Information You Provide

We collect information you provide when you use our Services or otherwise engage or communicate with us as described below.

• Identity Data, such as your name, date of birth, marital status, social security number, your photo, and other data on government-issued identification documents;

• Contact Data, such as your email address, mailing address, and telephone number;

• Financial Data, such as your bank account and payment card details, and information about your income, account balances, financial transaction history, and tax information;

• Profile Data, such as your username and password, your interests, preferences, feedback, and survey responses;

• Additional Data You Provide, such as via focus groups, survey responses, contests/sweepstakes, customer support; and

• Other Information You Provide: We collect additional personal information that you choose to provide to us. For example, in connection with our life insurance products, you may share your height and weight with us.

Information We Collect Automatically

We collect certain information about you automatically when you use our Services, as described below.

• Usage Information. We collect information about your activity on our Services, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.

• Transactional Information. When you receive, submit, or complete a transaction via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.

• Location Data. Our third party tools that are used to provide the Services use technologies to approximate your location, including IP address. We also approximate your location by your IP address.

• Information Collected Through Tracking Technologies. We and our service providers also use technologies, including cookies and web beacons, to automatically collect certain types of usage and device information when you use our Services or interact with our emails. The information collected through these technologies includes your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information and other similar information. For information about how to disable cookies, please see the Your Controls section below.

Information We Collect from Other Sources

We also obtain information about you from other sources as described below.

• Vendors and Business Partners. We collect information about you from companies that we do business with, such as name, contact data, and inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification.

• Financial Account Linking. Arta offers account linking and aggregation services through Plaid Inc. ("Plaid"). By utilizing these services, you acknowledge and agree that the terms of Plaid's Privacy Policy (currently located at https://plaid.com/legal/#end-user-privacy-policy) will govern Plaid's use of such information, and you consent to Plaid's Privacy Policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide its services.

• Publicly Available Data. This includes contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.

• Advertising Data. We collect information in connection with our ad campaigns that surfaced on other platforms, such as the ads you clicked on and other interactions with our ads.

We use the information we collect for purposes described below or as otherwise described to you at the point of collection:

• Maintain and provide the Services, including to process account applications, authenticate your identity, maintain our Services, support, process and record transactional information, and handle account management;

• Send you transactional or relationship information, including confirmations, invoices, technical notices, customer support responses, software updates, security alerts, support and administrative messages, and information about your transactions;

• Communicate with you about offers and other things we think you will be interested in, such as newsletters, product announcements, partner offerings, surveys, contests or sweepstakes, events or announcements;

• Personalize our Services, such as by suggesting content or customizing content or ads we show you;

• Monitor and improve our Services, including analyzing usage, research and development;

• Facilitate contests, sweepstakes, and promotions, and process and deliver entries and rewards;

• Help protect the safety and security of our Services, business, and users, such as to investigate and help prevent fraud or other unlawful activity;

• Protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and

• Comply with applicable laws and legal obligations, such as retaining your data for recordkeeping purposes as is required by state and/or federal law.

We are committed to maintaining your trust, and we want you to understand when and with whom we share information about you. We share information about you in the instances described below.

• Authorized third-party vendors and service providers. We share information about you with third-party vendors and service providers who perform services for us, such as identification verification, fraud prevention, advertising, fund administration, custody, brokerage services, marketing services, tax and accounting services, web hosting, and analytics services.

• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, Arta Finance Club LLC may assist in finding an estate planning product suited for you through third-party service providers and will share information with your consent. We will share personal information these other companies need to provide the services that you requested.

• Arta Affiliates. Where appropriate, we share information about you with other companies owned or controlled by Arta. For example, Arta Finance Insurance LLC may receive information to provide you with insurance product recommendations and other related services as described in your customer agreement. These companies will process any information shared in the same manner as described under this Privacy Policy.

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, may receive info about you where necessary in the course of the professional services that they render to us.

• Corporate transactions. We may share information about you in connection with a corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.

• Legal purposes. We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process or to protect and defend the rights, interests, safety, and security of Arta, our users, or the public.

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Sites, AdID, location, and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

We may engage in the following:

• Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, X (formerly Twitter), Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

• Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us.  We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at  https://google.com/ads/preferences, or by visiting NAI’s online resources at  http://www.networkadvertising.org/choices.

Some web browsers transmit “do-not-track” signals to websites. We currently don’t take action in response to these signals.

Account profile. You can update certain account profile information by logging into your account. Please note that any changes you make to your account profile must be in accordance with our Terms of Use.

Access to your device data. You may disconnect our mobile app’s access to certain stored device information through your device’s settings. For instance, you can withdraw permission for the app to access your photo gallery.

How to control your communications preferences. You can stop receiving promotional emails from us by clicking the “unsubscribe” link in those emails. We may still send you service-related or other non-promotional communications, such as account notifications, receipts, security notices and other transactional or relationship messages.

Affiliate sharing opt out. In some cases, you can limit sharing between Arta affiliates. Please see the privacy notice of each affiliate for more details. If you want to exercise this right, please contact us at privacy@artafinance.com.

Cookie controls. Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.

This section provides additional details about the personal information we collect about California and Virginia residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Please note that the CCPA does not apply to what is referred to as nonpublic personal information collected by financial institutions (like Arta), as that information is subject instead to other financial privacy laws. Additionally, the VCDPA does not apply to any Arta entities that are financial institutions. As a result, the CCPA and VCDPA do not apply to most of the information that Arta collects.

Subject to certain limitations and exceptions, the CCPA and VCDPA provide California and Virginia residents, respectively, with certain rights. Depending on the state in which you are a resident, you may have the right to:

• Confirm whether Arta processes your personal information;

• Correct inaccurate personal information;

• Request details (in a readily usable format) about the categories and specific elements of personal information we collect;

• Delete your personal information;

• Opt out of any sales, sharing, targeted advertising, or profiling for certain decisions (as these terms are defined in the CCPA and/or VCDPA); and

• Not be discriminated against for exercising these rights.

We do not sell information about you to third parties. In order to help Arta deliver advertising and marketing on other platforms, we do allow third parties to collect information through our Services. Please see the “Third-Party Tracking and Online Advertising” section above for more details, including choices available to you.

For more details about the information we collect (including the categories of sources of this information) as well as the purposes for processing, please see the “Information We Collect and How We Collect It” section above. We share this information with the categories of third parties described in the “Disclosures of Information” section above.

California and Virginia residents may make a request to exercise rights under the CCPA and VCDPA, respectively, that are not otherwise exempt under applicable law. You may request assistance by sending an email to privacy@artafinance.com. We may verify the request by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly. If you are a Virginia resident and Arta is unable to satisfy your request to exercise a right available to you under the VCDPA, you are entitled to appeal our decision by emailing privacy@artafinance.com.

We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services. In the event we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at privacy@artafinance.com

By using our Services, your information may be processed in the United States or Singapore.

This Privacy Policy will evolve with time, and when we update it, we will revise the "Effective Date" above and post the new Policy and, in some cases, we provide additional notice (such as adding a statement to our website or sending you a notification). To stay informed of our privacy practices, we recommend you review the Policy on a regular basis as you continue to use our Services.

If you have any questions about this Privacy Policy, please contact us at privacy@artafinance.com.