February 16, 2024

This Privacy Policy explains how 2ndVault Company collects, uses, and discloses

information about you.

This Privacy Policy (“Policy”) discloses the privacy practices for 2nd Vault, Inc a Florida C-
Corporation (referred to as the “Service”). This Privacy Policy applies to the information we
collect though the services and products (collectively, the “Service”) provided by 2ndVault
Company (referred to as “2ndVault” “us” or “we” or “our”), via 2ndVault’s online site(s) and
mobile application. We are committed to protecting your privacy online and this privacy
policy applies to the information we collect through our services and products via 2ndVault’s
online service site(s) and website.

Please read the information below to learn about your use of this service. The privacy policy
explains what and how we collect, share, use and protect your personal information when
you visit or use this service.

We reserve the right to change this Privacy Policy at any time and in our sole discretion. Such
changes, modifications, additions or deletions shall be effective immediately upon notice
thereof, which may be given by means including, but not limited to issuing an email to the
email address listed by registered users or posting the revised Policy on this page. You
acknowledge and agree that it is your responsibility to maintain a valid email address as a
registered user, review this site and this Policy periodically and to be aware of any
modifications. Your continued use of the service after such modifications will constitute your:
(a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by
the modified Policy.

We encourage you to review this Privacy Policy (which can be found at
https://2ndvault.com/privacy-policy/) regularly to stay informed about our information
practices and the choices available to you.

You (referred to as “you” or “user” or “your” or anyone acting on your behalf) acknowledge
that this Privacy Policy is part of our service’s Terms and Conditions, and by accessing or
using our services, you agree to be bound by all its terms and conditions. If you do not agree
to these terms, you may not access or use our service.

1.Collection of Your Information

1.1 Types of Information Collected

Our primary goal in collecting information from you is to provide you with a smooth, efficient,
and customized experience while using our service. In order to better provide you with our
numerous services, we collect your name, address, telephone number(s), email address, and
such other information about you that you may consider personal and confidential
(collectively “personal information”). When purchasing our service or subscribing to any free
trial service on our site, you may be asked to provide a credit card number. Depending upon
the activity, some of the information we ask you to provide is identified as mandatory and
some as voluntary. If you do not provide the mandatory data with respect to a particular
section, you will not be able to engage in that activity.

We gather certain information about you based upon where you visit on our site in several
ways. This information is compiled and analyzed on both a personal and an aggregated
basis. This information may include the Website’s Uniform Resource Locator (“URL”) that you
just came from, which URL you next go to, what browser you are using, and your Internet
Protocol (“IP”) address. A URL is the global address of documents and other resources on the
World Wide Web. An IP address is an identifier for a computer or device on a Transmission
Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks
like the Web use the TCP/IP protocol to route information based on the IP address of the
destination. In other words, an IP address is a number that is automatically assigned to your
computer whenever you are surfing the web, allowing web servers to locate and identify your
computer. Computers require IP addresses for users to communicate on the Internet.

1.2 Information You Provide to Us

When you create an account, we ask that you provide your name, email address, and other
personal information, such as job title, username and password, and your photo if you
choose to upload it. If you are acting as a personal advisor (“advisor”) and creating an
account for another individual (your “client”), you may provide us with personal information
about your client, such as their name and contact information. If you disclose any personal
information relating to other people, such as your clients or your clients’ families, to us or to
our service providers in connection with the Service, you represent that you have the
authority to do so and to permit us to use the information in accordance with this Privacy
Policy. Our Service is intended to gather and store information in one, easy-to-reference
place. Accordingly, when you use our Service, you may input information, including
information about bank accounts, credit card information, health-related information,
insurance information, household planning and organizational documents, identification
documents, tax documents, account details, and other similar information. We also collect
information when you participate in interactive features on our Service (like sending a
notification through our Service), fill out a form, participate in a promotion, request customer
support, or otherwise communicate with us. In addition, if you choose to participate in our
online certification training as an advisor, we collect information regarding your progress
throughout the training, such as assignments completed and assignment scores.

When you access or use our Service, we automatically collect certain information, including:

Transactional Information
Device Usage Information
Location Information
Analytics Information
Information Collected by Cookies and Similar Tracking Technologies

You provide certain personal information to us when you: (a) register for our services and
register your email address with us; (b) sign up for special offers from selected third parties;
(c) send email messages, submit forms or transmit other information by telephone or letter;
or (d) submit your credit card or other payment information when registering for a free trial or
purchasing our service on our site. We may collect personal information from you at other
points on our site that state the information is being collected.
In addition, we may also collect, or our third-party ad server and/or content server may
collect other information from you. This information is ultimately stored in the form of store
categories, and, in some cases, specific URLs. We use your IP address to diagnose problems
with our servers, software, to administer our site and to gather demographic information. Our
third-party ad servers will also provide us with summary, but not individual, user reports that
will tell us how many ads were presented and clicked upon at out site. 2ndVault does not
engage in any advertising agreements, paid or nonpaid and does not permit advertising
inside our service.

We will primarily use your personal information to provide our services to you, as required by
our agreements with you. We will also use your personal information to enhance the
operation of our site, improve our marketing and promotional efforts, statistically analyze site
use, improve our service, and customize our site’s content, layout, and services. We may use
personal information to deliver information to you and to contact you regarding
administrative notices. We may also use personal information to resolve disputes,
troubleshoot problems and enforce our agreements with you, including our site’s terms and
conditions, this Private Policy and our Partner Portal Terms and Conditions.

1.3 Information We Collect from Other Sources

We obtain information from other sources. For example, we may collect information about
you from third parties, including, but not limited to, publicly available sources and your
designated advisors and/or clients.

1.4 Information We Derive

We may derive information or draw inferences about you based on the information we
collect. For example, we may make inferences about your approximate location based on
your IP address.

1.5 Use of Your Information

We use the information we collect to: Provide, maintain, and improve our Service; Personalize
and improve your experience on our Service; Send you technical notices, security alerts, and
support and administrative messages; Respond to your comments and questions and
provide customer service; Communicate with you about products, services, and events
offered by 2ndVault and others, and provide news and information that we think will interest
you (see the User Choices section below for information about how to opt-out of these
communications at any time); Monitor and analyze trends, usage, and activities in
connection with our Service; Facilitate social sharing functionality that you choose to use;
Allow you to send and receive notifications through the Service if you choose to do so;
Aggregate and/or anonymize personal information so that it will no longer be considered
personal information; Facilitate contests, sweepstakes, and promotions and process and
deliver entries and rewards, detect, investigate, and prevent security incidents and other
malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of
2ndVault and others; Debug to identify and repair errors on our Service; Comply with our legal
and financial obligations; and Carry out any other purpose described to you at the time the
information was collected.

2. Sharing of Information

We do not sell, trade, or rent your personal information. We do provide some of your personal
information through contractual arrangements with affiliates, services providers, partners
and other third parties. We and our service partners use your personal information to operate
our sites and to deliver you our service. For example, we must release your credit card
information to the card-issuing bank to confirm payment for the service purchased on this
site.

We share personal information in the following circumstances or as otherwise described in
this Privacy Policy: We share personal information on an as-needed basis with vendors,
service providers, and consultants that require access to such personal information solely in
order to perform services for us, such as web hosting, data analysis, information technology,
videoconferencing, fraud prevention, customer service, and marketing and advertising. We
contractually limit their use of the personal information we share with them and require them
to protect such information.

We will encourage our service partners to adopt and post privacy policies. However, the use
of your personal information by our service partners is governed by the privacy policies of
those service partners and is not subject to our control.

Occasionally we may be required by law enforcement or judicial authorities to provide
personal information to the appropriate governmental authorities. We will disclose personal
information upon receipt of a court order, subpoena, or to cooperate with a law enforcement
investigation. We fully cooperate with law enforcement agencies in identifying those who use
our services for illegal activities. We reserve the right to report to law enforcement agencies
any activities that we in good faith believe to be unlawful. We share personal information with
our lawyers and other professional advisors where necessary to obtain advice or otherwise
protect and manage our business interests. We may share personal information in
connection with, or during negotiations concerning, any merger, sale of company assets, joint
venture, assignment, financing, transfer, or acquisition of all or a portion of our business by
another company (including in connection with any bankruptcy or similar proceedings). We
share personal information with your consent or at your direction. We also share aggregated
or de-identified information that cannot reasonably be used to identify you.

We may also provide information about our customers’ sales, traffic patterns, and related
site information to third party advertisers, but these statistics do not include any of your
personal information.

We may share personal information with third-party sponsors of contests or other
promotions. You may elect to disclose personal information with other users of our Service
when you make content available in publicly-accessible areas of our Service or when you
choose to share personal information with your designated advisors and/or clients.

3. Social Sharing Features

Our Service may offer social sharing features and other integrated tools (such as the
Facebook “Like” button). Your use of such features enables the sharing of information with
your friends or the public, depending on the settings you establish with the entity that
provides the social sharing feature. For more information about the purpose and scope of
data collection and processing in connection with social sharing features, please visit the
privacy policies of the entities that provide these features.

4. Security

We seek to use reasonable organizational, technical, and administrative measures designed
to protect personal information within our organization. Unfortunately, no data transmission

or storage system can be guaranteed to be 100% secure. If you have reason to believe that
your interaction with us is no longer secure, please immediately notify us in accordance with
the “Contact Us” section below. If you believe you are the victim of fraud, you should contact
law enforcement immediately.

The importance of security for all personal information with our user is paramount. Your
personal information is protected in several ways. Access by you to your personal information
is available through a password and unique customer ID selected by you. This password is
encrypted. We should not divulge your password to anyone. We encrypt your personal
information and thereby prevent unauthorized parties from viewing such information when it
is transmitted to us. All of the personal information that you add to your vault is saved on
servers in user encrypted, has layered encryption, end-to-end encryption, two-factor
authentication, no manual intervention, unique confidant codes, account cleanup after
retrieval, manual verification to retrieve an account from a confidant request. These security
measures are intended to prevent someone or something to decrypt this information. For
details on our security measures please visit https://2ndvault.com/security/.

Other information that you provide that is not personal information also resides on a secure
server and is only accessible via password. Since this information is not accessible from
outside our service, you will not be asked to select a password in order to view or modify such
information.

In order to serve you most efficiently, credit card transactions are handled by established
third party banking, processing agents and distribution institutions. They receive personal
information needed to verify and authorize your credit card or other payment information
and to process your order.

Unfortunately, no data transmission over the Internet, mobile deice, or tablet application,
server, database or any wireless network can be guaranteed to be 100% secure or “hacker
proof.” As a result, while we strive to protect your personal information, and you acknowledge
by using our service and the site that: (a) there are security and privacy limitations of the
Internet which are beyond our control; (b) the security, integrity and privacy of any and all
information (personal and non-personal) and data exchanged between you and us through
this site cannot be guaranteed; and (c) any such information (personal and non-personal)
and data may be viewed or tampered with in transit by a third party. Therefore, you should
have no expectation of complete privacy in such information (personal and non-personal).

5. Data Retention

We store the information we collect on you for as long as is necessary for the purpose(s) for
which we originally collected it, or for other legitimate business purposes, including to meet
our legal, regulatory, or other compliance obligations.

6. Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information,
or other practices of any third parties, including any third party operating any website or
service to which the Service links. The inclusion of a link on the Service does not imply
endorsement of the linked site or service by us or by our affiliates.

7. Jurisdictional Issues

The Service is controlled and operated by us from the United States and is not intended to
subject us to the laws or jurisdiction of any state besides Florida, country, or territory. For more
information about litigation and jurisdiction please visit our Terms of Use
(https://2ndvault.com/terms-and-condition-of-use/)

8. Updating and Correcting Information

You should have the ability to access and edit the personal information that you have
provided to us. You may change any of your personal information in your account online at
any time by linking to your account in accordance with instructions posted elsewhere on this
site. You may also access and correct your personal information and privacy preferences by
writing us with certified mail return receipt requested at:

2nd Vault, Inc
2825 NE 26 th Street
Fort Lauderdale, Florida 33305

Please include your name, address, and/or email address when you contact us.
DO NOT PROVIDE US WITH YOUR CONFIDANT CODE (as outlined in our Terms and Conditions)
OR ANY PERSONAL INFORMATION ASSOCIATED WITH YOUR ACCOUNT THAT YOU MAY HAVE
UPLOADED OR DOWNLOADED FROM OUR SITE.

We strongly encourage you to promptly notify us of any changes to your personal
information if it changes. You may ask to have the information on your account deleted or
removed; however, because we keep track of past transactions, you cannot delete
information associated with past transactions on this site. In addition, it may be impossible to
completely delete your information without some residual information because of backups or
other technical glitches. Upon us receiving your request to have your account deleted, your account will be deleted subject to the exclusions in this privacy agreement and as outlined in our terms and conditions.

9. User Choices on Collection and Use of Information

We may send you emails regarding our service. In addition, if you indicated upon registration
that you are interested in receiving offers or information from us, we may occasionally send
you direct mail about services that we feel may be of interest to you. Only we will send you
these direct mailings and only if you indicated that you do not object to these offers. If you do
not want to receive such mailings, simply tell us when you give us your personal information,
or, at any time you can easily edit your account information to no longer receive such offers
and mailings.

You also have choices with respect to cookies, as described below. By modifying your browser
preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or
to reject all cookies. If you choose to reject all cookies some parts of our site may not work
properly for you. in your case.

10. Cookies

When you use our site, we will store cookies on your computer in order to facilitate and
customize your use of our site. A cookie is a small data text file, which a Web site stores on
your computer’s hard drive (if your Web browser permits) that can later be retrieved to
identify you to us. Our cookies store randomly assigned user identification numbers, the
country, county, or city where you are located, and your first name to welcome you back to
our site. The cookies make your use of the site easier, make the site run more smoothly and
help us to maintain a secure site. You are always free to decline our cookies if your browser
permits, but some parts of our site may not work properly in that case.
We use cookies to collection information about the ways visitors use our sites, which pages
they visit, which links they use, and how long they stay on each page; to support the features
and functionality of our site; and to personalize your experience when you use our site,
including the serving of targeted advertisements.
Your mobile or tablet device may allow you to adjust your settings so that location
information is not available to any mobile website or application. If you have questions about
the security and privacy settings of your mobile or tablet device, please refer to instructions
from your mobile service provider or the manufacturer of your device.
We may use an outside ad serving company to display banner advertisements on our site. As
part of their service, they will place a separate cookie on your computer. We will not provide
any third- party ad server with any of your personal information or information about your
purchases. We and our third party ad server will collect and use any other information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular ad. Other advertisers may also place banner ads on our site in the same manner as above, but we will not disclose any personal information to them.

11. Privacy Policies of Third-Party Sites

Except as otherwise discussed in this Privacy Policy, this document only addresses the use
and disclosure of information we collect from you. Other sites accessible through our site
have their own privacy policies and data collection, use and disclosure practices. Please
consult each site’s privacy policy. We are not responsible for the policies or practices of third
parties. Additionally, other companies which place advertising on our site may collect
information about you when you view or click on their advertising using cookies. We cannot
control this collection of information. You should contact these advertisers directly if you have
any questions about their use of the information that they collect.

12. Miscellaneous Privacy Issues

You must be at least 18 years old to have our permission to use this site. Our policy is that we
do not knowingly collect, use or disclose personal information about visitors that are under 18
years of age.

You should also be aware that when personal information is voluntarily disclosed on this site,
that information, along with any other information disclosed in your communication, can be
collected and used by third parties and may result in unsolicited messages from third parties.
Such activities are beyond our control and this privacy policy does not apply to such
information. Ultimately, you are solely responsible for maintaining the secrecy of your
password and/or account information. Please be careful and responsible whenever you are
online.

If you have any questions about this privacy policy, the practices of this site, or your dealings
with this site, please contact us by sending a letter to:

2nd Vault, Inc
Privacy Policy
2825 NE 26 th Street
Fort Lauderdale, Florida 33305

You may also contact us by email at support@2ndvault.com