Vestwell Privacy Policy

Updated: June 2026

Vestwell Holdings Inc., together with its subsidiaries and affiliates (collectively, “Vestwell,” “us,” “we,” or “our”), is committed to protecting the privacy of Personal Data (i.e., information that identifies or is reasonably linked to a specific individual). This Privacy Policy describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events and purchases; and other online and offline interactions.

This Privacy Policy applies to information we collect about individual consumers and general website visitors (“Individuals”) as well as information we collect about our business partners, vendors and business customers in business-to-business interactions (“Business Contacts”). 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. However, this Privacy Policy does not apply to:

• Information about our current or former personnel, applicants, and other individuals who interact with us for employment-related purposes, which are governed by separate privacy notices that we make available to such individuals.
• Information that we handle as a “processor” in limited situations when we act on behalf of and under the instructions of business customers, in which case that business customer’s privacy notice applies.

Whenever you interact with us on behalf of another individual or entity, such as if you refer a client to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.

When you visit our Digital Properties, 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 may update this Privacy Policy from time to time. Any updated Privacy Policy will be effective when posted. Please check this Privacy Policy periodically for updates.

1. Sources of Personal Data

We collect Personal Data about you from the following sources:

• Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties, interact with us in person, sign up for offers or newsletters, communicate with us, initiate transactions, or sign up for an account or other services.
• Data collected automatically and through Cookies. We may automatically collect information or inferences about you, such as through cookies, pixels, tags, scripts, server-side tools, and similar technologies (collectively, “Cookies”), when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
• From your employer, its payroll company, or third parties. We may collect Personal Data from third parties, such as service and content providers, our business partners, data brokers, social media companies, or other parties who interact with us.
• From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.

2. Types of Personal Data We Collect

We may collect the following types of Personal Data about you depending on the context of your interaction with us and our Digital Properties and the services that you receive from us. Except as otherwise specified, we may collect this Personal Data about both Individuals and Business Contacts:

1. Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
2. Records about you, such as signatures; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties, such as reviews and comments.
3. Demographic information, such as age (including birthdates) and gender.
4. Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
5. Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties. For more information about Cookies, please see Section 5.
6. Non-precise geolocation data, such as your location as derived from your IP address.
7. Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
8. Professional or employment-related information (for Business Contacts), such as job title; organization; professional licenses, credentials, or affiliations; and other professional information.
9. Education information (for Business Contacts).
10. Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services.
11. Sensitive Personal Data, including the following:
    1. Government-issued identification numbers, such as Social Security Number, driver’s license number, or passport number.
    2. Precise geolocation.
    3. Content of mail, email, and text messages where we are not the intended recipient.
    4. Biometric data processed for the purpose of uniquely identifying you.
    5. Information about your health.
    6. Citizenship, citizenship status, or immigration status.
    7. Information about criminal convictions and offences.

3. How We Use Personal Data

We use Personal Data for the following purposes:

• To provide you or your company products and services, such as making our Digital Properties and other products and services available to you and your authorized representatives or users; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request; providing customer service; processing or fulfilling transactions (including processing payments); verifying information and eligibility for certain benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
• For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and security and administration.
• For our internal research and product improvement purposes, such as verifying or maintaining the quality of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
• For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ property or rights; detecting, preventing, and responding to security incidents and health and safety issues; and protecting against malicious, deceptive, fraudulent, or illegal activity.
• In connection with a corporate transaction, such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
• For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising to you (including by identifying you across devices/sites); to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe from marketing communications via the link in marketing emails, by responding “STOP” to the text message, or by contacting us using the information in Section 9 (Contact Information) below.

We may use personal information to develop and improve algorithms, artificial intelligence or machine learning tools and models in connection with all the above processing activities. We may also use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Personal Data

We may disclose Personal Data to third parties, including the categories of recipients described below:

• Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
• Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, data and web hosting providers, software service providers, email marketing providers, payment processing companies, data analytics providers, and companies that provide business support services, financial administration, or event organization.
• Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
• Vendors necessary to complete transactions you request, such as third parties to verify your identity and detect and prevent fraud.
• Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Platform Terms of Use and other agreements or policies, and to protect our, our customers’, or third parties’ safety, property, or rights.
• Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
• Business partners that may use Personal Data for their own purposes, such as:
• Advertisers, ad platforms and networks, and social media platforms;
• Third parties whose Cookies we use as described in Section 5 below;
• Commercial data partners to whom we make information available for their own marketing purposes; and
• Partners who work with us on promotional opportunities, including co-branded products and services.

Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.

• The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
• Entities to which you have consented to the disclosure.
• 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.

Vestwell may also share aggregated, anonymized, or de-identified information with third parties, such as about the demographics of users of our services.

5. Cookies

Our Digital Properties and authorized third parties use Cookies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about:

• The types of Cookies we use and the purposes for which we use them
• The types of information we collect using these technologies
• How we disclose or make information available to others
• Choices you may have regarding these technologies

A. Types of Cookies

We and the third parties that we authorize may use:

• Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit our Digital Properties.
• Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier. In addition to the uses described below, these technologies provide information about interactions with our Digital Properties (including communications such as email we may send to you) and help us customize our marketing activities. In contrast to cookies, which are stored on a user's device hard drive, pixels, web beacons, and tags are embedded invisibly on our Digital Properties.
• Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
• Embedded scripts and SDKs, which allow us to build and integrate custom experiences on our Digital Properties. Embedded scripts are temporarily downloaded onto your device from our web server, or from a third party with which we work, and are active only while you are connected to our Digital Properties and are deleted or deactivated thereafter.
• Server-side technologies, which collect and process information about you and your interactions with our Digital Properties on our servers and transmit that data to third parties (such as through an API connection).

We may use both first-party Cookies, which are set by us, and third-party Cookies, which are set by other parties. Some of the Cookies we use may last solely for your browsing session and are deleted when you close your browser, while others are persistent and stored after you close your browser.

B. Purposes for Using Cookies

We and authorized third parties use these technologies for purposes including:

• Strictly Necessary, such as determining when you are signed in, determining when your account has been inactive, providing you with privacy disclosures and choices, and for troubleshooting and security purposes (including preventing fraud and malicious behavior);
• Functionality/Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties;
• Performance/Analytics, such as analyzing how our websites are used to understand which pages within our Digital Properties are most popular and how users move around them. For example, we use Google Analytics to help us improve the user experience. Google Analytics may use Cookies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at https://policies.google.com/technologies/partner-sites;
• Targeting/Advertising, such as conducting advertising and content personalization on our Digital Properties and those of third parties, tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”), providing you with offers and online content that may be of interest to you, and measuring the effectiveness of advertising campaigns and our communications with you—including identifying how and when you engage with one of our emails. For example, we use the Meta (Facebook) Pixel and similar technologies, which allow Meta and other third parties to collect or receive information from our Digital Properties and to use that information to provide measurement services and deliver targeted ads. To learn more about how Meta collects and uses this information, please visit Meta's "About Meta Business Tools" page or Meta's Privacy Policy at https://www.facebook.com/privacy/policy/. To learn how to opt out of interest-based advertising, see Section 5.E., below.

C. Types of Data Collected

These Cookies collect data about you and your device listed above in Section 2 (Types of Personal Data We Collect). Examples of common data elements include your IP address, location (both approximate and precise), cookie ID, device ID, Ad ID, click ID, operating system, device type, device settings and other device information, browser used, browser history, search history, pages viewed, search queries, login information, shopping cart information, information entered into webforms, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).

D. Disclosures of Data

We may disclose information to third parties or allow third parties to directly collect information using these Cookies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics (including providers of ad tracking and reporting services), security providers, and others that help us operate our business and Digital Properties.

E. Your Choices

As described in Section 10 (“Supplemental U.S. State Privacy Disclosures”) below, residents of certain states may be able to disable Cookies that constitute a “sale,” “sharing,” or “targeted advertising,” as those terms are defined under applicable laws.

In addition, you may be able to control how we use Cookies through other mechanisms. Please be aware that if you disable the use of Cookies, the functionality of our Digital Properties may be negatively impacted, and certain areas or features may not display or work correctly. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your Cookies, you may need to repeat this process for each computer, device, or browser.

• Interest-Based Advertising. Some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”). The DAA provides a mechanism for you to opt out of interest-based advertising performed by participating members at https://youradchoices.com/. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives. If you are using a mobile device, you can manage interest-based ads on your device by adjusting the settings provided by your device manufacturer or the operating system provider: Manage settings on iOS devices; and Manage settings on Android devices.
• Browser Settings. You can also refuse or delete Cookies using your browser settings. If you want to disable the use of certain specific Cookies or remove them from your device, you can disable or delete them using your browser settings. Please be aware that not all Cookies can be deleted through browser settings. Please refer to your browser’s Help instructions to learn more about how to manage Cookies, or use the following links for instructions for commonly used browsers: Apple Safari; Google Chrome; Microsoft Edge; and Mozilla Firefox.
• Do Not Track. Some web browsers may include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your preference to not have data about your online browsing activities monitored and collected over time and across websites. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As a result, we do not currently respond to DNT browser signals or similar mechanisms.
  

6. Data Security and Data Retention

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information. Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest or as required to comply with applicable law.

7. Children’s Privacy

Our Digital Properties are intended for individuals 13 years of age and older and are not directed at, marketed to, nor intended for, children under 13 years of age. Generally, we do not knowingly collect any Personal Data within the scope of this Privacy Policy from children under 13 years of age except 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. If you believe that we have inadvertently collected Personal Data from a child under the age of 13 for any other reason, please contact us at the address in Section 9 (Contact Information) below, and we will take prompt steps to delete the information.

8. External Links

Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

9. Contact Information

Privacy matters to us. If you have questions regarding this Privacy Notice, please contact us at Legal@vestwell.com or by mail at Vestwell Holdings Inc., Legal Department, 360 Madison Avenue, 15th Floor, New York, New York 10017 (917) 979-5358.

10. Supplemental U.S. Privacy Disclosures

A. Data Subject Rights

Depending on our relationship with you (i.e., whether you are an Individual or a Business Contact), and in which state you reside within the United States (such as California, Colorado, Oregon, Delaware, or Maryland), you may have certain rights regarding Personal Data that you can exercise by emailing us at Legal@vestwell.com or by calling us at (917) 979-5358:

• Right to Know. You may have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why. You may also request the specific pieces of Personal Data we have collected about you. Oregon, Minnesota, and Connecticut residents may also request a specific list of third parties to whom we disclose your Personal Data.
• Right to Delete. You may have the right to request that we delete Personal Data that we have collected about you.
• Right to Correct. You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
• Right to Opt Out of Profiling. You may have the right to opt out of certain automated processing activities that are used to evaluate characteristics about you.
• Right to Limit Use and Disclosure of Sensitive Personal Data. You may have the right to limit the use and disclosure of Sensitive Personal Data.
• Right to Opt Out of Sale, Sharing, and Targeted Advertising. You may have the right to opt out of selling, sharing, and targeted advertising (as such terms are defined under applicable laws). We do not knowingly sell data about minors under 13. You can exercise the Right to Opt Out of Sale, Sharing, and Targeted Advertising by changing your selection in the cookie preference center. To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

We will not discriminate or retaliate against you for exercising your privacy rights.

To process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request.

• For Requests to Opt-Out of Sale, Sharing, and Targeted Advertising and Requests to Limit Use and Disclosure of Sensitive Personal Data: We collect your name and email to locate you in our records.
• For Requests to Know, Delete, and Correct: We collect information necessary to verify your identity and that you are a resident of a state that provides for these rights, including name, mailing address, email address, phone number, and relationship to us.

Authorized Agents: Authorized agents may exercise rights on your behalf by submitting a request via email to Legal@vestwell.com.

• If you designate an authorized agent to submit a Request to Know, Delete, or Correct, we may reach out to you directly to verify your own identity or to confirm that you provided the authorized agent with permission to submit the request.
• If you designate an authorized agent to submit a Request to Opt Out of Sale, Sharing, and Targeted Advertising, we may seek additional information directly from the authorized agent to process the request.

Appeal: If we deny your rights request, you may have the right to appeal. To submit an appeal, contact us at Legal@vestwell.com. We will inform you in writing our response to your appeal.

Nevada residents: Individuals may contact us at Legal@vestwell.com to inquire about your right to opt out of the sale of your Personal Data.

B. Additional Data Processing Disclosures for California Residents

In addition to the disclosures above, this section provides supplemental information about how we process Personal Data. These additional disclosures apply only to individuals who reside in California as required by the California Consumer Privacy Act (“CCPA”).

Disclosure of Personal Data

Below please find a chart detailing the categories of Personal Data we collected and to whom it was sold, shared, or disclosed for a business purpose in the past 12 months.

Sensitive Personal Data: We only use and disclose Sensitive Personal Data for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.

California Shine the Light: If you are a California resident, you may opt out of sharing your Personal Data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes by emailing us at Legal@vestwell.com and following all of the instructions for opting out of disclosures that may be a “sale” or “sharing” for targeted advertising.

California Eraser Law: Any California residents under the age of eighteen (18) who have posted content or information on our Digital Properties can request removal by contacting us at Legal@vestwell.com, detailing where the content or information is posted, and attesting that you posted it. We will make reasonable, good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content that we do not control.

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.

11. 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.