PRIVACY POLICY

May 26, 2021

Click here for California Privacy Policy

Welcome to Aqqru®, a goals-based planning tool offered by ML Wealth, LLC (“ML Wealth”; also referred to as “we,” “us” and “our” throughout this Privacy Policy). This Privacy Policy describes how we may collect, share, use, protect and disclose information that identifies, relates to, or could be reasonably linked (directly or indirectly) with a particularly identified or identifiable natural person or household (“Personal Information”) we receive through our website located at www.aqqru.com (the "Website") and our services which may also be accessible via our Website (together, the "Services"). It is separate from the Privacy Policy for MoneyLion Inc. and certain of its affiliates and subsidiaries, including but not limited to ML Wealth, LLC (collectively, “MoneyLion”), that is located here and governs personal information and related services received through www.moneylion.com. By using or submitting information through the Services, you are indicating your agreement to be bound by this this Privacy Policy. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services or referenced by us in print, online or email. Your utilization of the Services is also governed by the Terms of Use, so please make sure you have read and understand those terms. When you visit our Website or use our Services, you signify acceptance to the terms of this Privacy Policy and consent to the collection, use, and disclosure of your Personal Information as described below. If you do not agree with, or you are not comfortable with any aspect of this Privacy Policy, please immediately discontinue access or use of our Services.

INFORMATION WE COLLECT TO PROVIDE YOU SERVICES

This Privacy Policy covers all Personal Information that you submit to us and that we may obtain from our partners or other third-parties, including without limitation: Personal Information you provide online and on applications or other forms, such as your name, address, email address, phone number, social security number, driver’s license number, passport, date of birth, income, profession/employment information, bank account information, marital status, income information and budgeting objectives. You may also provide us with Personal Information related to your external financial accounts, such as bank account number, so that we may provide you with special product and service features. Your technical, navigational and other information may be transferred to us when visiting our Website, including IP address, mobile device IDs, device type, cookies, browsing activity, location and browser type. In addition, for business purposes consistent with applicable law, we may compile aggregate, anonymous, or de-identified data from various sources, which does not identify individual customers.

HOW WE USE AND SHARE YOUR INFORMATION

We do not sell any Personal Information to any third party.

We may disclose Personal Information we collect, such as the categories described above, to make our financial products and services, as well as those offered by our service providers, available to you. We may also use and disclose Personal Information with your consent. If you decide to withhold certain information, it may limit our ability to provide you with the services or products you request or that may be of interest to you. Information Shared with Our Services Providers:

Information Shared with our Marketing Partners and Third Parties:

Transfer in the Event of Sale, Merger or Change of Control:

Information we collect from users of the Services, including Personal Information, is considered a business asset. If the ownership of all or substantially all of our business changes or is contemplated to be changed, or we otherwise transfer or contemplate transferring assets relating to our business to a third party -- such as by merger, acquisition, bankruptcy proceeding or otherwise -- we may disclose or transfer your Personal Identification to such new actual or potential owner or third party acquirer in connection with the transaction or, for evaluation purposes, the potential transaction. Legal Proceedings and Matters:

We will share any applicable information, including Personal Information, with third party companies, organizations or individuals in order to cooperate with government and law enforcement officials or private parties to enforce and comply with law, regulation, ordinance, subpoena, legal process or government requests. As such, we may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate:

We may also disclose your Personal Information to the following entities:

Our service providers are obligated to keep the Personal Information we share with them confidential and use it only to provide services specified by us.

SECURITY OF YOUR INFORMATION

Maintaining the privacy of your Personal Information is of utmost importance to us. ML Wealth maintains reasonable physical, administrative, and technical safeguards to protect your Personal Information and we regularly adapt these controls to respond to changing requirements and advances in technology. As necessary, Personal Information shall be subject to additional safeguards to ensure this data is processed securely. For example, we work hard to ensure data is encrypted when in transit and storage, and access to this data will be strictly limited to a minimum number of individuals and subject to confidentiality commitments. We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website(s); any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. When possible, encryption is used, both in transit and storage. Access controls within the organization limit who may access information. The Website may contain links to other sites that you may choose to visit. ML Wealth is not responsible for the privacy and security practices utilized by other sites.

INFORMATION WE MAY COLLECT AUTOMATICALLY

We may receive and store certain types of information automatically, such as when you visit the Website or use our Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, or web-browser software. For example, we may use data collection and tracking tools such as cookies, web beacons, pixel tags, and other similar tracking techniques that may be downloaded to your personal computer, tablet, mobile phone or other device (“Device”) when you visit or interact with our Website. “Cookies” are small amounts of data that a website can send to your web browser and store on your computer. Cookies do not contain Personal Information (unless you knowingly provide it). We may use both “session ID” cookies and “persistent” cookies. A session ID cookie, if utilized, expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. To the extent we will utilize persistent cookies, you can remove them by following directions provided in your Internet browser’s “help” directory. If we do utilize cookies, and you reject them, you could still use our Website, but your ability to use some areas of it may be limited. The use of cookies by our partners, affiliates, tracking utility company, and/or service providers is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and/or service providers may use session ID cookies to make it easier for you to navigate the Website.

CHILDREN

This Website is not directed at individuals under the age of eighteen (18). MoneyLion does not knowingly collect or receive Personal Information from any individual under the age of eighteen (18).

GEOGRAPHIC RESTRICTIONS

The Website and Services offered by ML Wealth, including the Aqqru® goals-based planning tool, are operated in the United States and are intended for access and use within the United States only. As such, ML Wealth complies with applicable United States privacy laws. The Website and Services are not intended for, or directed to, citizens, domiciles or residents of the European Union. By accessing the Website and/or the Services, you affirm that you are not a citizen, domicile or resident of the European Union. Further, if you use the Website and/or attempt to receive or utilize the Services outside of the United States, you acknowledge that your information, including Personal Information, will be transferred, processed, and stored in the United States, as it is necessary to provide the Services. If you are accessing the Website and/or Services outside of the United States, you further acknowledge that your Personal Information may be subject to locations where privacy laws may not be as protective as those governing this Privacy Policy.

YOUR CHOICES

You have choices regarding the collection and use of your Personal Information. We may periodically send you promotional emails and notifications. You will have the opportunity to “opt out” of receiving these promotional messages, (although we may need to send you certain information regarding the Services you may not be able to opt-out of). To Opt Out of Our Promotional Messages:

To Delete, Change or Modify Your Information: As a customer, you may access and update or correct information you have provided to us for the Services. You may also request that information provided be deleted by emailing us at [email protected]. We will take reasonable steps to delete your information from our servers, but please note some information may remain in archived/backup copies for our records or as otherwise required by law. Also note that such requests regarding information passed onto third parties not governed by this Privacy Policy may need to be addressed directly with such third party. To Revoke Your Consent: You may revoke consent to processing or utilizing Personal Information (where such processing is based upon consent) by emailing us at [email protected]. Please note if you revoke such consent, we may no longer be able to provide you the Services.

YOUR CALIFORNIA PRIVACY RIGHTS

NOTICE TO CALIFORNIA RESIDENTS-

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL INFORMATION TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A "CALIFORNIA CUSTOMER"), MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES' DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING [email protected] PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR, AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS. CALIFORNIA CONSUMER PRIVACY ACT (CCPA) Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request and subject to applicable exemptions, to request that we give you access, and (if technically feasible) in readily usable form, to the specific pieces and categories of Personal Information that we have collected or shared about you. California residents also have the right to submit a request for deletion of Personal Information under certain circumstances that ML Wealth is not otherwise entitled to maintain. Consistent with California law, ML Wealth will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services or provide you with a different level or quality of services based on this exercise of your rights. To submit a data request, please follow the instructions below. For your protection, we will need to verify your identity before fulfilling your request. Government identification may be required. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law, which may take up to forty-five ( 45) days following verification of your identity. Please note that applicable law(s) allows us to keep certain forms of data for recordkeeping or other lawful purposes. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons. To contact us regarding your California Privacy Rights, please email us at [email protected]. You may also contact us offline via mail to: ML Wealth, LLC: 30 W. 21st Street, Fl. 9, New York, NY 10010.

UPDATE TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email or by means of a notice on the Website prior to the change becoming effective. We encourage you to periodically review the Website for the latest information on our privacy practices.

CONTACT US

If you have any questions about our Privacy Policy, please contact us at

Email: [email protected]

30 W. 21st Street, FL 9, New York, NY 10010