Privacy Policy

Thank you for choosing to be part of our community at Ark7 Inc. (“Company ”, “we”, “us”, or “our”). We take your privacy seriously and do our best to protect it. We are required by law to ask for certain information in order to perform our services for you, but we are committed to protecting your personal and financial information. Below are basic privacy principles or privacy policy "bill of rights" that we adhere to. This Bill of Rights includes the following list of policies:

1. We don't ask you for personal or financial information unless we need it.
2. We don't share your personal information with anyone except to comply with the law, develop our products, or protect our rights.
3. We aim to make it as simple as possible for you to control what's visible to the public, seen by search engines, kept private, and permanently deleted.
4. We will send you emails relating to specific transactions but will keep these emails to a minimum.
5. We will maintain appropriate security standards and procedures to protect your information.
6. We will respect the trust you place in us and the confidential nature of the information you provide through your financial relationship with us.

In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important.

BY USING THE SERVICES, YOU AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THESE TERMS, PLEASE DO NOT USE THE SERVICES.

This privacy policy applies to all information collected through our website (such as https://ark7.com), our mobile app, and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Table Of Contents

• What Information Do We Collect?
• How Do We Use Your Information?
• Will Your Information Be Shared With Anyone?
• Who Will Your Information Be Shared With?
• Do We Use Cookies And Other Tracking Technologies?
• How Long Do We Keep Your Information?
• How Do We Keep Your Information Safe?
• Do We Collect Information From Minors?
• What Are Your Privacy Rights?
• Controls For DO-NOT-TRACK Features
• Do California Residents Have Specific Privacy Rights?
• Do We Make Updates To This Policy?
• How Can You Contact Us About This Policy?

1. What Information Do We Collect?

Personal information you disclose to us

In Short: Information that you provide to us such as name, address, date of birth, social security number, bank account information, contact information, and passwords and security data.

We collect personal information that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites , the choices you make and the products and features you use. The personal information we collect can include the following:

Identification and Contact Data. We collect your first and last name, date of birth, social security number, email address, postal address, phone number, and other similar contact data.

Investment Profile. We collect your investment profile information solely for the purpose to comply with certain SEC regulations. You may voluntarily provide to us with information about your investment profile, such as, income level, return expectations, net worth, investment experience.

Credentials. We or our third-party service providers may collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, including payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to You by us.

All payment data is stored by our payment facilitator and you should review its privacy policies and contact the payment facilitator directly to respond to your questions.

Customer Support. We collect the information about your use of our services you provide when you contact us, including information about our products that you own and your contact details, so that we can provide customer support.

Your personal information may be accessed by us or transferred to us in the United States. By providing us with personal information, you consent to this transfer and consent to the storage or processing of personal information in the United States and acknowledge that the personal information will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of Your Personal Information.

If you are outside the United States, no matter where you live or where you happen to use our services, your information, including personal information, may be shared with our current and future parents, affiliates, subsidiaries and other companies under common control and ownership. We may collect your personal data from, transfer it to, and store and process it in other countries outside of where you live.

We may use your personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites.

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics like browser type and browser version, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

When you access our services by or through a mobile device, the information we automatically collect may include the type of mobile device you use, your mobile device 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.

You can enable and disable communicating certain information which would be automatically collected by us by adjusting your device security and privacy settings.

Like many businesses, we also collect information through cookies and similar technologies.

Location Information

In Short: We may collect information about your location if you give us permission to do so or information that may disclose the location of your device when you access our website.

We may use and store information about your location if you give us permission to do so. We use this information to provide features of our services, to improve and customize our services. We also collect your computer or mobile device’s source IP address, which may disclose the location of your computer or mobile device at the time you access our website. While you can always decide not to share information about your location with us, You must agree to provide certain types of location information if you want to use our services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information like your user name or handle, date of birth, and pictures, marketing leads and search results and links, including paid listings (such as sponsored links). We do not have access to your third-party account passwords. The data we receive from other sources is dependent upon your privacy settings with these third parties. You should always review, and if necessary, adjust your privacy settings on those Accounts before linking or connecting them to our sites. We use information obtained from other sources to operate, maintain, and provide to you the features and functionality of our services, to process orders, to provide customer services, and to communicate directly with you, such as to send you information about your orders, product sales, special offers, and new site features.

The following is a list of current third party analytics tools that may either directly or indirectly collect information from you. Please review the relevant privacy policies (links current as of the date of publication of this Privacy Policy) for further information on how each third party handles your personal information:

2. How Do We Use Your Information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
• To send you marketing and promotional communications. We participate in interest-based advertising and use third-party advertising companies. We permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our website over time. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "What Are Your Privacy Rights" below).
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfill and manage your orders. We may use your information to fulfill and manage your orders and payments made through the Sites.
• To protect our Sites. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions and policies.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites , products, services, marketing and your experience.

We engage in these activities to comply with a legal obligation or because we have a legitimate interest. To the extent that we process your information based on your consent, you may withdraw your consent at any time.

3. Will Your Information Be Shared With Anyone?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, payment facilitators, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: facilitating payments, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites , which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your 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.
• 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 subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

4. Who Will Your Information Be Shared With?

In Short: We only share information with the following third parties.

Identified Parties. We only share and disclose your information with the following third parties. These third parties only have access to your personal information to the extent of performing these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

• Advertising, Direct Marketing, and Lead Generation Google AdSense, Sendgrid
• Retargeting Platforms Facebook Custom Audience, Google Ads Remarketing
• Access Control and Security Authentication Amazon Simple Notification Service, Amazon Cognito
• Web and Mobile Analytics Google Analytics
• Website Performance Monitoring Firebase Crashlytics
• Payment Facilitator Dwolla
• Financial Account Connection Plaid, Inspira Financial Company

Please review the relevant privacy policies of the third parties above (links current as of the date of publication of this Privacy Policy) for further information on how each third party handles your personal information:

Unidentified Parties. We disclose your information with the third party in the following circumstances:

• Business Transaction. If we are involved in a merger, acquisition or asset sale, your personal information may be shared. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.
• Disclosure for Law Enforcement. We may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
• Legal Requirements. We may be required to disclose your personal information in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend our rights or property, to prevent or investigate possible wrongdoing in connection with our services, to protect the personal safety of our users or the public, or to protect against legal liability.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties. The inclusion of a link does not imply endorsement of the linked site or Services by us.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other application developer, application provider, social media platform provider, operating system provider, wireless services provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with our services.

5. Do We Use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about the device, such as: user settings, browsing history, and activities conducted while using our services.

Our Services use the following cookies:

• Strictly necessary cookies, which are required for the operation of our services. Without them, for example, you would not be able to use your account.
• Analytical/performance cookies, which allow us to recognize and count the number of visitors, learn how visitors navigate the services, and improve the services.
• Functionality cookies, which we use to recognize you when you return to the Services.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 90 days past the termination of the user's account.

We also retain your information for internal analysis purposes. Information retained for such purposes is generally kept for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. We will protect the privacy and security of your personal information according to this Privacy Policy, regardless of where it is processed or stored. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites , you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@ark7.com.

9. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.

Account Information

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account.
• Contact us using the contact information provided.

In certain circumstances, you have the right:

• To access and receive a copy of the personal information we hold about you;
• To rectify any personal information held about you that is inaccurate; and
• To request the deletion of personal information held about you

If you wish to enforce your rights above, please also contact us using the contact information provided.

Although You cannot opt-out of all data collection when You use Our Services, You can limit the collection, use and sharing of your personally identifiable information.

You have the right to data portability. You can request to obtain a copy of your personal information in a commonly used electronic format so that You can manage and move it. Be advised that we may not be able to delete your information without also deleting your user account. You will not be permitted to examine the personal information of any other person or entity and may be required to provide us with personal information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement or result in incorrect information.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

If you do not want us to collect your personal information, please do not provide it to us. Please understand that if you choose not to provide certain personal information to us, your choice will restrict your ability to access some content and use some of the functionality of our services.

For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Sites, visit http://www.aboutads.info/choices.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

• Note your preferences when you register an account with the site.
• Access your account settings and update preferences.
• Contact us using the contact information provided.

10. Controls For DO-NOT-TRACK Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

11. Do California Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.

For more about your consumer privacy rights as a California resident, please review the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020.

12. Do We Make Updates To This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may email us at legal@ark7.com or by post to:

Ark7 Inc.
1 Ferry Building, Ste 201
San Francisco, CA 94111
United States
Attention: Ark7 Legal