Financial Privacy Notice

Facts	What does FinClusive do with your personal information?
Why?	Financial companies choose how they share your personal information. Federal law gives you the right to limit some, but not all, sharing and requires us to inform you how we collect, share, and protect your personal information. Please read this notice carefully to understand how your information may be used.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include, without limitation: Domestic and foreign-government identification numbers, such as driver’s license, passport, visa, Social Security or tax; Identification number; Name, date of birth, address, email address, occupation, employer, mobile and home telephone number; Transaction history; Credit, debit, bank account and payment history information; E-mail communications; Hardware and software identifiers, geolocation, browser type, internet service provider, referring/exit pages, operating system, IP address, and browsing history logs to obtain usage statistics and behavior patterns as well as other information from and about your device (such as device properties, settings, applications, stored information and usage) and carrier; the browser and operating system software you use; social profile and network information; the date and time you access our website and the Internet address used to link to our website when you visit us. You consent to our collection, transfer and storage of information by computers or other transfer or storage devices in the United States and elsewhere.
How?	As a company in the financial industry, we need to share a certain amount of our customers’ personal information to run our everyday business and provide services to you. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons FinClusive may share this information; and whether you can limit this sharing.

Reasons we can share your personal information	Does FinClusive share?	Can you limit this sharing?
For our everyday business purposes – such as to process your transactions; collect payments; detect and prevent fraud and other illegal activities; cooperate with criminal or government investigations; maintain your account(s); comply with court orders, subpoenas, and court orders and other lawful requests; enhance your consumer experience; in the event FinClusive were to become involved in a merger, acquisition, or any form of sale of some or all of its business; or as otherwise permitted or required by law	Yes	No
For our marketing purposes—to offer our proprietary products and services to you or send you marketing and promotional messages	Yes	No
For joint marketing with other financial companies—to offer jointly marketed products and services to you or send you marketing and promotional messages	Yes	No
For our affiliates’ everyday business purposes—such as information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes—such as information about your creditworthiness	Yes	Yes
For our affiliates to market to you	Yes	Yes
For non-affiliates to market to you	No	We don't share

To Limit Our Sharing	Visit us online: www.finclusive.com Please note: If you are a new customer, we can begin sharing your information 30 days from the date you on-board with us. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions?	Go to www.finclusive.com , click “Contact Us” or contact us via email at: support@finclusive.com.

Who We Are
Who is providing this notice?	FinClusive Capital, Inc.

What we do
How does FinClusive protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We use encryption in the transmittal of your sensitive personal information between your systems and ours and we use firewalls. See here: Information Security.
How does FinClusive collect my personal information?	We collect your personal information, for example, when you: Register at www.finclusive.com; Use or visit our online sites, navigate through mobile apps providing our services (for example, to complete a transaction, manage your accounts, or provide your choices); Sign up for our newsletters or other public outreach; Provide your government issued ID; Provide account information or otherwise give us your contact information; or Enter a FinClusive-sponsored or affiliated promotion or loyalty program. By using FinClusive services you expressly consent to our use of your geolocation to respond to your requests, improve your customer experience, or fulfill risk management, security and/or compliance related requirements. We may, on occasion, combine information from outside sources to customize your experience on the FinClusive platform, risk management, compliance, regulatory and for know-your-customer and customer due diligence purposes, including for authentication and identity verification purposes. FinClusive may, in the future, also collect and store for such purposes various biometric information—all in compliance with and subject to the limitations of applicable law.
Why can’t I limit all sharing?	Federal law gives you the right to limit only: Sharing for affiliates’ everyday business purposes — information about your creditworthiness; Affiliates from using your information to market to you; Sharing for non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. We currently do not have affiliates, but we reserve the right to share information with our affiliates as described on here.
Non-affiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates with whom we share information may be Partner Banks, including banks of record (BoR) or bank/non-bank financial institutions, service providers, joint marketing partners, and others.
Joint Marketing	A formal agreement between non-affiliated financial companies that together market financial products or services to you. Our joint marketing partners include our bank of record (BoR) partners, Stellar blockchain anchors, and others.

Other Important Information
Nevada: If you are a Nevada resident, we are providing you this notice under state law. If you prefer not to receive marketing calls from us, you may be placed on our internal Do Not Call List by contacting us at 1-888-375-4407; privacyofficer@finclusive.com; 632 Broadway, 4th Floor, New York, NY 10012. You may also contact the Nevada Attorney General's office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; 1-702-486-3132; email BCPINFO@ag.state.nv.us or AgInfo@ag.nv.gov. Vermont: If you are a Vermont resident, non-public personal financial information will not be shared with others except as permitted by law unless you specifically consent to the disclosure. Vermont is known as an ‘Opt-In’ state, so unless you affirmatively “Opt In” (that is, give your consent to us), FinClusive will not share your information (except as permitted by law) and FinClusive will not disclose information about your credit reports and/or creditworthiness information with affiliates unless you specifically authorize us to make those disclosures. California: If you are a California resident, we will not share information we collect about you with companies outside of FinClusive, unless the law allows. For example, we may share information to complete requested transactions. You may request information about our practices related to disclosing your personal information and how we respond to Do Not Track signals. Texas: If you have a complaint, first contact FinClusive by visiting our website and clicking “Contact Us”. If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity, please direct your complaint to the Texas Department of Banking: 2601 North Lamar Boulevard, Austin, TX 78705-4294; 1-877-276-5554 (toll free); https://www.dob.texas.gov/.

Other Important Information

Nevada: If you are a Nevada resident, we are providing you this notice under state law. If you prefer not to receive marketing calls from us, you may be placed on our internal Do Not Call List by contacting us at 1-888-375-4407; privacyofficer@finclusive.com; 632 Broadway, 4th Floor, New York, NY 10012. You may also contact the Nevada Attorney General's office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; 1-702-486-3132; email BCPINFO@ag.state.nv.us or AgInfo@ag.nv.gov.

Vermont: If you are a Vermont resident, non-public personal financial information will not be shared with others except as permitted by law unless you specifically consent to the disclosure. Vermont is known as an ‘Opt-In’ state, so unless you affirmatively “Opt In” (that is, give your consent to us), FinClusive will not share your information (except as permitted by law) and FinClusive will not disclose information about your credit reports and/or creditworthiness information with affiliates unless you specifically authorize us to make those disclosures.

California: If you are a California resident, we will not share information we collect about you with companies outside of FinClusive, unless the law allows. For example, we may share information to complete requested transactions. You may request information about our practices related to disclosing your personal information and how we respond to Do Not Track signals.

Texas: If you have a complaint, first contact FinClusive by visiting our website and clicking “Contact Us”. If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity, please direct your complaint to the Texas Department of Banking: 2601 North Lamar Boulevard, Austin, TX 78705-4294; 1-877-276-5554 (toll free); https://www.dob.texas.gov/.