FUND&GROW PRIVACY POLICY

Last Updated: February 26, 2026

Welcome to the fundandgrow.com website (the "Site"). This policy (the "Privacy Policy") is designed to tell you about our practices regarding collection, use, and disclosure of information that you may provide via this Site and certain related Services.

Please read this Policy carefully to understand how we collect and use your Personal Information, the choices you have for controlling your Personal Information and the circumstances under which we may share such information with others. This Policy forms part of the Terms that govern your use of the Site, the Services, and any Client Agreement you may enter into now or in the future.

By using this Site, the Services, and/or entering into any Client Agreement you consent to this Policy. We may update this Policy periodically; the "Last Updated" date will reflect changes. Continued use after changes constitutes acceptance of the revised Policy.

Quick Links

1. What information is subject to this Policy?
2. Does Fund&Grow Collect NPI?
3. How does Fund&Grow collect Personal Information?
4. Why do we collect your Personal Information?
5. Who do we share your Personal Information with?
6. How does Fund&Grow use and share your Personal Information?
7. What are your rights and choices?
8. How do you opt out of data sharing?
9. How do you make a request to exercise your rights or choices?
10. What is Fund&Grow’s Cookie Policy?
11. What is de-identified or aggregate data and how does Fund&Grow use such data?
12. How does Fund&Grow protect your Personal Information?
13. How does Fund&Grow protect your financial information?
14. What other steps can you take to protect your account?
15. What about children’s privacy?
16. Does Fund&Grow use or process Personal Information outside the country where the data was originally collected?
17. How does Fund&Grow retain Personal Information?
18. What do you need to know about links to third party websites?
19. What else should you know about your privacy?
20. How will we inform you of changes to this Policy?
21. State Specific Disclosures
22. Contact Us.

1. What information is subject to this Policy?
   1. Personal Information

      "Personal Information" refers to any information, in any form, about an identified or identifiable individual or household, including an individual or household whose identity may be inferred or determined from such information.

      Fund&Grow may collect the following Personal Information about you: name, address, email, phone number, birthdate, gender, communication preferences, location data, employment data, IP address, browsing history, transaction history, account information, and information from communications with us.

   2. Sensitive Personal Information

      “Sensitive Personal Information” is a more sensitive subset of Personal Information.

      Fund&Grow may collect the following categories of Sensitive Personal Information: Identification numbers (SSN, driver's license, passport), financial account credentials, precise geolocation, racial/ethnic origin, citizenship/immigration status, gender (where considered sensitive), credit profile information, and exact contents of certain communications.

      Unless expressly stated otherwise in this Policy, we refer to Personal Information and Sensitive Personal Information together as “Personal Information.”

   3. What is not Personal Information?

      Personal Information does not include the following: publicly available information; de-identified or aggregated consumer information; or information exempted from applicable state privacy laws, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act (“FCRA”), or health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), etc.

   4. Non-Public Personal Information (“NPI”)

      NPI is non-public information collected by financial institutions under the Gramm-Leach-Bliley Act and certain state laws, including information consumers provide to obtain financial products/services, transaction results, or information obtained in connection with providing financial products/services.

2. Does Fund&Grow Collect NPI?

   Yes. As a company that conducts activities that are financial in nature, Fund&Grow is a “financial institution”, as that term is defined by the GLBA, and certain of the information it collects from, or about, you qualifies as NPI. If you utilize our financial products and services, we will use and share any information that we collect from, or about, you in accordance with our Gramm-Leach-Bliley Act Privacy Policy, which offers you certain choices with respect to the use and sharing of your personal information.

3. How does Fund&Grow collect Personal Information?

   Fund&Grow collects only the Personal Information data that is reasonably necessary and proportionate to our legitimate business purposes.

   We collect Personal Information:

   • Directly from you when you use the Site or Services
   • Automatically via cookies and similar technologies (see Cookie Policy)
   • From third parties including affiliates, service providers, social media platforms, online databases, and marketing data providers. We also purchase marketing data about our customers from third parties and combine it with the Personal Information or Sensitive Personal Information our customers provide us, to offer advertising and products from our company or one of our subsidiary companies.
   
   
4. Why do we collect your Personal Information?

   We collect Personal Information to provide the products and Services you purchase and to provide you with a customized experience. This includes personalization services, interactive communications, as well as display of advertisements for valuable products and services.

   We may collect and use your Personal Information for any of the following purposes:

   • Manage your account and preferences
   • Communications with you
   • Customer support with the Site or the Services
   • Process transactions or perform the Services
   • Ensure safety, security, and fraud prevention
   • Personalize your experience
   • Conduct marketing and send advertisements
   • Manage and Improve the Site and our Services
   • Meet legal and compliance obligations
   • Conduct research on user demographics and behaviors.

   Personal Information collected for one purpose may also be used for any of the other purposes listed above.

5. Who do we share your Personal Information with?

   We will share your personal information with third parties only in the ways that are described in this Policy or the Gramm-Leach-Bliley Privacy Policy. We do not sell, rent, trade, or otherwise share your personal information with third parties without first providing you notice and choice. Fund&Grow may share your Personal Information with the following third parties:

   • Service Providers who operate the Site, provide Services, or assist with marketing/research.
   • Business Affiliates and Partners, including, but not limited to, Kaydem Credit Help, who perform certain professional services, such as payment processing, fraud prevention or detection, audits, make referrals to us or provide leads to us.
   • Financial Institutions including credit card issuers, lenders, banks, or other parties as necessary to provide the Services.
   • Subsidiaries or other entities disclosed to you at the time your information is collected or prior to sharing your Personal Information.
   • Other Parties not specifically identified in this Policy but who are necessary to accomplish any of the purposes identified in Section 4 of this Policy.
   • Legal Personnel, including our attorneys, law enforcement, courts, and regulatory bodies when legally required or to protect rights
   • Marketing Partners and Sponsors or other entities disclosed to you at the time your information is collected or prior to sharing your Personal Information.
   • Ad Servers for advertising, targeted or direct marketing, and lead generation.
   
   
6. How does Fund&Grow use and share your Personal Information?

   In the past twelve (12) months, Fund&Grow has collected and shared Personal Information for the following purposes and with the following third parties:

   Category	Source Collected From	Purpose for Collection and Use	Sharing with Third Parties for Business Purpose	Third Parties to Whom Personal Information was Sold/Shared
   A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.	· Directly from you · Automatically from your browser or device · From third parties	· Manage account · Communications · Customer support · Process transactions or perform Services · Safety and security · Personalize your experience · Marketing · Manage and improve the Site and Services · Legal or compliance · Research	· Service providers · Business affiliates and partners · Subsidiaries · Other parties · Legal Personnel · Marketing partners and sponsors · Ad servers	· Subsidiaries · Business affiliates and partners · Marketing partners and sponsors · Ad servers · Financial Institutions
   B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, employment, bank account number, credit card number, debit card number, or other financial information. Some personal information included in this category may overlap with other categories.	· Directly from you · Automatically from your browser or device · From third parties	· Manage account · Communications · Customer support · Process transactions or perform Services · Safety and security · Personalize your experience · Marketing · Manage and improve the Site and Services · Legal or compliance · Research	· Service providers · Business affiliates and partners · Subsidiaries · Other parties · Legal Personnel · Marketing partners and sponsors · Ad servers	· Subsidiaries · Business affiliates and partners · Marketing partners and sponsors · Ad servers · Financial Institutions
   C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, national origin, citizenship, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	· Directly from you · From third parties	· Manage Account · Manage and improve the Site and Services	· Service providers · Business affiliates and partners · Other parties · Legal Personnel	· Not sold/shared
   D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	· Directly from you · From third parties	· Process transactions or perform Services · Personalize your experience · Marketing · Manage and improve the Site and Services	· Service providers · Business affiliates and partners · Subsidiaries · Other parties · Legal Personnel · Marketing partners and sponsors · Ad servers	· Subsidiaries · Marketing partners and sponsors · Ad servers · Financial Institutions
   E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	· Not collected	· Not Collected	· Not collected	· Not collected
   F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement,	· Automatically from your browser or device	· Manage and improve the Site and Services · Safety and security · Marketing	· Service providers · Business affiliates and partners · Subsidiaries · Other parties · Legal Personnel · Marketing partners and sponsors · Ad servers	· Subsidiaries · Marketing partners and sponsors · Ad servers · Financial Institutions
   G. Geolocation data. Physical location or movements.	· Directly from you · Automatically from your browser or device	· Manage and improve the Site and Services · Safety and security · Marketing · Legal or compliance	· Service providers · Business affiliates and partners · Subsidiaries · Other parties · Legal Personnel · Marketing partners and sponsors · Ad servers	· Subsidiaries · Marketing partners and sponsors · Ad servers · Financial Institutions
   H. Sensory data. Audio information (including voice recordings).	· Not collected	· Not Collected	· Not collected	· Not collected
   I. Professional or employment-related information. Current or past job history or performance evaluations.	· Not collected	· Not Collected	· Not collected	· Not collected
   J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	· Not collected	· Not Collected	· Not collected	· Not collected
   K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	· Not collected	· Not collected	· Not collected	· Not collected
   L. Sensitive Personal Information Any information that reveals a consumer’s SSN, driver’s license number, or passport number, account credentials, precise geolocation, racial and ethnic origin, religious beliefs, biometric data, personal information concerning a consumer’s health or sex life or sexual orientation, as well as contents of mail, e-mail and text messages	· Directly from you · From third parties	· Manage Account · Manage and improve the Site and Services · Process transactions or perform Services	· Service providers · Business affiliates and partners · Subsidiaries · Other parties · Legal Personnel · Marketing partners and sponsors · Ad servers	· Not sold/shared

   In the preceding twelve (12) months, we have disclosed the following categories of personal information to the third parties listed above for a business purpose:

   • Category A: Identifiers.
   • Category B: California Customer Records personal information categories.
   • Category C: Protected classification characteristics under California or federal law.
   • Category D: Commercial information.
   • Category F: Internet or other similar network activity
   • Category G: Geolocation data
   • Category L: Sensitive Personal Information
   
   

   In the preceding twelve (12) months, we have shared the following categories of information for marketing or cross-context behavioral advertising purposes:

   • Category A: Identifiers.
   • Category B: California Customer Records personal information categories.
   • Category D: Commercial information.
   • Category F: Internet or other similar network activity
   • Category G: Geolocation data
   • Category L: Sensitive Personal Information
   
   
7. What are your rights and choices?

   If you live in California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the rights and/or choices described in this section:

   • Right to access: The right for a consumer to access from a business/data controller the information or categories of information collected about a consumer, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared; or, some combination of similar information. If you live in Utah, Virginia, or Connecticut, you have the right to make a request up to twice in a 12-month period.
   • Right to correct: The right for a consumer to request that incorrect or outdated Personal Information be corrected but not deleted. You may correct information at any time by logging into your account using your username and password. If you have forgotten your password, please click here and select "Forgot Password". If you have problems signing in to your account, please click here to email customer service.
   • Right to Delete: The right for a consumer to request deletion of Personal Information about the consumer under certain conditions.
   • Right to opt out of certain processing: The right for a consumer to restrict a business’s ability to process certain types of Personal Information about the consumer, such as the right to opt out of sharing of Sensitive Personal Information or profiling, where applicable.
   • Right to portability: The right for a consumer to request Personal Information about the consumer be disclosed in a common file format.
   • Right to opt-out of sales or sharing: The right for a consumer to opt out of the sale of Personal Information about the consumer to third parties.
   • Right to limit the use of Sensitive Personal Information: You may have a right to limit our use of sensitive personal information for any purposes other than to provide the Services or goods you request or as otherwise permitted by law. ·
   • Right against automated decision making: A prohibition against a business making decisions about a consumer based solely on an automated process without human input. We do not engage in automated decision making.
   • Right to appeal: Where a controller declines to take action regarding a consumer's request to exercise any privacy right, the controller must allow the consumer to appeal the decision and provide instructions on how they may request an appeal.
   • Private right of action: Some states give you the right to seek civil damages from us for violations of data privacy laws.
   • Right to withdraw consent: You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.
   • Right of Non-Discrimination: You have a right to exercise your rights under this section free of discrimination. Fund&Grow will not discriminate against you in any way if you choose to exercise your rights under this section.

   Please Note: These rights do not extend to Personal Information that is exempted from your state’s applicable privacy laws. For information exempted from state privacy laws under the GLBA, please see our Gramm-Leach-Bliley Act Privacy Policy for more information about how we use and process your information and your rights.

8. How do you opt out of data sharing?
   1. Opt Out Request Form

      Submit opt out requests through our Data Request Form

   2. Universal Opt Out Mechanism

      We honor Global Privacy Control (GPC) and other opt-out signals as requests to:

      • Opt out of personal information sales
      • Opt out of sharing for targeted advertising
      • Limit use of Sensitive Personal Information
      • Your opt-out applies only to the specific browser/device sending the signal. Renew if you switch devices/browsers or clear cookies.
   
   
9. How do you make a request to exercise your rights or choices?
   1. How to make a Request

      To exercise your rights or to make an inquiry, please visit our Data Request Form or you can contact us using any of the methods listed in the Contact Us section.

      We may verify your identity before processing requests. Verification information is used only for verification, security, or fraud-prevention and deleted after processing.

   2. Fund&Grow’s Response to Requests

      We will confirm receipt of your request within 10 business days. In general, we will respond within 45 days of our receipt of your request. If we need more time to respond, we will let you know the reason for the additional time and may take up to another 45 days to respond.

   3. Authorized Agents

      You may designate an authorized agent to exercise your rights on your behalf. We require verification of the agent's authority and may require attestation under penalty of perjury. Without power of attorney, we also require you to verify your identity.

   4. What to do if you disagree with our decision

      If we deny your request, you may appeal by contacting us (see Contact Us section) with your name, email, request type, appeal reason, and original request reference.

10. What is Fund&Grow’s Cookie Policy?

    We use tracking technologies ("Cookies") including cookies, pixels, and tracking scripts to collect, store, and track information about you and your use of the Site or Services.

    1. Cookies Explained

       Fund&Grow may use the following tracking technologies on its Site or in providing the Services:

       Cookies: Small text files stored on your device for months; deletable through browser settings. Cookies can be stored on your device for months, but you can choose to delete cookies stored on your device at any time through your browser settings.

       • Pixels/Web Beacons: Tags on web pages/emails recording activities; stop tracking when you navigate away. We may also allow some third parties to place web beacons on our Site or in our communications. Pixels are not stored on your device and will stop tracking you once you navigate away from the Site.
       • Tracking Scripts: Small piece of code, typically in JavaScript, monitoring user behavior, such as page visits, time spent on pages, clicks, and device information. Tracking scripts usually work with cookies to website users across sessions.
    
    
    2. Cookie Classifications

       Cookies are classified by their purpose (their primary function on the website) and generally fall into one or more of the following categories:

       • Essential: Required for the Site to function. You cannot disable these.
       • Targeted Advertising: Deliver targeted ads and measure effectiveness.
       • Personalization: Remember preferences (such as your username, language, or the region you are in) and provide enhanced features.
       • Analytics: Understand Site performance and visitor interactions.

       Fund&Grow uses cookies for all of the above purposes.

    3. How Fund&Grow Uses Third Party Cookies

       Fund&Grow may also use third party cookies or analytics tools for the following purposes:

       • Third Party Analytics Tools: Fund&Grow uses third party analytics tools to collect information about how consumers use our platforms. This information is collected in aggregated form only. Some third party analytics tools, such as Google, allow you to control your privacy preferences across all websites by allowing you to download an extension for your browser.
       • Third Party Ad Servers: Fund&Grow may use other third-party tracking technologies (“Ad Servers”) to either re-target relevant advertising about our products or services, or enable third parties to serve their ads and monitor users’ responses to their advertisements. Ad Servers may re-direct you to other websites not associated with Fund&Grow. The use of Ad Servers may be considered a “sale” or “sharing” under certain data protection laws. Ad Servers have their own privacy practices, we do not control these third parties’ use of cookies, or how they manage the information they gather through them. You should review the privacy policies of other websites you visit or link to from our Site to understand how these other websites use cookies and how they use the information they collect through the use of cookies on their own websites.
    4. Blocking, Disabling, or Opting Out of Cookies

       You may have choices about the collection of information by cookies we use on the Site.

       • Browser Settings: Most browsers allow you to reject cookies by default. You may also be able to delete our cookies as soon as you leave the Site. Disabling cookies may impact your ability to use all of the features and functionality of the Site.
       • Google Ad On: For Google Analytics, you may download an Opt-out Browser Add-on. Please note that the Add-on does not prevent information from being sent to Fund&Grow. To learn more about the Add-on tool for Google Analytics, click here.
       • Subscribe to Opt-Out Lists: Some advertisers and service providers that perform advertising-related services for us and for third parties may participate in the self-regulatory programs. See the below links to learn more:
         • Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices.
         • Network Advertising Initiative (“NAI”), see http://www.networkadvertising.org/choices/.
       • Request to “Opt-Out Of The Sale Or Sharing Of Personal Information”: Submit the Data Request Form. Please note: we can only accommodate opt-out requests if you have an account with us. If you do not have a Fund&Grow account, please use one of the other methods described in this section.
       • Do Not Track Signals: Some browsers allow you to turn on Do Not Track signals (DNTs), which sends a signal to the websites you visit telling those sites that you do not wish to allow third-party cookies. There is no standard technology at this time for companies to receive these signals. Our Site does not currently consistently respond to DNTs received from web browsers.
    
    
11. What is de-identified or aggregate data and how does Fund&Grow use such data?

    "De-identified data" cannot reasonably be linked to a particular person. "Aggregate data" shows high-level trends without linking to individuals.

    We may de-identify and aggregate data for business purposes (improving products, security, analytics). We maintain such data in de-identified/aggregate form and do not attempt re-identification except as legally permitted. Third parties receiving such data commit to maintaining it in de-identified form.

12. How does Fund&Grow protect your Personal Information?

    We maintain reasonable administrative, physical, and technological measures to protect Personal Information. However, no communication method is 100% secure. We cannot guarantee security of transmitted information; you transmit at your own risk.

13. How does Fund&Grow protect your financial information?

    Any financial information provided to Fund&Grow (including credit card and payment information) is stored/shared/transmitted in encrypted format complying with PCI standards using SSL (secure socket layer) encryption.

14. What other steps can you take to protect your account?

    If you purchase any products or services with us, you will need to establish an online Fund&Grow account. Your account is password protected so that you and only you have access to this personal information. You may edit your Fund&Grow account information by using your Fund&Grow user ID and password. Do not divulge your password. We will never ask for your password in unsolicited calls/emails. Sign out and close your browser after use, especially on shared/public computers.

15. What about children’s privacy?

    The Site and Services are not intended for minors under 18. We do not knowingly collect, sell, or share Personal Information of minors under 18 or send direct offers to users under 18. If you believe a child submitted Personal Information without parental consent, contact us.

16. Does Fund&Grow use or process Personal Information outside the country where the data was originally collected?

    We may send Personal Information to servers outside your country. By using the Site and Services, you consent to transfer and processing in other countries. Data protection laws may differ from your country of residence. We take steps to ensure secure treatment in accordance with our Terms and this Policy.

17. How does Fund&Grow retain Personal Information?

    Unless you request deletion, we retain Personal Information for the duration of our relationship or as long as necessary to fulfill collection purposes, whichever is longer. We consider amount, nature, sensitivity, risk of harm, processing purposes, and legal requirements when determining retention periods.

18. What do you need to know about links to third party websites?

    The Site may link to other websites operated by unaffiliated entities with their own privacy policies. We are not responsible for their content or privacy practices. Review their privacy policies when linking.

19. What else should you know about your privacy?

    Please keep in mind that whenever you voluntarily disclose Personal Information online, for example on message boards, social media, through email, or in chat areas that information can be collected and used by others. In short, if you post Personal Information online that is accessible to the public, you may receive unsolicited messages from other parties in return.

    Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you’re online.

20. How will we inform you of changes to this Policy?

    We may modify this Policy at any time. Changes supersede previous policies. Updates will be posted with a revised "Last Updated" date. Check frequently for updates. For material changes, we will notify you by email and/or account notice as required by applicable privacy laws. For changes to how we collect, use, process, or share Personal Information, we'll provide opportunity to consent or opt out as required.

21. State Specific Disclosures

    California – Shine the Light Law

    California residents have the right to request certain details about how their Personal Information is shared with third parties and, in some cases, affiliates for direct marketing purposes. We may from time to time elect to share certain Personal Information about you with third parties for those third parties’ direct marketing purposes. If you are a California resident, you may obtain the categories of Personal Information shared and the names and addresses of third parties that received Personal Information for their direct marketing purposes during the preceding calendar year. You may make this request by contacting us using the information provided in the Contact Us section. Such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. To help us determine if this right applies to you, we may ask that you attest to the fact that you are a California resident and provide a current California address. Please note that we are only required to respond to one request per customer each year.

    California and Vermont

    We automatically treat accounts with Vermont and California billing addresses as if you requested we not share information with nonaffiliated third parties and limit information shared with affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.

    Nevada

    We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing by using the contact information provided in Section 21. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.

22. Contact Us.

    If you have any questions or concerns about Fund&Grow, the Site, the Services, this Policy, the Gramm-Leach-Bliley Privacy Policy, or to exercise your rights or choices, please contact us:

    DATA REQUEST FORM

    Mail:

    Fund&Grow

    ATTN: Privacy

    8328 Balm St.,

    Spring Hill, FL 34607

    Email: service@fundandgrow.com

    Phone Number: (800) 996-0270