of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Analytics means features, dashboards, reports, metrics, benchmarks, insights, or related tools that help approved firms or Authorized Firm Users understand activity, engagement, content performance, relationship activity, audience composition, employee activity, and similar activity on the Service.

Analytics Data means information collected, generated, inferred, or processed in connection with Analytics, including views, profile visits, reactions, comments, event RSVPs, conversation participation, content engagement, timestamps, source and target content identifiers, user identifiers, company identifiers, firm affiliation, professional profile information, geography, firm type, AUM or fund range, engagement categories, relationship metrics, content performance metrics, employee metrics, Peer Benchmarks, and related metadata.

Authorized Firm User means a user who is authorized by a firm, provider, or other organization to access Analytics or other firm level features through the Service.

Firm Analytics means Analytics made available to an approved firm or Authorized Firm User regarding activity connected to that firm’s content, employees, representatives, events, profiles, Marketplace activity, or other activity on the Service.

Peer Benchmarks means aggregated, deidentified, or otherwise limited analytics that compare one firm’s activity or performance to a peer group, category, market segment, or other comparison group.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: California, United States Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

Attachment means any image, media, file, or other content that You upload, send, receive, or otherwise provide through the Service, including through Direct Messaging.

Direct Message means a private user to user communication sent or received through the Service after a Message Request has been accepted.

Direct Messaging means the feature within the Application that allows users to send Message Requests, accept or decline Message Requests, and exchange Direct Messages and Attachments through the Service.

Message Request means a request from one user to another user to start a Direct Message conversation.

Marketplace means the gated directory within the Service where approved Inflows users may discover approved third party service providers relevant to financial advisors and wealth management firms.

Marketplace Inquiry means a connection inquiry, request for information, or similar submission sent by a user to a Marketplace Provider through the Marketplace.

Marketplace Provider means a third party service provider, vendor, business, or provider representative that applies to, is approved for, is listed in, or participates in the Marketplace.

Provider Portal means the separate portal or administrative experience through which Marketplace Providers may apply to participate in the Marketplace, maintain profile details, manage contact information, view payment status, and access receipts or related Marketplace administration features.

Review means a rating, review, testimonial, comment, feedback, or similar Marketplace submission about a Marketplace Provider or its services.

Referral Post means a text based post, request, recommendation, or related submission made through the Service to seek, offer, or facilitate professional introductions, referrals, centers of influence, or related networking opportunities among approved members.

Referral Post Response means a comment, response, expression of interest, Direct Message initiation, or similar interaction with a Referral Post.

Recommended Professional means a third party professional or center of influence, such as an attorney, accountant, insurance professional, mortgage professional, business broker, consultant, or other professional whose work contact information or professional details may be submitted through a Referral Post or related feature.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

GDPR refers to EU General Data Protection Regulation.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Service refers to the Application or the Website or both.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Inflows, accessible from https://www.inflows.com You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address First name and last name Phone number Address, State, Province, ZIP/Postal code, City Account profile information and professional information You choose to provide, such as firm, title, role, and professional affiliation Direct Messages, Message Requests, Attachments, reports, and related metadata if You use Direct Messaging Notification preferences, device tokens, routing information, and other information used to deliver notifications Marketplace information, including provider applications, provider profile information, business contact information, services, service categories, displayed pricing, subscription and payment status, receipts, approval or delisting status, Marketplace searches, provider profile views, Marketplace Inquiries, Reviews, access eligibility, feature flag information, and related metadata if You use or participate in the Marketplace Provider Portal information, including information submitted by Marketplace Providers or provider representatives, such as name, business name, role, email address, phone number, website, profile content, service descriptions, and other information they choose to provide Referral Post information, including structured dropdown or selection field responses, free form descriptions, client or prospect situation descriptions, professional referral needs, life stage or planning context, geography, age range, asset range, AUM range, business sale information, tax considerations, retirement status, marital or family status, profession, business ownership, Referral Post Responses, comments, Direct Message creation activity, Recommended Professional contact information, and related metadata if You use Referral Posts or related features

Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Pictures and other information from your Device’s camera and photo library We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Direct Messaging and User Communications

When You use Direct Messaging, We may collect, store, process, and transmit information necessary to provide the feature, including:

• Direct Message text and conversation content
• Message Requests, acceptance status, decline status, and related request handling information
• Attachments, including image attachments and related file information
• participants, account identifiers, profile information, and contact information for conversation participants
• timestamps, delivery information, read status if available, loading state information, routing information, and other interaction information
• reports, blocks, support records, safety review records, and moderation or enforcement records
• notification routing information, device tokens, message type, sender information, and message preview information if notifications are enabled Direct Messages are not public areas of the Service. Direct Messages are intended to be visible to the users participating in the conversation. However, Direct Messages, Attachments, and related metadata may be stored by Inflows and may be accessed by Inflows and Our Service Providers as necessary to provide the Service, deliver notifications, maintain security, investigate reports, enforce Our Terms, comply with law, respond to valid legal process, or protect rights, property, and safety.

We do not review all Direct Messages before they are sent. We may access, review, preserve, remove, or disclose Direct Messages, Attachments, and related metadata when necessary to operate the Service, investigate abuse or security issues, respond to user reports, enforce Our Terms, protect users or the public, comply with legal obligations, or protect the rights and property of Inflows.

Notifications related to Direct Messaging may distinguish between a new Message Request, an accepted request, and a Direct Message. Depending on Your device settings and Our product design, notifications may include the sender name, profile information, message type, message preview, or routing information. You can manage certain notification preferences through the Application or Your Device settings.

Attachments may contain sensitive information or metadata, such as screenshots, documents, faces, locations, business information, or other information You choose to include. Users should not send information they are not authorized to share. Recipients may save, copy, screenshot, download, forward, or disclose Direct Messages and Attachments outside the Service, and Inflows cannot control recipient actions outside the Service.

The Service is intended for professional networking and platform communication. Users are responsible for determining whether their Direct Messaging activity must be supervised, archived, exported, retained, or otherwise handled under laws, regulations, employer policies, or professional obligations that apply to them. Users should not use Direct Messaging to send confidential client information, nonpublic personal information of clients or other third parties, trade orders, instructions regarding funds or securities, client specific investment advice, securities recommendations, or information that violates a law, regulation, firm policy, or professional obligation.

Marketplace

Inflows may offer a gated Marketplace where approved Inflows users can discover approved third party service providers relevant to financial advisors and wealth management firms. Marketplace access may depend on Your login status, user approval status, email verification status, allowlist status, feature flag eligibility, provider approval status, and other eligibility or configuration data.

If You use the Marketplace as an Inflows user, We may collect and process information related to Your Marketplace activity, including search terms, browsing activity, category filters, provider profile views, clicks, Marketplace Inquiries, Review submissions, ratings, reports, support communications, and related metadata.

If You are a Marketplace Provider or provider representative, We may collect information You submit through the Provider Portal or otherwise provide to Us, including Your name, business name, role, email address, phone number, website, business description, service categories, service descriptions, contact details, displayed pricing, profile content, logo or images if provided, application information, approval or delisting status, subscription and payment status, receipts, Stripe customer or subscription identifiers, and related administrative information.

We do not collect Tax ID or EIN information through the Provider Portal unless We separately request and disclose such collection.

Approved Marketplace Provider profile information may be displayed to approved, logged in Inflows users who have access to the Marketplace. This may include the provider’s With approved members through Referral Posts: Referral Posts and related comments may be visible and searchable to approved members of the Service who have access to the applicable feature. Referral Post Responses may be shared with the original posting user. If users express interest in connecting through a Referral Post, a Direct Messaging conversation may be created or enabled between those users, and each participant may see profile information associated with the other participant.

With requesting advisors and approved users for Recommended Professionals: If a user recommends a Recommended Professional or center of influence, We may share that professional’s name, work email address, work phone number, business name, role, professional category, and related professional information with the requesting advisor or other approved users who can access the relevant Referral Post or related feature.

business name, representative or contact information, description, categories, services, displayed pricing, Reviews, and other profile information submitted by the Marketplace Provider. Marketplace Provider profile information is not treated as private once published within the Marketplace, and users who view it may copy, save, screenshot, or share it outside the Service.

If You submit a Marketplace Inquiry, We may share Your inquiry, contact information, Account profile information, firm or professional information, and any information You include in the inquiry with the Marketplace Provider so the provider can respond to You.

Marketplace Providers are independent third parties and may process information they receive from You according to their own privacy practices. You should not include confidential client information, nonpublic personal information, or information You are not authorized to share in a Marketplace Inquiry.

If You submit a Review, rating, or other Marketplace feedback, We may collect, display, moderate, remove, retain, and associate that Review with Your Account, name, profile, firm, or other identifying information depending on how the feature is designed. Reviews may be visible to Marketplace users, the reviewed Marketplace Provider, and Inflows administrators.

We may use feature flags, allowlists, approval status, email verification status, provider subscription status, and similar configuration data to determine whether You can access Marketplace features and whether Marketplace Provider profiles should be visible. Provider payment status may be tracked for subscription administration, but Marketplace listing visibility may also depend on approval status, feature availability, and other product rules.

We use Marketplace information to operate and improve the Marketplace, review and approve providers, delist providers where appropriate, manage provider listings, process Marketplace Inquiries, manage subscriptions and receipts, display Reviews, prevent fraud or abuse, enforce Our Terms, provide support, maintain Marketplace trust and quality, and comply with legal obligations.

Referral Posts

Inflows may offer Referral Posts as a Marketplace adjacent professional networking and introduction feature. Referral Posts allow approved members to publish, search, comment on, respond to, and connect around professional referral or introduction opportunities relevant to financial advisors, wealth management firms, and related professionals.

Referral Posts are text only and may include structured dropdown or selection fields and limited free form descriptive text. Information submitted through Referral Posts may include professional, financial, demographic, or situational information relating to clients, prospects, businesses, Recommended Professionals, or other third parties, including age range, geography, retirement status, marital or family status, profession, business ownership, business sale activity, tax considerations, investment objectives, asset range, AUM range, or other life stage or financial planning related information.

Users are instructed not to include names, email addresses, phone numbers, account numbers, Social Security numbers, tax records, medical records, trade instructions, nonpublic personal information, or other directly identifying information about clients or prospects in Referral Posts. Referral Posts do not include fields for client names, client email addresses, or client phone numbers. However, users may voluntarily include information in free form text fields that could relate to, describe, or allow inferences about third parties.

Referral Posts and related comments may be visible and searchable to approved members of the Service who have access to the applicable feature. Referral Post Responses may be shared with the original posting user. If users express interest in connecting through a Referral Post, the Service may create or enable a Direct Messaging conversation between those users, and each participant may see profile information associated with the other participant as part of that interaction.

Inflows may also permit users to recommend outside professionals or centers of influence, including attorneys, accountants, insurance professionals, mortgage professionals, business brokers, consultants, or other professionals. If a user recommends a Recommended Professional, Inflows may collect and share the Recommended Professional’s name, work email address, work phone number, business name, role, professional category, and related professional information with the requesting advisor or other approved users who can access the relevant Referral Post or related feature.

Referral Posts are intended for professional networking and introductions only. Inflows does not facilitate referral compensation, solicitation payments, securities transactions, advisory agreements, client engagements, or referral fee arrangements through Referral Posts.

Users may request deletion or removal of Referral Posts or related information by contacting the Company. Non user third parties, including end clients, prospects, or Recommended Professionals, may also request removal of their information by contacting the Company through the contact methods described in this Privacy Policy.

Earnings Prediction Polls

Inflows may offer Earnings Prediction Polls that allow approved members to create and vote on anonymous polls concerning whether a public company will Beat, be In-line with, or Miss analyst consensus earnings per share for an upcoming earnings report. Poll creators provide the company ticker. Company information, market price information, analyst consensus estimates, earnings dates, reporting timing, fiscal period information, and reported earnings information may be supplied by a third party market data provider.

When You vote in an Earnings Prediction Poll, We may collect and store Your user identifier, prediction choice, professional or firm type segment, vote timestamp, and related poll and baseline information. Individual votes are not displayed to other users and are processed by Inflows and Our Service Providers as necessary to operate, secure, resolve, and administer the feature.

We may derive and maintain a prediction record associated with Your Account based on Your Earnings Prediction Poll activity. A prediction record may include the polls in which You participated, the relevant company or ticker, Your prediction, the reported outcome, whether Your prediction was correct, resolution dates, total predictions, correct predictions, accuracy, current and best streaks, professional or firm type cohort, cohort percentile, rankings, leaderboard position, and similar prediction or participation metrics.

Prediction records and individual prediction histories are not currently displayed to other users. Inflows may introduce features that display certain prediction metrics, rankings, streaks, percentiles, leaderboard positions, or similar information to other approved members in the future. If such features are enabled, We may provide additional notice or controls where required by applicable law.

Earnings Prediction Poll results may be displayed in aggregate and may be segmented by professional or firm type. Individual voter names and individual votes are not displayed as part of poll results. To reduce the risk of identifying individual voters from small groups, segmented results are displayed only when the applicable segment meets a minimum threshold of at least three votes. Before a poll closes, results may be available after You vote. After a poll closes, final aggregated results may be available to approved members who did not vote.

Earnings Prediction Polls are anonymous to other users by design. The identity of a poll creator may be stored by Inflows for account administration, security, moderation, enforcement, legal, audit, and operational purposes, but is not displayed with the poll to other users. Polls may be excluded from author based profile listings and other features that would identify the poll creator.

When a poll resolves, We may use reported earnings information to determine the outcome and update prediction records, aggregate results, and related metrics. We may send notifications to participating users regarding poll status, upcoming resolution, final outcomes, or their prediction results. Such notifications may be associated with Your Account but are intended for You and are not used to identify the poll creator to other users.

Market data used in Earnings Prediction Polls may be obtained from a third party market data provider. Market data may be delayed, incomplete, unavailable, or inaccurate. We process such data to operate the poll feature, populate poll information, resolve outcomes, and provide related records, results, and notifications.

You may contact Us using the methods described in this Privacy Policy to exercise privacy rights available under applicable law with respect to Fund Intelligence activity and related behavioral or usage data, including rights of access, correction, deletion, or objection where applicable. These rights may be subject to legal exceptions and retention obligations, including the five year archival period described above.

We may retain Fund Intelligence questions, usage records, derived analytics, summaries, clustering or cache information, and Asset Manager Dashboard records for as long as reasonably necessary to provide and improve the features, maintain historical analytics, administer paid access, maintain security, prevent abuse, resolve disputes, enforce Our Terms, satisfy legal, regulatory, audit, backup, archiving, and recordkeeping obligations, and maintain business records. Records associated with a deleted Account may be retained for up to five years for archiving and related compliance or recordkeeping purposes, subject to applicable law. Wholesaler and sales contact records may be retained while needed to provide the dashboard or related representative matching features and for applicable legal, audit, backup, or recordkeeping purposes.

The Asset Manager Dashboard may allow an asset manager or its authorized users to provide and maintain contact information for wholesalers, sales representatives, or other firm personnel, including name, business email address, business phone or mobile number, title, channel, sales region, and related professional information. We may use this information to administer the dashboard and to identify or display an appropriate wholesaler or representative to users who ask Fund Intelligence or related features who their representative is.

Wholesaler and Sales Contact Information

Access to Asset Manager Dashboard analytics may be limited to authorized users of an asset manager and to funds within that firm’s approved scope. We may determine eligibility, access, scope, and feature availability based on firm affiliation, administrative provisioning, payment status, feature configuration, and other criteria.

Inflows does not intend to display verbatim Fund Intelligence questions to asset managers as part of the Asset Manager Dashboard. We may process question text internally and through Service Providers to generate summarized or derived insights. We may use aggregation, summarization, clustering, suppression, access controls, or other measures where We determine appropriate to protect privacy, data quality, confidentiality, or platform integrity.

Asset Manager Dashboard analytics may include aggregated or summarized question themes, research topics, content gaps, session and engagement statistics, activity patterns, source document usage, and the names of firms researching an asset manager’s funds. The dashboard is not intended to identify the individual professional who asked a particular question, and Inflows does not intend to display an individual user’s question history to asset managers. Asset managers may nevertheless be able to infer information about individuals in some circumstances, particularly where a firm has a small number of users or activity is limited.

We may use Fund Intelligence activity to generate analytics, summaries, trends, topic groupings, content gaps, engagement measures, and other research insights. Access to certain Asset Manager Dashboard analytics is a paid service that Inflows may sell to asset managers. Accordingly, research activity by eligible professional users may contribute to commercial analytics and insights made available to the asset manager associated with the funds being researched.

Fund Intelligence is not a confidential channel for client or third party information. You should not submit client names, account information, nonpublic personal information, confidential information, trade instructions, or other information that You are not authorized to disclose. We may display an in product notice stating: Research activity may contribute to insights shared with asset managers. Do not include client or confidential information.

When You use Fund Intelligence, We may collect and store information about Your research activity, including Your user identifier, firm or company affiliation, professional or firm type, the fund You research, Your question text, classified topic or intent, whether the system was able to answer the question, session and turn identifiers, source citations, timestamps, and related usage information. Question text may be stored substantially as You submit it, subject to technical limits.

Inflows may provide Fund Intelligence, an artificial intelligence assisted research feature that allows eligible professional users to ask questions about investment funds using information derived from public SEC filings and public firm materials, such as fact sheets, prospectuses, commentaries, presentations, and fund literature. Fund Intelligence answers are generated or synthesized from available source materials and may be processed by third party artificial intelligence service providers.

Fund Intelligence and Asset Manager Dashboard

Inflows Analytics

Inflows may provide Analytics to approved firms and Authorized Firm Users to help them understand engagement with their content, employees, representatives, events, profiles, Marketplace activity, and other activity on the Service.

When You use the Service, We may collect, store, process, and use Analytics Data, including post views, profile visits, reactions, comments, event RSVPs, conversation participation, content engagement, source and target content identifiers, timestamps, user identifiers, company identifiers, firm affiliation, professional profile information, geography, firm type, AUM or fund range, audience segments, engagement categories, relationship metrics, content performance metrics, employee metrics, Peer Benchmarks, and related metadata.

Inflows Analytics is a core feature of the Service. Analytics tracking may occur automatically when You use the Service, including when You view posts, visit profiles, react to content, comment, RSVP to events, participate in conversations, interact with employees or representatives of a firm, or otherwise engage with content, profiles, events, or activity on the Service.

If You interact with another firm’s content, employees, representatives, events, profiles, Marketplace activity, or other activity on the Service, information about Your activity may be included in Analytics made available to that firm or its Authorized Firm Users. Analytics may show named firms, firm segments, geography, professional categories, AUM or fund ranges, engagement levels, content performance, relationship activity, and similar business insights.

We do not intend to show outside firms the names of individual users in Analytics. However, Analytics may show the name of the firm associated with a user, and in some cases firm level information may allow a recipient to infer information about users associated with smaller firms. We may use thresholds, aggregation, delay, suppression, or other controls where We determine they are appropriate to protect privacy, discretion, data quality, or platform integrity.

Authorized Firm Users may be able to view Analytics related to their own firm’s employees, representatives, authors, content, events, relationship activity, and use of the Service. For example, a firm may be able to see employee level performance, content engagement, relationship activity, rankings, or other Analytics for users associated with that firm.

Profile visits may be included in Analytics. This means that when You visit a profile, interact with a profile, or engage with content connected to a profile or firm, that activity may be included in Analytics shown to the relevant firm or Authorized Firm Users. Outside firms will not be shown Your individual name in Analytics, but Your firm, segment, geography, or other profile attributes may appear.

We may assign users, firms, or activity to engagement categories or audience segments, such as frequent engagement, passive engagement, or similar categories, based on activity on the Service. We use these categories to provide Analytics, relationship insights, audience insights, content performance metrics, and similar features. We do not intend for Analytics or engagement categories to be used for credit, employment, insurance, housing, lending, eligibility, supervisory approval, or similarly significant decisions.

If sentiment or content insight features are enabled, We may process reactions, ratings, comments, posts, or other content signals to generate audience or content performance insights. If such analysis uses message content, comment text, or other user generated text, We may process that content for the limited purpose of providing Analytics, maintaining trust and safety, enforcing Our Terms, improving the Service, and complying with legal obligations.

Peer Benchmarks may be based on aggregated, deidentified, or otherwise limited information from participating firms, users, content, events, or activity on the Service. We may apply minimum thresholds, peer set rules, aggregation, delay, suppression, or other controls to reduce the risk that a user or firm can be identified from a benchmark. We may change benchmark methodology, peer sets, thresholds, availability, and reporting rules at any time.

We do not currently provide a product level setting to opt out of inclusion in Inflows Analytics, except where required by applicable law. You may still exercise any privacy rights available to You under applicable law, including rights to access, correct, delete, object to processing, or opt out of certain sales or sharing where those rights apply.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies We use include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.

However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies on TermsFeed website article.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or functionality of the Website to see how our users react to them.

Targeting and Advertising Cookies Type: Persistent Cookies Administered by: Third Parties Purpose: These Cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest to You. These Cookies use information about your browsing history to group You with other users who have similar interests.

Based on that information, and with Our permission, third party advertisers can place Cookies to enable them to show adverts which We think will be relevant to your interests while You are on third party websites.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

To provide Direct Messaging: To process Message Requests, accepted conversations, Direct Message text, Attachments, notifications, delivery information, reports, and related metadata; to route users to the relevant messaging or request area; to provide loading states and status information; and to support reporting, safety, and support features.

To provide and administer the Marketplace: To review Marketplace Provider applications, approve or delist Marketplace Providers, display Marketplace Provider profiles, enable Marketplace search and browsing, process Marketplace Inquiries, display Reviews, manage provider subscriptions, support the Provider Portal, and maintain Marketplace trust, safety, and quality.

To manage Marketplace access: To determine Marketplace eligibility and feature availability based on login status, user approval status, email verification status, allowlist status, feature flag eligibility, provider approval status, provider subscription or payment status, and similar configuration information.

To communicate about Marketplace activity: To contact users and Marketplace Providers about applications, approvals, delistings, Marketplace Inquiries, Reviews, subscriptions, receipts, payment status, support, policy enforcement, and Marketplace updates.

To provide and administer Referral Posts: To enable approved members to create, search, view, comment on, respond to, and connect through Referral Posts; to process structured referral fields, limited free form descriptions, Referral Post Responses, Recommended Professional information, comments, expressions of interest, Direct Message creation, expiration, hiding, moderation, support, safety, and related metadata; and to maintain the Referral Posts feature as a Marketplace adjacent professional networking and introduction feature.

To provide Analytics: To collect, process, generate, display, and maintain Analytics, Firm Analytics, Peer Benchmarks, audience insights, content performance metrics, relationship metrics, profile visit metrics, employee metrics, engagement categories, sentiment or content insights, and similar reporting features for approved firms and Authorized Firm Users.

To provide firm and relationship insights: To help approved firms and Authorized Firm Users understand engagement with their content, employees, representatives, events, profiles, Marketplace activity, and other activity on the Service, including by showing named firms, firm segments, geography, professional categories, AUM or fund ranges, engagement levels, and related metrics.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, subscriptions, provider participation, or services You have purchased or of any other contract with Us through the Service, including Marketplace provider subscriptions and related administration.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications, regarding updates, security updates, message requests, accepted Direct Messaging requests, new messages, Marketplace applications, Marketplace Inquiries, Reviews, subscriptions, receipts, payment status, and other informative communications related to the functionalities, products or contracted services, when necessary or reasonable for their implementation.

To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

To maintain safety and enforce Our policies: To detect, prevent, investigate, and respond to spam, harassment, abuse, security incidents, policy violations, unlawful activity, and other misuse of the Service, including through review of reported Direct Messages, Marketplace Inquiries, Reviews, Marketplace Provider profiles, and related metadata.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to host and store data, process Attachments, operate the Marketplace, manage the Provider Portal, support search and browsing, manage feature flags and allowlists, deliver notifications, monitor and analyze the use of Our Service, show advertisements to You to help support and maintain Our Service, process payments and subscriptions, contact You, provide support, maintain security, debug issues, prevent abuse, and administer Marketplace features.
• We do not share Direct Message content or Attachments with advertising Service Providers for cross context behavioral advertising.
• We do not share Marketplace Inquiries, provider application data, provider subscription records, provider payment records, or Reviews with advertising Service Providers for cross context behavioral advertising.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With Marketplace Providers: If You submit a Marketplace Inquiry or otherwise choose to interact with a Marketplace Provider, We may share Your inquiry, contact information, Account profile information, firm or professional information, and any information You include in the inquiry with that Marketplace Provider so the provider can respond to You.
• With Marketplace users: Approved Marketplace Provider profile information and permitted Reviews may be visible to approved, logged in Marketplace users who have access to the Marketplace.
• With payment processors: If You are a Marketplace Provider who pays to participate in the Marketplace, We may share payment and subscription related information with Our payment processor and receive payment status, subscription status, customer identifiers, receipts, webhook events, and related transaction information needed to administer provider participation.
• With other users: when You share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside. Direct Messages are not public areas of the Service. Direct Messages are visible to the users participating in the conversation, and a recipient may save, copy, screenshot, download, forward, or disclose Direct Messages and Attachments outside the Service. Marketplace Provider profile information and permitted Reviews may be visible within the gated Marketplace and may be copied, saved, screenshotted, or shared by users outside the Service.
• With firms receiving Analytics: If You interact with another firm’s content, employees, representatives, events, profiles, Marketplace activity, or other activity on the Service, We may make certain Analytics available to that firm and its Authorized Firm Users. These Analytics may include named firm information, firm segments, geography, professional categories, AUM or fund ranges, content engagement, profile visit activity, event activity, relationship activity, and related metrics. We do not intend to show outside firms Your individual name in Analytics.
• With Your firm: If You are associated with a firm, We may share Analytics related to Your use of the Service, content, posts, events, profile, relationship activity, employee activity, and other firm related activity with Authorized Firm Users at Your firm.
• With Service Providers supporting Analytics: We may share Analytics Data with Service Providers that help Us host, store, process, secure, analyze, aggregate, deidentify, display, maintain, debug, and improve Analytics and related Service features.
• With peer benchmark participants: We may use aggregated, deidentified, or otherwise limited Analytics Data to provide Peer Benchmarks, comparison metrics, methodology reports, and similar insights to participating firms or Authorized Firm Users.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.

Retention of Direct Messages and Attachments

We may retain Direct Messages, Message Requests, Attachments, and related metadata for as long as Your Account is active, for as long as needed to provide Direct Messaging, or for as long as needed for the purposes described in this Privacy Policy. We may retain this information longer where necessary to comply with legal obligations, resolve disputes, enforce Our Terms, maintain security, preserve evidence of abuse, prevent fraud, satisfy backup and audit requirements, or protect rights and safety.

Deletion of a message or Account may not immediately delete all copies from active systems, backups, logs, legal holds, safety records, or records maintained for dispute resolution or compliance purposes. Some Direct Messages may remain visible to other conversation participants unless and until product controls remove them for those participants.

Retention of Marketplace Information

We may retain Marketplace information, including provider applications, provider profile information, approval and delisting records, Marketplace Inquiries, Reviews, search and browsing activity, provider profile views, subscription and payment status, receipts, Stripe customer or subscription identifiers, webhook events, feature flag and allowlist records, support records, and related metadata for as long as necessary to provide and administer the Marketplace or for the purposes described in this Privacy Policy.

We may retain Marketplace information longer where necessary to maintain provider listings, administer subscriptions, process inquiries, display Reviews, resolve disputes, enforce Our Terms, prevent fraud or abuse, comply with accounting, tax, legal, regulatory, backup, audit, and recordkeeping obligations, or protect rights, property, and safety.

Retention of Referral Post Information

We may retain Referral Post information, including structured field responses, free form descriptions, Referral Post Responses, comments, Recommended Professional information, Direct Message creation activity, expiration status, hiding status, moderation records, reports, support records, and related metadata for as long as necessary to provide and administer Referral Posts or for the purposes described in this Privacy Policy.

Referral Posts may expire or become hidden after a period of time determined by the Company. Expired, hidden, declined, or closed Referral Posts may no longer be visible through standard user interfaces but may remain retained for internal business, legal, audit, abuse prevention, compliance, dispute resolution, backup, security, product integrity, or recordkeeping purposes as permitted by applicable law and this Privacy Policy.

Direct Messaging conversations created or enabled through Referral Posts may be retained according to the Direct Messaging retention terms described in this Privacy Policy.

Retention of Earnings Prediction Poll Information

We may retain Earnings Prediction Poll information, including poll records, individual vote records, prediction histories, accuracy metrics, streaks, professional or firm type cohorts, cohort percentiles, rankings, leaderboard information, aggregate results, resolution records, and related metadata for as long as necessary to operate the feature, maintain historical prediction records, provide rankings or leaderboards, resolve polls, provide notifications, prevent abuse, enforce Our Terms, maintain security, comply with legal obligations, resolve disputes, and maintain business records.

If You delete Your Account or request deletion, We may delete, deidentify, aggregate, or detach identifiers from Earnings Prediction Poll information as required or permitted by applicable law. Certain aggregated poll results, market data, poll outcomes, and deidentified or historical reporting information may remain after deletion because they are not maintained solely as information about an identifiable individual.

Retention of Analytics Data

We may retain Analytics Data for as long as necessary to provide Analytics, maintain historical reporting, support Peer Benchmarks, preserve content performance trends, provide relationship insights, resolve disputes, enforce Our Terms, maintain security, comply with legal obligations, improve the Service, and maintain business records.

Analytics Data may be retained for current reporting periods, one year reporting periods, all time reporting periods, historical snapshots, benchmark records, content performance records, employee performance records, relationship records, and other reporting periods made available through the Service.

If You delete Your Account or request deletion, We may preserve historical Analytics in aggregated, deidentified, or firm level form. We may also retain certain Analytics Data where necessary or permitted by law, including for legal obligations, security, fraud prevention, dispute resolution, audit, backup, compliance, and enforcement purposes. Where reasonably feasible, We may remove, deidentify, or detach direct personal identifiers from historical Analytics records after account deletion, while preserving firm level, aggregated, deidentified, or historical reporting metrics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Direct Messages and Attachments may involve more than one user. If You delete Your Account or request deletion, certain Direct Messages or Attachments may remain available to other conversation participants or may be retained by Us for the purposes described above, including legal obligations, security, backup, dispute resolution, enforcement, regulatory, and safety purposes.

Where available, product controls may allow You to delete, remove, or manage certain Direct Messages, Message Requests, or Attachments. The effect of those controls may differ depending on whether the deletion applies only to Your view or to the conversation more broadly.

Marketplace information may involve Marketplace Providers and other users. If You delete Your Account or request deletion, certain Marketplace information may remain visible or may be retained by Us, including Reviews, provider profile information, records of Marketplace Inquiries sent to Marketplace Providers, provider application records, payment and subscription records, security records, backup records, and information retained to comply with legal obligations or resolve disputes.

Marketplace Providers are independent third parties. If You submit information to a Marketplace Provider through a Marketplace Inquiry or through provider contact information displayed in the Marketplace, that provider may retain and process the information it receives according to its own privacy practices.

Referral Posts may involve users and non user third parties, including clients, prospects, businesses, and Recommended Professionals. If You delete Your Account or request deletion, certain Referral Post information may remain visible to other users or may be retained by Us where necessary or permitted for legal obligations, security, fraud prevention, dispute resolution, audit, backup, compliance, enforcement, product integrity, or legitimate business purposes. Non user third parties may request removal of their information by contacting Us through the contact methods described in this Privacy Policy.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Analytics may involve more than one user, firm, employee, content item, event, profile, or reporting period. If You delete Your Account or request deletion, certain historical Analytics may remain in aggregated, deidentified, firm level, benchmark, or historical reporting form. Deleting Your Account may not remove historical metrics, content performance data, peer benchmarks, firm level trends, employee level metrics for Your own firm, or other records that are retained for legal, security, dispute resolution, audit, backup, compliance, enforcement, or legitimate business purposes.

We do not currently provide a product level setting that allows users to opt out of inclusion in Analytics, except where required by applicable law. You may contact Us to exercise any privacy rights available to You under applicable law.

Disclosure of Your Personal Data

Marketplace Providers, Inquiries, Reviews, and Administration Approved Marketplace Provider profile information and permitted Reviews may be disclosed to approved, logged in Marketplace users who have access to the Marketplace. If You submit a Marketplace Inquiry, We may disclose Your inquiry, contact information, Account profile information, firm or professional information, and any information You include in the inquiry to the relevant Marketplace Provider so the provider can respond to You.

Inflows administrators may access and review Marketplace Provider applications, profile content, Reviews, Marketplace Inquiries, reports, subscription status, payment status, receipts, webhook events, and related metadata to operate the Marketplace, approve or delist Marketplace Providers, provide support, investigate reports, prevent abuse, enforce Our Terms, comply with law, and maintain Marketplace trust and quality.

Referral Posts, Responses, and Recommended Professionals

Referral Posts and related comments may be disclosed to approved members who have access to the applicable feature. Referral Post Responses may be disclosed to the user who created the Referral Post. If users express interest in connecting through a Referral Post, We may create or enable a Direct Messaging conversation and disclose profile information between those users as part of the connection experience.

If a user recommends a Recommended Professional or center of influence, We may disclose that professional’s name, work email address, work phone number, business name, role, professional category, and related professional information to the requesting advisor or other approved users who can access the relevant Referral Post or related feature. Recommended Professionals may be non users of the Service.

Inflows administrators may access and review Referral Posts, Referral Post Responses, comments, Recommended Professional information, Direct Message creation activity, reports, support records, and related metadata to operate Referral Posts, provide support, investigate reports, prevent abuse, enforce Our Terms, comply with law, and maintain trust, safety, and quality.

Marketplace Providers are independent third parties. We are not responsible for the privacy practices of Marketplace Providers after they receive information from You or after You contact them outside the Service.

Direct Messages, Reports, and Safety Review

Direct Messages are not public posts, but they are not guaranteed to be confidential from the recipient, the Company, Service Providers, legal process, or safety and compliance review. We may access, review, preserve, remove, or disclose Direct Messages, Attachments, reports, and related metadata when necessary to operate the Service, investigate abuse or security issues, respond to user reports, enforce Our Terms, protect users or the public, comply with legal obligations, or protect the rights and property of Inflows.

Analytics and Firm Reporting

Analytics may include activity connected to users, firms, content, employees, representatives, events, profiles, Marketplace activity, and other activity on the Service. Analytics may be made available to approved firms and Authorized Firm Users when users interact with that firm’s content, employees, representatives, events, profiles, Marketplace activity, or other activity on the Service.

Analytics may show named firms, firm segments, geography, professional categories, AUM or fund ranges, content engagement, profile visits, event activity, relationship activity, employee activity for the subscribing firm’s own employees, and similar business insights. We do not intend to show outside firms the individual names of users in Analytics.

We may disclose Analytics Data to Service Providers that help Us provide, process, aggregate, deidentify, secure, display, maintain, debug, and improve Analytics.

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

Because Analytics may include activity patterns, profile visits, engagement data, firm affiliation, professional profile information, engagement categories, and related metadata, You should understand that Your activity on the Service may be processed to generate Analytics for Inflows and approved firms. We use reasonable safeguards designed to protect Analytics Data, but no method of transmission or electronic storage is completely secure.

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Because Direct Messaging allows users to exchange content and Attachments, You should exercise care before sending confidential, regulated, client related, or sensitive information.

No method of transmission or electronic storage is completely secure, and We cannot guarantee that Direct Messages or Attachments will remain secure or confidential.

Because Marketplace allows users to view provider profiles, submit Marketplace Inquiries, and leave Reviews, You should exercise care before including confidential, regulated, client related, or sensitive information. Marketplace Providers are independent third parties, and We cannot guarantee how they will secure, use, retain, or disclose information they receive from You.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data, including Direct Messages, Attachments, Marketplace information, provider applications, provider profile information, Marketplace Inquiries, Reviews, subscription and payment status, and related metadata, when necessary to provide their services to Us. These third party vendors collect, store, use, process, secure, transmit, and transfer information about Your activity on Our Service in accordance with their Privacy Policies and Our agreements with them.

Messaging, Storage, Notifications, and Security We may use Service Providers to host, store, transmit, process, monitor, and secure Direct Messages, Attachments, notifications, reports, and related metadata. These Service Providers may provide cloud hosting, database storage, file storage, image processing, push notification delivery, content delivery, security monitoring, abuse prevention, troubleshooting, customer support, analytics, debugging, and similar operational services.

Service Providers may have access to Direct Messages, Attachments, and related metadata only as needed to perform services for Us and subject to their applicable contractual obligations.

Marketplace, Provider Portal, Feature Flags, and Payments We may use Service Providers to host, store, transmit, process, search, display, monitor, and secure Marketplace information, provider applications, provider profile information, Marketplace Inquiries, Reviews, subscriptions, payment status, receipts, feature flags, allowlists, approval status, and related metadata. These Service Providers may provide cloud hosting, database storage, authentication, file storage, search, feature flag management, analytics, payment processing, webhook processing, email delivery, notification delivery, customer support, admin tools, security monitoring, fraud prevention, debugging, and similar operational services.

Service Providers may have access to Marketplace information only as needed to perform services for Us and subject to their applicable contractual obligations. Marketplace Providers are independent third parties and are not Service Providers merely because they are listed in or contacted through the Marketplace.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy Firebase Firebase is an analytics service provided by Google Inc. If enabled for the Application, Firebase or related Google services may also support app functionality such as diagnostics, performance measurement, cloud messaging, feature flags, app configuration, staged rollouts, access eligibility, Marketplace availability, subscription status synchronization, or similar app services.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy We also encourage You to review Google’s policy for safeguarding Your data:

https://support.google.com/analytics/answer/6004245 For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or apps webpage:

https://policies.google.com/technologies/partner-sites Hubspot Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy- policy?hubs_content=www.hubspot.com/&hubs_content-cta=privacy-policy Rebrandly Their Privacy Policy can be viewed at https://www.rebrandly.com/privacy-policy

Advertising

We may use Service Providers to show advertisements to You to help support and maintain Our Service.

Inflows Their Privacy Policy can be viewed at https://inflows.com/privacy-policy/ Email Marketing We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Hubspot Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy- policy?hubs_content=www.hubspot.com/&hubs_content-cta=privacy-policy SmartLead Their Privacy Policy can be viewed at https://www.smartlead.ai/privacy-policy Payments We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Marketplace Providers may pay a recurring subscription to participate in the Marketplace.

We may use Stripe Checkout and Stripe webhooks to process provider subscriptions and to receive payment status, subscription status, customer identifiers, subscription identifiers, receipts, webhook events, and related transaction information needed to administer Marketplace participation, show payment status and receipts in the Provider Portal, support accounting, prevent fraud, and manage subscriptions.

We do not collect Tax ID or EIN information through the Provider Portal unless We separately request and disclose such collection.

Stripe Their Privacy Policy can be viewed at https://stripe.com/us/privacy Usage, Performance and Miscellaneous We may use third-party Service Providers to maintain and improve our Service.

OpenGraph Their Privacy Policy can be viewed at https://www.opengraph.io/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Direct Messaging and safety: Processing Personal Data, including Direct Messages, Attachments, notifications, reports, and related metadata, may be necessary to provide Direct Messaging, secure the Service, investigate reports, prevent abuse, enforce Our Terms, comply with legal obligations, and pursue Our legitimate interests in operating and protecting the Service.

Marketplace and provider subscriptions: Processing Personal Data, including provider applications, provider profile information, Marketplace Inquiries, Reviews, subscription and payment status, receipts, feature flag data, allowlist data, approval or delisting records, and related metadata, may be necessary to provide the Marketplace, perform a contract with You, take steps before entering into a contract, manage provider subscriptions, enforce Our Terms, prevent fraud or abuse, comply with legal obligations, and pursue Our legitimate interests in operating, securing, and improving the Marketplace.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Analytics and legitimate interests: Where permitted by applicable law, We may process Analytics Data based on Our legitimate interests in operating, improving, securing, and monetizing the Service, providing firm and relationship insights, measuring content performance, supporting Peer Benchmarks, and helping approved firms understand engagement with their content, employees, representatives, events, profiles, and other activity on the Service. This processing may include engagement categories or other limited analytics used to provide Analytics. You may have the right to object to certain processing based on legitimate interests, including profiling, as described in this Privacy Policy and applicable law.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12)

months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes, including names, email addresses, phone numbers, account identifiers, online identifiers, provider portal identifiers, Stripe customer or subscription identifiers, and similar identifiers.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes, including contact information, business contact details, provider billing records, payment related records, and other information You provide. We do not store payment card details, and We do not collect Tax ID or EIN information through the Provider Portal unless We separately request and disclose such collection.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: Yes, if You voluntarily provide this information in Your profile, Direct Messages, Attachments, reports, Marketplace Inquiries, Reviews, Marketplace content, or other communications. Otherwise, We do not intentionally request this information.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes, including provider subscriptions, products or services purchased or considered, displayed pricing, receipts, Marketplace profile views, Marketplace Inquiries, Reviews, and provider participation history.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes, including interaction with Our Service, Marketplace searches, browsing activity, category filters, provider profile views, clicks, feature usage, diagnostic data, and interactions with advertisements if applicable.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes, if You voluntarily provide location information in content, Direct Messages, Attachments, Marketplace Inquiries, Reviews, Marketplace Provider profiles, or other information You submit. Otherwise, We do not intentionally collect precise geolocation information through the Service.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: Yes, if You upload, send, or otherwise provide photos, logos connected to an individual, image attachments, videos, audio, or similar content through the Service, Direct Messaging, or the Marketplace.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: Yes, including professional profile information, business affiliation, title, role, firm information, Marketplace Provider profile information, provider representative information, business contact details, service descriptions, and professional or employment related information You provide or include in Direct Messages, Attachments, Marketplace Inquiries, Reviews, or Marketplace content.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No. We do not currently use Marketplace search or browsing activity to create inference profiles reflecting user preferences, characteristics, or behavior. If We later use Marketplace activity for provider recommendations, personalization, or profiling, We will update this Privacy Policy as required.

Category L: Sensitive personal information.

Examples: Account login and password information; contents of private communications such as Direct Messages; Attachments to the extent they include sensitive information; Marketplace Inquiries or Reviews to the extent You include sensitive information; precise geolocation if enabled or included in content; and financial account, health, government identifier, protected classification, or other sensitive information You choose to provide.

Collected: Yes.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA/CPRA’s scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
• Indirectly from You. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to provide advertising on our Service, third- party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.
• From other users. For example, when another user sends You a Message Request, Direct Message, Attachment, invitation, report, Review, Marketplace Inquiry, or other interaction involving Your Account.
• From Marketplace Providers. For example, from provider applications, Provider Portal submissions, provider profile information, service descriptions, displayed pricing, contact information, Reviews responses if available, subscription status, payment status, and related Marketplace administration information.
• From payment processors. For example, from Stripe Checkout, Stripe webhooks, receipts, payment status, subscription status, customer identifiers, subscription identifiers, and related transaction information needed to administer provider participation.

Use of Personal Information

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

• To operate our Service and provide You with Our Service.
• To provide Direct Messaging, including Message Requests, acceptance or decline controls, message delivery, Attachment delivery, notification routing, and related support and safety features.
• To provide and administer the Marketplace, including provider applications, approval and delisting, provider profiles, Marketplace search and browsing, Marketplace Inquiries, Reviews, provider subscriptions, payment status, receipts, Provider Portal administration, and Marketplace trust and safety.
• To manage Marketplace access, including login status, user approval status, email verification status, allowlist status, feature flag eligibility, provider approval status, provider subscription or payment status, and similar configuration information.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To investigate reports, prevent abuse, protect users, preserve evidence, enforce Our Terms, and maintain the safety and integrity of Direct Messaging, Marketplace, and the Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information Marketplace Providers, Inquiries, Reviews, and Administration Marketplace Provider profile information and permitted Reviews may be disclosed to approved, logged in Marketplace users with access to the Marketplace. If You submit a Marketplace Inquiry, We may disclose Your inquiry, contact information, Account profile information, firm or professional information, and any information You include in the inquiry to the relevant Marketplace Provider so the provider can respond to You.

We may disclose provider application information, subscription and payment status, receipts, webhook events, approval or delisting records, Reviews, Marketplace Inquiries, reports, and related metadata to Service Providers, payment processors, Inflows administrators, and other parties where necessary to operate the Marketplace, provide support, investigate reports, prevent abuse, enforce Our Terms, comply with legal obligations, and protect rights, property, and safety.

Direct Messages, Reports, and Safety Review

Direct Messages are not public posts, but they are not guaranteed to be confidential from the recipient, the Company, Service Providers, legal process, or safety and compliance review. We may access, review, preserve, or disclose Direct Messages, Attachments, reports, and related metadata when necessary to operate the Service, investigate abuse or security issues, respond to user reports, enforce Our Terms, protect users or the public, comply with legal obligations, or protect the rights and property of Inflows.

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category C: Protected classification characteristics, to the extent You voluntarily provide such information
• Category D: Commercial information
• Category F: Internet or other similar network activity
• Category G: Geolocation data, to the extent You voluntarily provide such information
• Category H: Sensory data
• Category I: Professional or employment related information
• Category L: Sensitive personal information Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sharing of Personal Information We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors, including Stripe
• Our affiliates
• Our business partners
• Marketplace Providers, when You submit a Marketplace Inquiry, contact a Marketplace Provider, or otherwise direct Us to disclose information to that provider
• Approved Marketplace users, when provider profile information or permitted Reviews are visible in the Marketplace
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You
• Other users of the Service, when You choose to share information with them, send Direct Messages or Attachments to them, interact with them through the Service, submit Reviews, or participate in Marketplace features Sale of Personal Information As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

We do not sell or share Direct Message content, Attachments, reports, or Direct Messaging metadata for cross context behavioral advertising, and We do not use Direct Message content or Attachments for cross context behavioral advertising.

We do not sell or share Marketplace Inquiries, provider application data, provider subscription records, provider payment records, Reviews, or Marketplace payment information for cross context behavioral advertising. When You submit a Marketplace Inquiry to a Marketplace Provider, We disclose the inquiry to that provider at Your direction so the provider can respond to Your request.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age The Service is intended for users who are 18 years of age or older. We do not knowingly collect, sell, or share personal information from Consumers less than 16 years of age.

If You have reason to believe that a child under the age of 13 or a minor under the age of 16 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information where required or appropriate.

Analytics, Sale, and Sharing Clarification

We do not sell personal information as the term “sell” is commonly understood. We do not use Analytics Data for cross context behavioral advertising unless We disclose that use and provide any legally required choices.

Inflows Analytics is a core feature of the Service. Analytics made available to approved firms and Authorized Firm Users may include named firm information, firm segments, geography, professional categories, AUM or fund ranges, engagement activity, profile visit activity, event activity, content performance, relationship activity, and related metrics. We do not intend to show outside firms the individual names of users in Analytics.

Because privacy laws may define “sale,” “sharing,” or similar terms broadly, certain disclosures related to Analytics may be considered a sale, sharing, disclosure for a business purpose, or disclosure for a commercial purpose under applicable law. Where required by applicable law, We will provide the rights and choices required by that law.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
• The categories of personal information We collected about You
• The categories of sources for the personal information We collected about You
• Our business or commercial purposes for collecting or selling that personal information
• The categories of third parties with whom We share that personal information
• The specific pieces of personal information We collected about You
• If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
• The categories of personal information categories sold
• The categories of personal information categories disclosed
• The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the “Do Not Sell My Personal Information” section or contact Us.
• The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
• The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the “Limit the Use or Disclosure of My Sensitive Personal Information” section or contact Us.
• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
• Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the “Do Not Sell My Personal Information” section and “Limit the Use or Disclosure of My Sensitive Personal Information” section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

By email: support@inflows.com By visiting this page on our website: https://www.inflows.com Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it We cannot respond to Your request or provide You with the required information if We cannot:
• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

We do not sell or share Direct Message content, Attachments, reports, or Direct Messaging metadata for cross context behavioral advertising, and We do not use Direct Message content or Attachments for cross context behavioral advertising.

We do not sell or share Marketplace Inquiries, provider application data, provider subscription records, provider payment records, Reviews, or Marketplace payment information for cross context behavioral advertising. When You submit a Marketplace Inquiry to a Marketplace Provider, We disclose the inquiry to that provider at Your direction so the provider can respond to Your request.

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners)

may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest- based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website If applicable, click “Privacy Preferences”, “Update Privacy Preferences” or “Do Not Sell My Personal Information” buttons listed on the Service to review Your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.

Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN The opt-out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Mobile Devices Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the “Use of Your Personal Data” section or contact us.

Sensitive personal information may include Direct Message content, Attachments, Marketplace Inquiries, Reviews, or Marketplace content if You provide sensitive information through those features. We use such information to provide Direct Messaging, operate the Marketplace, maintain security, provide support, investigate reports, enforce Our Terms, comply with legal obligations, and protect rights, property, and safety.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

Although the Service is intended for users who are 18 years of age or older, California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Children’s Privacy

The Service is intended for users who are 18 years of age or older. We do not permit users under 18 to create an Account, use the Service, use Direct Messaging, or use the Marketplace.

We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.

If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, or from a user under 18 in violation of Our eligibility requirements, We take steps to remove that information from Our servers where required or appropriate.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

Marketplace Provider profiles may include websites, contact information, or other links to third party services. If You contact a Marketplace Provider outside the Service or visit a Marketplace Provider website, the Marketplace Provider or third party site may collect and process Your information according to its own privacy practices.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: support@inflows.com

By visiting this page on our website: https://www.inflows.com