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California Privacy Disclosures

eMONEY ADVISOR, LLC PRIVACY POLICY ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

Last Updated: July 1, 2025

These Additional California Privacy Disclosures (“CA Disclosures”) are provided pursuant to our obligations under California laws, including the California Consumer Privacy Act (“CCPA”), and supplement the information contained in the eMoney Privacy Policy (“Privacy Policy”).

These CA Disclosures apply to our processing of personal information of individual California residents within the scope of CCPA. Any terms defined within the CCPA have the same meaning when used within these CA Disclosures. The other provisions of the Policy continue to apply except as modified in these CA Disclosures.

Unless otherwise noted, these CA Disclosures describe how and why we collect, use, and disclose personal information subject to the CCPA, as well as how we have collected, used, and disclosed that personal information in the prior 12 months.

Collection, Use, and Disclosure of Personal Information

As described in the Our Collection of Personal Information section of our Privacy Policy, we collect personal information directly from you when you provide it to us, automatically when you visit our Sites and use our Services, from publicly available sources, and from service providers and other parties, including business partners, advisors, and financial institutions. This includes:

  • Identifiers: Name, postal address, phone number, email address, and similar identifiers.
  • Personal Information Categories in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)): including your contact information; identifiers, such as name, email address, mailing address, phone number, account identifier, and security/authentication information; financial account information; information relating to education, employment, and employment history; joint account holder and family information; credit and identity information relating to your account; account history relating to your account; and any other information you provide to us, including tax records, income level, and signature.
  • Protected Classification Characteristics: including age, date of birth, gender, and sex.
  • Commercial Information: including account history, investment history, purchases, transaction information, insurance coverage information, service profile information, interests, and feedback information, order details, order/product preferences, and credit information.
  • Device Information and Other Unique Identifiers: including log file data (e.g., IP address, browser type, clickstream data) and cookies and related technology data (e.g., your usage and activity on our Sites or Services).
  • Geolocation Data: including your geographic area based on your IP.
  • Sensory Information: including voice recordings from calls to customer service.
  • Profession/Employment Information: including represented business, employer, department, income, work history, and job title.
  • Inferences Drawn from Personal Information Collected: including user preferences, customer characteristics, and behaviors.
  • Sensitive Information: including social security, driver’s license, state identification card, or passport number; racial or ethnic origin; religious or philosophical beliefs; union membership; and sexual orientation.

We collect the above categories of personal information for the purposes described in the Our Use of Personal Information section of our Privacy Policy. For representatives of our clients, vendors, service providers, and other parties, we also collect your personal information to maintain an ongoing relationship between us and the entity you represent and to contact you in connection with our relationship with the entity you represent.

As described in the Disclosures of Personal Information section of our Privacy Policy, we disclose the above categories of personal information with a variety of parties, including our affiliates, business partners, service providers, and contractors. For representatives of our clients, vendors, service providers, and other parties, we also disclose your personal information with the entity you represent.

Retention of Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including our internal operational and business purposes; as required to satisfy any legal, obligations; or as necessary to resolve disputes. To determine the appropriate retention period for your personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes we process your personal information for, and whether we can achieve those purposes through other means.

Selling and Sharing of Personal Information

eMoney does not sell personal information in exchange for monetary compensation. However, we disclose personal information to third parties via cookies and other online tracking technologies on our websites for cross-context behavioral advertising and other advertising, marketing, or analytics purposes. Under the CCPA, these kinds of disclosures may be considered a “sale.” The Cookies and Other Online Tracking Technologies section Privacy Policy includes more information about the processing of personal information through the use of cookies and online tracking technologies, including how to control your privacy settings. However, under the CCPA, we sell or share for cross-context behavioral advising purposes the following categories of personal information to advertisers and marketing partners, data analytics providers, and social media networks for advertising purposes via website cookies and tracking technologies:

  • Identifiers.
  • Commercial Information (e.g. purchase information, feedback information).
  • Device Information and Other Unique Identifiers (e.g., IP address, browser type, clickstream data) and cookies and related technology data (e.g., your usage and activity on our Sites or Services).
  • Geolocation Data (e.g. general geographic location based on your IP address).

Your Privacy Rights

Subject to certain limitations, California residents have the right to submit certain requests related to personal information, as detailed below.

Right to Know. You have the right to request:

  • The categories of personal information we have collected about you, including:
    • The categories of sources from which the personal information was collected;
    • Our business or commercial purposes for collecting, selling, or sharing personal information;
    • The categories of recipients to which we disclose personal information;
    • The categories of personal information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of personal information; and
    • The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of PI.
  • The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request the deletion of personal information we have collected about you. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.

Right to Correct. You have the right to request the correction of personal information we have collected about you.

Right to Opt Out. You have the right to direct us to not sell your personal information or share your personal information for cross-context behavioral advertising, as described in the Selling and Sharing of Personal Information section above. You can opt out of sales and sharing using cookies and related technologies by clicking the “Do Not Sell or Share My Personal Information” link in our website footer and selecting your preferences, or by using the global privacy control (“GPC”) signal. Please note GPC signals are browser dependent and some browsers may not accept GPC signals unless a browser extension is used; please refer to your browser requirements to ensure you are transmitting the GPC signal accurately. Please note that your use of our website may still be tracked by eMoney and/or our service providers when necessary, such as to provide the website or security purposes.
We do not knowingly sell the personal information of consumers under 16 years of age.

Right to Limit. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclose applies under the CCPA.

Right to Non-Discrimination. You have the right to be free from discrimination for exercising any of the rights described above.

How to Submit a Request

To Exercise Your Right to Know, Delete, Correct, or Limit as a California Resident, please submit a request by:

  • Calling 1-888-362-8482, select Option 1 for Customer Support and then select Option 9 to speak with a client services representative trained to address your request.
  • Completing our privacy rights request form.

If you participate in a workplace retirement plan, or other employee benefit plan sponsored by or provided through your employer, and that is serviced or administered by a company using eMoney’s services, your CCPA request should be directed to your employer. Please note as well that not all of the personal information collected or processed by eMoney is subject to the CCPA—for example, if your relationship and interactions with eMoney consist solely of personal financial services (e.g., your advisor provides you financial planning access through our Services).

We will need to verify your identity before processing your request. To verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion, certain requests may require us to obtain additional personal information from you.

In certain circumstances, we may decline a request to exercise the right to know, right to deletion, and/or right to correct, particularly where we are unable to verify your identity.

You may designate an authorized agent to submit a request on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; or (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

If you have been designated as an authorized agent to submit a request on behalf of another consumer, you must (1) download and complete this Authorized Agent Designation Form found here and have it signed by the consumer, and (2) attach the signed form when you submit a request to us at privacy@emoneyadvisor.com.

California “Shine the Light” Law

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). We may disclose personal information to affiliates, which may use this information for all purposes outlined in our Privacy Policy. Because separate legal entities are considered “third parties” for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their financial services, we are providing the following information for California residents who have provided us with their personal information during the creation of or during the course of an established services relationship that is primarily for personal, family, or household purposes (“Individual California Users”). Individual California Users must submit their requests to us either by email at privacy@emoneyadvisor.com or by mail at the address listed in the How to Contact Us section of the Privacy Policy and specify that you want a copy of your “Shine the Light” California Privacy Rights Policy.

We will provide a list of the categories of personal information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

Changes to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the date at the beginning of these CA Disclosures to include the “Last Updated” date. All changes shall be effective from the date of publication unless otherwise provided in the notification.

How to Contact Us

If you have any questions regarding these CA Disclosures, please contact us by email at privacy@emoneyadvisor.com using the subject title of “California Privacy Disclosures.”

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