SecFi, Inc. is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust. We NEVER rent, sell or trade your Personal Information (as defined below) to anyone. Ever. This Privacy & Security Statement describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information. We refer to SecFi, Inc. and SecFi Limited collectively as “SecFi”, “we”, or “us”. We refer to those who establish an account with us (“Account”) or otherwise use our service offerings as “Users”. We refer to those who visit our website without logging into an Account or using our service offerings as “Visitors”. We refer to those who enroll in our Option Exercise Service or Share Liquidity Service as “Clients”. This Privacy Policy governs your use of our services.

How to Use this Privacy Policy

This Privacy Policy explains, in plain English, how SecFi gathers and uses your Personal Information in the context of each of SecFi’s service offerings, including use of our financial dashboard software service for reviewing your options and shares (“Dashboard”), our delivery of automated advisor option exercise and share liquidity consultations (“Consultation Service”), and delivery of our option exercise and share liquidity service services (“Service”, “Option Exercise Service” or “Share Liquidity Service”). All of SecFi’s services are made available through SecFi’s website, www.secfi.com (“Site”). In particular, we describe how your Personal Information is shared and/or disclosed, how we collect and use other non-Personal Information and how we address other privacy and security matters – such as our overall security practices, deletion of your Personal Information upon request and opting-out of marketing communications. Lastly, we describe methods for contacting SecFi if you have privacy or security questions, comments or feedback.

Information Collection

The types of information we collect depend on whether you are a current or former User, Visitor and/or Client. We collect Personal Information from you when you voluntarily provide it to us. Examples of instances when we collect Personal Information include:

  • when you answer questions on the Site to determine what kind of services we might recommend if you were to become a Client,
  • when you provide information about the company you have equity in,
  • when you register to open an account,
  • when you contact our client service organization with questions,
  • when you become a Client, or

Wherever SecFi collects Personal Information, we endeavor to provide a link to this Privacy Policy.

Information We Collect from Users

We collect Personal Information such as name, address, telephone number and other optional information you may provide, such as your age, financial assets, which may include the options and shares you hold, income information, tax data, such as tax bracket and security cost basis, and other financial planning information about you, your household and the company you have equity in. We may collect your e-mail address and/or telephone number should you engage with us via our Site, or email or by calling our client service team.

Information We Collect from Clients

If you choose to become a Client, in addition to the information we collect from you as a User, described above, we will ask you for certain additional Personal Information, including but not limited to:

  • your and your dependents full legal name, contact information, birth date, Social Security Number, citizenship;
  • your approximate net worth, and other regulatory disclosures that may be necessary and required by federal and certain statutory laws;
Information Regarding Children

Due to the nature of our business, Services and benefits are not marketed to minors. SecFi does not knowingly solicit Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information to SecFi. If we learn that we have collected Personal Information directly from a minor, we will delete such information from our files.

If a parent or guardian becomes aware that his or her child under the age of 18 has directly provided us with Personal Information without his or her consent, he or she should contact us at info@secfi.com and we will delete such information from our files.

Other Ways We Collect Information

Other means by which we collect Personal Information include the following:

  1. Anonymized or aggregated Information. SecFi’s Site and App automatically record certain anonymized or aggregated information about your use or evaluation of our Service. Anonymized or aggregated information is used for a variety of functions, including the measurement of Users’ interest in and use of various portions or features of the Site. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
  2. Cookies and Pixels. Similar to other technology platforms and services, SecFi uses cookies, a small piece of computer code that enables our Web servers to “identify” Users, each time an individual initiates a session on our websites. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your own hard drive at any time. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.
  3. Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
  4. Site Activity. SecFi may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site and App.
  5. “Do Not Track” Technology. We do not collect personal information about your online activities over time and across different web sites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different web sites or online services.
How we use Information
User Personal Information

We use your Personal Information to help you evaluate our Service, offer you new products or services, and enhance our Service. We may also use your Personal Information a number of ways, including research, internal analysis, and analytics.

Client Personal Information

SecFi stores, processes, and maintains Personal Information related to you in order to provide client support, offer new products or services and provide our Service to Clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and Financial Industry Regulatory Authority, Inc. (“FINRA”). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Client. Additionally, we may share the information required to become a Client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide services to you.

Information Sharing and Onward Transfer

We will not sell, rent, or trade your Personal Information (whether you are a current or former Client) to any nonaffiliated third parties except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use. There are certain circumstances, in which we may share your Personal Information with nonaffiliated third parties without further disclosure to you. For example, from time-to-time, we hire third-parties to perform certain business and technology related functions (e.g., mailing information, database maintenance and payment processing). In the case we hire a third party to perform a function of this kind, we endeavor to only provide them with the minimum information they need to perform their specific function and to require these third parties to safeguard your information.

No Renting, Selling or Trading Out List

We will never rent, sell or trade your Personal Information to anyone. Ever. Reviewing and Updating your Personal Information You can view and update information associated with your Account that we collect for you by going to the “settings” function on our website or the Dashboard applications we offer for our Services. The credibility and relevance of our services depend on your providing us with complete, accurate and up-to-date information about yourself and your accounts, both now and in the future.

Email Marketing Opt-out

When we communicate our own marketing offers to you, these communications are CAN-SPAM compliant, including the ability for you to opt-out of marketing communications.

Deletion/Retention of Personal Information

Unless you request otherwise, we will retain the Personal Information we collect from you indefinitely. SecFi, as a registered investment advisor, must comply with certain legal and regulatory requirements pertaining to record retention. We will respond to any requests we receive asking that we delete Personal Information that we possess from those who use our services, downloaded our Dashboard or registered and established a user profile. However, we will not delete information that we are required to retain in order to comply with applicable laws and regulations.

Security

SecFi takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free therefore, we cannot ensure or warrant the security of any information you transmit to us.

Other Important Information
Former Clients

If you are a former Client, these policies also apply to you; we treat your information with the same care as we do information about current Clients.

How You Accept This Policy

By using and continuing to use the SecFi Site and/or Services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version.

Changes to the Policy

We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or app. Please check the effective date at the top of this page to determine if there have been any changes since you have last reviewed the SecFi privacy policy.

Your Rights as a California Resident

Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at info@secfi.com. Your request should specify your full name and the email address you used when submitting personal information to us.

Your Rights as a Vermont Resident

We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by entering into our Customer Agreement, please contact us at info@secfi.com. Please note, however, that we will not be able to provide you with services through SecFi without the ability to share this financial information.

International Visitors

This Service is hosted in the United States. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy.

Questions

If you have any questions on the privacy policy, please contact us at:
SecFi, Inc.
11F, 600 California Street,
San Francisco, CA 94108
info@secfi.com

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