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Vestwell Privacy Policy

Updated: April 2026

Vestwell Holdings Inc. and our subsidiaries (referred to as "Vestwell") are committed to protecting the privacy of individuals who visit, access, or use our websites, the Vestwell platform, the Vestwell mobile app, and the Gradifi Powered by Vestwell platform (collectively, our “Sites”). This Privacy Policy explains what information we collect, why we collect it, how we use that information, and the choices we offer relating to the information we collect from or about you. Some of the information we collect from you constitutes non-public “Personal Information.” Our collection, sharing, and use of Personal Information is governed by this Policy and the privacy notice that we deliver to you pursuant to applicable state or federal law.

When you visit our Sites, enter into an agreement with us for our services, register for a Vestwell account, attend one of our events, engage with any of our social media content, or subscribe to our blog, you agree to the terms of this Privacy Policy as well as any other agreements you accept when registering for a Vestwell account. We will review and update this Privacy Policy so please review it periodically to be sure you are still comfortable with its terms. We reserve the right to use and disclose aggregated or deidentified information for any commercially reasonable purpose.

1. What Information We Collect About You

Personal Information, as used in this Policy, is information that identifies, relates to, describes, or can be reasonably linked to you. It does not include information that is lawfully made available through federal, state, or local government records or information that we have a reasonable basis to believe is lawfully made available to the general public, including through widely distributed media or by you.

We collect this information from you directly, from your current or prior employer, or a third party (such as a payroll company) acting on their behalf. We may also obtain Personal Information from third parties that we have partnered with or have engaged as service providers who help with our operations, such as data analytics providers, marketing or advertising providers, fraud prevention providers, or vendors that provide services on our behalf.

If you interact with us on social media or use certain features, such as plugins, widgets, or other tools made available by social media platforms (including but not limited to Instagram, Facebook, Twitter, Google, YouTube, and LinkedIn (collectively, “Social Media Platforms”) in connection with our services, we collect Personal Information that you or the Social Media Platforms disclose to us. Lastly, we may obtain Personal Information about you from other sources, such as proprietary search services, consumer reporting agencies, our clients or other individuals who have referred you to our services. We may also create information based on our analysis of the foregoing with other information we have collected from or about you.

The Personal Information that you provide and that we collect or receive from or about you depends on the context of your interaction with us and our Sites, the choices you make when you use our Site, and the services that you receive from us. One or more categories of information may apply to you. We have collected these categories of Personal Information for at least the last twelve (12) months.

Plan Sponsors, Participants, Beneficiaries, and Alternate Payees Who Use Vestwell’s recordkeeping And Other Services To Support Their Workplace Retirement Plans

In order to perform our contractual responsibilities, Vestwell receives information from you or someone acting on your behalf, such as your employer, a Third Party Administrator, or your employer’s payroll provider. This includes but is not limited to:

  • Full legal name
  • Contact information, such as your mailing address, telephone and/or mobile phone numbers, and email address
  • Demographic information, such as your date of birth, marital status, or gender
  • Social Security Number, Tax Identification Number, or Employer Identification Number
  • Employment-related records, such as the name of your employer, job title, compensation, and date of hire
  • Sensitive Personal Information, including drivers’ license, social security number, and precise geolocation.

If you are a beneficiary or alternate payee of a participant in a Plan supported by Vestwell, we also collect Personal Information about you or information that is not otherwise publicly available that was provided to us by the participant.

Individuals Who Visit Our Sites

Anytime you visit our Sites, we collect information about you automatically using various technologies. We utilize browser storage mechanisms, tracking technologies, and information gathering tools such as cookies, internet tags, web beacons, website analytics, and navigational data collection. Our practices are explained more in the Cookie Policy below.

Individuals Who Register For Or Attend One Of Our Events

We collect and receive information from you when you register for or attend one of our events, including your name and contact details, the marketing channel by which you learned about Vestwell, and any communication delivery preferences, including your consent to receive promotional materials from us, directly or indirectly, by phone, text message, email, or mail about our services. We use this information to provide future communications relating to the event or our services unless and until you opt out of such communications or revoke your consent. If we conduct an event with a third party sponsor or partner, that third party may also receive and use your information.

Individuals Who Interact With Our Social Media Pages

We collect and receive information from you when you interact with our Social Media Platforms. If you choose to make any of your activities or other content available through a Social Media Platform, your friends and followers on those Social Media Platforms that you have enabled, and potentially the general public, will be able to view that content and activities. The manner in which Social Media Platforms use, store, and disclose your information is governed by the policies of such third parties and we are not responsible for their privacy practices.

2. How We Use The Information We Collect From Or About You

We use the information we collect from you in a variety of ways, including:

  • To present our Site and its contents to you and to operate our Sites.
  • To deliver the information, products, or services that you or your employer requested from us.
  • To register your account and give you or your authorized users access to your accounts.
  • To reach out to you about and market or promote new information, products, or services to you that we believe you may be interested in.
  • To communicate with you, including notifying you about changes to our Sites or services.
  • To help us improve our Sites and deliver a more personalized experience. This includes enabling us to store information about your preferences, speed up your searches, and recognize you when you return to our Sites.
  • To carry out our obligations and enforce our rights arising from any contracts entered into with you. This includes for billing and collection and as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Sites, our employees, agents, or other users or to comply with applicable law.
  • To verify your identity, and detect and prevent fraud.
  • In any other way we may describe when you provide the information, or otherwise at your direction or with your consent.
  • As permitted by law or as we may notify you.

3. How We Share Information

We share the information that we collect from or about you as follows:

  • With our affiliates.
  • With our service providers, business partners, and vendors. These parties may include companies that host our Sites, provide web analytics, perform data processing, distribute emails or marketing communications to you, or help us communicate with you. These service providers include, but are not limited to, vendors we use to transact with financial institutions, and to whom you grant access to transmit your information from your financial institution in accordance with such vendor’s privacy policy.
  • With Social Media Platforms, which may provide advertisements or marketing features through their platform.
  • With third party analytics platforms, including Google Analytics and Heap, for identifying trends of our website visitors.
  • Third party providers of mutual funds and investment options in which you are invested through your Vestwell account.
  • With retirement plan sponsors, employers, payroll providers, investment advisors, third-party administrators, or other service providers associated with your retirement plan or account with us.
  • When you request any of our products or services, we share your information to the extent necessary or appropriate to fulfill your request, including sharing information with third party identity verification and fraud detection service providers.
  • When required to do so by law. For example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s or other authorized government or regulatory agencies’ request.

Vestwell may also share aggregated, anonymized, or de-identified information with third parties, such as about the demographics of users of our services. If Vestwell or any of our subsidiaries or lines of business is merged, acquired, divested, financed, disposed of, or dissolved, including through merger, consolidation, sale, or divestiture of assets, the relevant database(s), including Personal Information we may possess about you, may in whole or in part be sold, transferred, or otherwise disclosed as part of that transaction or proceeding.

4. Cookie Policy And Tracking Technologies

We and the third parties we engage use cookies, web beacons, pixel tags, browser analysis tools, session replays, server logs, and other tracking technologies (collectively, “Cookies”) to automatically collect information, including Personal Information, about you. We use Cookies for a variety of purposes, including functional, analytics, and advertising purposes.

What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help websites function, improve user experience, and provide information to the website operator. We use cookies and similar technologies such as web beacons, pixels, tags, digital fingerprinting, scripts, session replays, and software development kits (collectively, “Cookies”).

Types Of Cookies We Use

We use the following categories of Cookies:

  • Strictly Necessary: These Cookies are essential for the operation of our services. They enable core functionality such as security, authentication, and accessibility. These Cookies cannot be disabled.
  • Performance and Analytics: These Cookies collect information about how visitors to our Sites use our services and Sites, such as analyzing pages viewed and time spent. We use this information to improve our functionality and performance. These Cookies cannot be disabled.
  • Advertising: These Cookies track browsing activity across our Sites to deliver relevant advertising and measure promotional campaign effectiveness. They may be set by us or third parties. You may manage or disable them, as explained below.

First And Third Party Cookies

First party Cookies are set by Vestwell Holdings Inc. Third party Cookies are set by service providers or partners, such as analytics providers, social media platforms, or advertising networks. We use third party Cookies set by Google Analytics, Google Ads, Google Tag Manager, Meta, Heap, Reddit, 6Sense, PartnerStack, and Hubspot (collectively, “Third Party Tracking Technologies”). Cookies expire either when you close your browser (“Session Cookies”) or remain on your device for a defined period until deleted (“Persistent Cookies”).

Our Sites reference or provide links to third party websites, including social media bookmarking buttons that enable or require you to share certain content on or communicate with our Sites. Some of these sites may be co-branded with a Vestwell logo even though they are not operated or maintained by Vestwell. You may be directed through links to those sites while visiting our Sites. This Policy only describes Vestwell’s privacy practices. Vestwell is not responsible for any activities of third party websites. We do not control, nor are we responsible for, the privacy policies, operation, data collection, information practices, or use of third parties or their websites. When you use third-party links, these third parties may collect Personal Information about you or your online activities.

Data Collected Through Cookies

We collect the following information:

  • Device data- IP address, browser type, operating system, type of device, carrier name, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID), or unique device identifier (a number uniquely given to your device by your device manufacturer).
  • Usage data - date and time you visited our Sites, pages viewed, interactions, time spent using the Sites. Clicks and page transitions are tracked through Google Tag Manager and Heap to measure engagement and improve navigation.
  • Approximate location data, such as your zip code, the approximate geographic area provided by your Internet service provider, or location positioning information provided by the location services and GPS features of your device.
  • Referral URLs - the website URL that directed you to the Sites.

How To Manage Cookies

You can control Cookies in several ways. You can adjust your browser settings to block or delete them or opt out of certain third-party tracking through industry tools. You can also manage or opt out of Cookies at any time by adjusting your preferences in the Cookie settings banner or preference center displayed when visiting our Sites. If you disable certain Cookies, it may affect the functionality of our platform or services. Most web browsers will tell you how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org.

Google Analytics

With respect to Google Ads, Google Analytics, and Google Tags, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout to opt-out of being tracked by Google Analytics. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at

http://www.google.com/policies/privacy/partners.

Meta Platforms

We also utilize Facebook pixels to gather information about visitors to the Sites. Meta’s Privacy Policy explains how to change your device settings to opt out of Facebook tracking technologies.

Google Meta, and other Social Media Platforms and Third Party Tracking Technologies use their technology to provide advertising about products and services tailored to your interests, which may appear either on our Sites or on a third party’s websites. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or online applications. To the extent these Third-Party Tracking Technologies are deemed to be a “sale” or “sharing” (which includes targeted advertising) of Personal Information, as defined under applicable data privacy laws, we will provide you with preferences to exercise control over such Third-Party Tracking Technologies along with options to opt-out.

Opting Out Of Marketing Communications

Except where “opt-in” consent is required by law, our marketing communications include an “opt-out” or unsubscribe option that describes your right to opt out of future marketing communications from us and how to do so. The consent you provide to us to send you promotional communications about our services will be shared with third parties, including aggregators and providers of text messaging services. If you would like us to remove your name and information from marketing communications, please email us at Legal@vestwell.com. It may take up to 30 days to complete your request. You may change your mind and opt back into the processing of your Personal Information at any time by contacting us at legal@vestwell.com or contact us at (917) 979-5358.

5. How Does Vestwell Protect Your Personal Information

Your privacy matters to Vestwell and we work hard to protect it. We protect your Personal Information by physical, electronic, and procedural safeguards. However, as with all online service providers, the security of your information depends in part on the security of your computer, device, internet service provider, and your activities, all of which are beyond Vestwell’s control. Your use of our Sites and services is also governed by our Platform Terms of Use, which are incorporated herein by reference. Vestwell does not send unsolicited communications asking for account information, such as your password.

6. How Long Does Vestwell Keep Your Personal Information

Vestwell retains Personal Information for as long as necessary to provide our services, carry out the purposes described in this Privacy Policy, or as required to comply with applicable law.

7. Additional Information for Residents Of Other States

California

Our California Privacy Notice and Notice of Collection is available at: https://files.vestwell.com/download/a5d12f82d69c11eebc2d66cdb1f414f2 and supplements this Privacy Policy. Additionally, for a description of the treatment of Personal Information we have from California residents (1) in their capacity as current or former employees, personnel, or independent contractors of Vestwell; (2) who are emergency contacts of, or benefits recipients related to, current or former employees, personnel, or independent contractors of Vestwell; or (3) in their capacity as current or former job applicants or prospective job applicants to Vestwell, please read our California Resident Applicant and Prospective Applicant Privacy Notice. California residents who interact with us in their capacity as representatives of individuals enrolled in an Achieving a Better Life Experience (“ABLE”) program or other Vestwell or state-sponsored savings products, please see our Privacy Notice for California Resident Authorized Legal Representatives for more information.

Colorado

If you live in Colorado you may have the following rights for data that is not collected pursuant to the Gramm Leach Bliley Act or the Fair Credit Reporting Act.

(1) The right to confirm whether Vestwell is processing your Personal Information, and accessing your Personal Information;
(2) The right to request we correct inaccuracies in your Personal Information;
(3) The right to request we delete your Personal Information;
(4) The right to request a copy of the Personal Information you provided to us; and
(5) The right to opt out of (i) processing of your Personal Information for targeted advertising purposes; (ii) the sale of your Personal Information; and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise rights (1) through (5)(i), please contact us at Legal@vestwell.com or call (917) 979-5358. For right 5 (ii-iii), please note that Vestwell does not use Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects nor does it sell your Personal Information. Therefore, the consumer rights that apply to such decisions are not applicable to Vestwell’s activities.

If you are a resident of Colorado, we will inform you, in writing, of any action taken or not taken in response to your appeal within forty-five (45) days of receipt of your appeal. If we require more time (up to another sixty (60) days), we will inform you of the reason and extension period in writing. If we deny your appeal, you can file a complaint with the Office of the Attorney General of Colorado at: Ralph L. Carr Judicial Building, 1300 Broadway, 10th Floor, Denver, CO 80203, by phone at (720) 508-6000, or online at https://coag.gov/file-complaint/

Connecticut

If you are a resident of Connecticut, you can file a complaint with the Office of the Attorney General of Connecticut at 165 Capitol Avenue, Hartford, CT 06106, Phone number: (860) 808-5420, Online: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page More information about your rights as a Connecticut consumer may be found on Connecticut’s Attorney General website.

Delaware

If you are a resident of Delaware, you can file a complaint with the Delaware Department of Justice, Consumer Mediation Division at 820 N. French Street, 5th Floor, Wilmington, DE 19801 Phone number: (302) 577-8600 or (800) 220-5424

Online: https://attorneygeneral.delaware.gov/fraud/cmu/complaint/ More information about your rights as a Delaware consumer may be found on the Delaware’s Department of Justice, Fraud & Consumer Protection Division website.

Iowa

If you are a resident of Iowa, you can file a complaint with the Office of the Attorney General of Iowa, Consumer Protection Division at: Hoover State Office Building, 1305 E. Walnut Street, Des Moines, Iowa 50319-0106 Phone number: (515) 281-5926 or (888) 777-4590 Online: https://www.iowaattorneygeneral.gov/for-consumers/file-a-consumer-complaint/complaint-form More information about your rights as an Iowa consumer may be found on the Iowa’s Department of Justice, Attorney General website.

Montana

If you are a resident of Montana, you can file a complaint with the Montana Department of Justice’s Office of the Attorney General at: P.O. Box 201401, Helena, MT 59620-1401 Phone number: (406) 444-2026 Online: https://app.doj.mt.gov/OCPPortal/?q=node/395/ More information about your rights as a Montana consumer may be found on Montana’s Department of Justice website.

Nebraska

If you are a resident of Nebraska, you can file a complaint with the Nebraska Attorney General at: 2115 State Capitol, Lincoln, NE 68509 Phone number: (402) 471-2682 Online: https://www.nebraska.gov/apps-ago-complaints/?preSelect=CP_COMPLAINT More information about your rights as a Nebraska consumer may be found on Nebraska’s Attorney General website.

New Hampshire

If you are a resident of New Hampshire, you can file a complaint with the New Hampshire Department of Justice, Consumer Protection & Antitrust Bureau at 1 Granite Place South, Concord, NH 03301 Phone number: (603) 271-3658

Online: https://www.doj.nh.gov/citizens/consumer-protection-antitrust-bureau/consumer-complaints More information about your rights as a New Hampshire consumer may be found on the New Hampshire’s Department of Justice website

New Jersey

If you are a resident of New Jersey, you can file a complaint with the New Jersey Office of the Attorney General, Division of Consumer Affairs] at 124 Halsey Street, Newark, New Jersey 07101 Phone number: (973) 504-6200 Online: https://njconsumeraffairs.nj.gov/file-a-complaint/ More information about your rights as a New Jersey consumer may be found on New Jersey’s Office of Consumer Protection website.

Oregon

If you are a resident of Oregon, you can file a complaint with the Oregon Department of Justice at: 1162 Court St. NE, Salem, OR 97301-4096 Phone number: (877) 877-9392 Online: https://app.smartsheetgov.com/b/form/02fff1dd26bd4dc19a7297e83012eb4e

More information about your rights as an Oregon consumer may be found on the Oregon’s Department of Justice’s website.

You may also have the following rights for data that is not collected pursuant to the Gramm Leach Bliley Act or the Fair Credit Reporting Act.

  1. The right to confirm whether Vestwell is processing your Personal Information, and the categories of personal data that is or has been processed;1
  2. The right to request we correct inaccuracies in your Personal Information;
  3. The right to request we delete your Personal Information;
  4. The right to request a copy of the Personal Information you provided to us; and
  5. The right to opt out of (i) processing of your Personal Information for targeted advertising purposes; (ii) the sale of your Personal Information; and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise rights (1) through (5)(i), please contact us at Legal@vestwell.com or call (917) 979-5358. For right 5 (ii-iii), please note that Vestwell does not use Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects nor does it sell your Personal information. Therefore, the consumer rights that apply to such decisions are not applicable to Vestwell’s activities.

Tennessee

If you are a resident of Tennessee, you can file a complaint with the Office of the Attorney General of Tennessee at P.O. Box 20207, Nashville, TN 37202 Phone number: (615) 741-4737 Online: https://agtnprod.powerappsportals.us/DCA/ More information about your rights as an Tennessee consumer may be found on Tennessee’s Attorney General & Reporter website.

Texas

If you are a resident of the Texas, you can file a complaint with the Office of the Attorney General, Consumer Protection Division of Texas at PO Box 12548, Austin, TX 78711-2548 Phone number: (800) 621-0508

Online: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint More information about your rights as a Texas consumer may be found on Texas’ Attorney General website.

Utah

If you are a resident of Utah, you can file a complaint with the Division of Consumer Protection of the State of Utah Department of Commerce at PO Box 146704, Salt Lake City, UT 84114 Toll Free: (800) 721-7233 Phone number: (801) 530-6601 Fax number: (801) 530-6001 Online: https://dcp.utah.gov/wp-content/uploads/2023/12/Data-Privacy-Complaint-Form-Final-12.28.2023.pdf More information about your rights as a Utah consumer may be found on Utah’s Consumer Protection Division website.

Virginia

If you are a resident of the Commonwealth of Virginia, you can file a complaint with the Consumer Protection Section of the Office of the Attorney General of Virginia at: 202 North Ninth Street, Richmond, VA 23211 Toll Free: (800) 552-9963 Phone number: (804) 786-2042 Fax number: (804) 225-4378

Online: https://www.oag.state.va.us/consumercomplaintform/form/start More information about your rights as a Virginia consumer may be found on Virginia’s Attorney General website.

8. How To Contact Vestwell

Privacy matters to us. If you have reason to believe that we have not adhered to this Privacy Policy, or any other questions or complaints relating to our privacy practices, please contact Vestwell by email at help@vestwell.com or by mail at Vestwell Holdings Inc., Legal Department, 360 Madison Avenue, 15th Floor, New York, New York 10017 (917) 979-5358. All complaints are recorded, reviewed, and handled by the Vestwell Legal Department, which can also be reached at Legal@vestwell.com

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded. If we determine that the request warrants a fee, we will tell you why and provide you with an estimate. The “Right to Appeal” below describes how you can appeal our refusal to take action on a request to exercise your rights.

If we refuse to take action on your request to exercise your rights, you may appeal our refusal. To appeal a refusal, please submit a copy of your request for an appeal and the original request to us as indicated in this Policy. Unless otherwise indicated in this policy, within sixty (60) days of our receipt of your request for an appeal, we will inform you, in writing, of any action taken or not taken in response to your appeal. We will include a written explanation of the reasons for the decisions. If we deny your appeal, you may contact your local privacy enforcement authority to submit a complaint based on the below information.

9. Children

Vestwell’s services and our Sites are not targeted or directed at children under the age of 13, and we do not intend to or knowingly collect or solicit Personal Information from children under the age of 13. Vestwell does process Personal Information about children from adult account holders, if necessary to perform our services. For example, if you have a savings account supported by Vestwell, we may collect information relating to the beneficiaries of that account, which may include children under age 13. Personal information about individuals under age 13 will be treated the same as Personal Information described in this Policy. The information of children under 13, however, will not be used for the marketing or promotion of new information, products, or services whatsoever.

10. International Use Statement

Vestwell and our services and Sites are based in the United States and our services and Sites are provided and targeted only to residents of the United States. Personal information provided to us may be transferred to or controlled and processed in the United States, but in certain circumstances, service providers or business partners may process data in or outside of the United States. By providing Vestwell with Personal Information or by using the Sites, our services, or the Vestwell Platform, you consent to this transfer and acknowledge that Personal Information stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts, law enforcement, and/or regulatory agencies of the United States that have valid jurisdiction over Vestwell to obtain disclosure of your Personal Information. You also understand and agree that your Personal Information may be transferred to and processed in the United States and other countries that may not provide the same level of data protection and privacy as the United States or the country of your residence, and may have been deemed to have inadequate data protection and privacy laws. If you access the Sites from a location outside of the United States, you agree that your use of our Sites is subject to the terms of this Privacy Policy.