Privacy Policy

Purpose

Financial companies choose how they share your personal information. Federal law gives consumers (our clients and prospective clients) the right to limit some but not all sharing. Federal law requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

The firm collects personal information about consumers from the following sources:

• Information provided to us to assist with their investment recommendation.
• Information provided through engagement agreements and other documents completed in connection with the opening and maintenance of an investment account.
• Information received from service providers, such as custodians, about investment account transactions.

Financial companies often need to share consumers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their consumers' personal information, the reasons Pebble Finance chooses to share, and whether you can limit this sharing.

Reasons we can share your personal information	Does Pebble Finance share?	Can you limit this sharing?
For everyday business purposes — to process transactions, maintain your account(s), respond to court orders or a legal investigation	YES	NO
For internal marketing purposes — to offer you our services	YES	NO
For joint marketing with other financial companies	NO	YES
For our affiliates' everyday business purposes — information about your transactions and experiences	NO	YES
For our affiliates to market to you	NO	YES
For non-affiliates to market to you	NO	We don't share.

How does Pebble Finance protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with state or federal law, as appropriate. These measures include computer safeguards and secured files and buildings. We also maintain procedural safeguards to protect your personal information.

How does Pebble Finance collect my personal information?

• We collect your personal information when you engage our advisory firm.
• When you open, make a deposit or withdrawal from your investment account managed by our firm.
• When you use a credit card to pay our firm.

We do not collect your personal information from others such as credit bureaus, affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only sharing for affiliates' everyday business purposes, affiliates from using your information to market to you, and sharing for non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing.

Definitions

Affiliates — Companies related by common ownership or control of our firm. They can be financial and non-financial companies. Pebble Finance has an affiliated parent company.

Non-Affiliates — Companies not related by common ownership or control. They can be financial and non-financial companies. Pebble Finance does not share with non-affiliates so that they can market to you.

Joint Marketing — A formal agreement between non-affiliated financial companies that together market financial products or services to you. We do not engage in joint marketing arrangements.

We reserve the right to change our privacy policy from time to time. Should there be any changes to the policy, we will provide you with the most up-to-date version.

Information collected

Information about your use of the Services is collected as follows:

Registration

In order to use Pebble Finance Services, you may be required to register an account and provide certain personal information such as your name, email address, zip/postal code, profession, occupation, specialty and depending on your country of residence. You may choose to update or supplement the personal information that you provided at registration at any time through your account settings.

Services information

We automatically collect and store information about your use of the Services including on our Demo Site, such as your engagement with particular content including our Pebble News, Fund and Portfolio Explains as well as other products and services. Additionally, we also collect whether you opened a particular email, clicked on a link, ran a query or your search queries and how often and when you engage with the Services. We also collect information about your device when you access the Services including IP address, precise location information, browser information (including referring URL), cookie information and advertising ID. We use cookies and other tracking technologies, such as pixels, tags, web beacons and software development kits, to collect the information about your use of the Pebble Finance and our Services and your device.

Cross-device tracking

We and our service providers collect and store information about users' interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices. We do so in order to:

• Provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.
• Detect and prevent fraud.
• Allow users to use our service on one device and pick up seamlessly where they left off on another device.
• Limit the number of times a user is shown the same advertisement, across known or inferred devices.

Market research

You may be invited to participate in market research surveys conducted by us or on our behalf for our own internal business purposes and also market research surveys conducted by or on behalf of third party sponsors that commissioned the survey.

Information from third party sources

We may obtain additional information about you from third party sources to assist us in providing the Services. For example, we may use third party information to verify and augment your registration information, for research purposes or to personalize the Services, including advertising.

Non-registered users

You must register with Pebble Finance to gain full access to Services, however, you may be able to access certain limited Services without registering. Even if you have not registered, we collect information about your use of the Services through the use of cookies and other tracking technologies. The information we collect includes the referring website, if applicable, the type of browser you use, the material viewed, and the time and date that you accessed the Services.

How your information may be used

Information about you may be used for the following purposes:

Provision of the Services

We may use the information collected about you to provide and improve the Services, and to develop new Services.

Member profiles

We may associate information that we have collected about your use of the Services with your registration information and any other information we have about you, thereby creating a profile of you that we may update from time to time ("Member Profile"). This processing of your Member Profile is necessary to deliver the Services tailored according to your specialty and interests.

Network profiles

We may use your registration information, as well as information from third-party sources, to create a profile for you that is viewable by other members of Pebble Finance, which may be associated with content with which you engage and comments you may post (collectively, your "Network Profile").

Communications

By registering as a member of the Pebble Finance, you agree to the use of your registration information and other information collected about you as described in this Privacy Policy to communicate with you about the Services and other information that may be of interest to you. These communications may be conveyed through a variety of channels, subject to applicable law, including emails and may contain advertisements and other promotional materials from third party sponsors.

User data

Your user data, including your questions/prompts, may be sold to third parties or otherwise monetized as a commercial data feed.

Personalization including advertising

We may personalize the Services, including the advertising you see within the Pebble Finance product suite or Pebble Finance demo site, on third party websites and in our email communications, based on information included in your Member Profile. We partner with third parties to manage and conduct our advertising activities. These third parties may use cookies and other tracking technologies to deliver advertising based on your activities and interests.

Personalization is necessary for the performance of the contract between you and us according to which we deliver the Services. We analyze or deduce your preferences and interests based on a number of factors including your profile, your interactions with our Services, your viewing and search history, the time and location of your access, the device you use, survey responses, content you post or share, and your interactions with other websites.

Verification purposes

We may use your information in conjunction with information from third parties to recognize you as a registered member when you visit one of our properties and to verify your identity and/or professional credentials.

Account management

We may use your information to administer your account, respond to your inquiries, fulfill your requests and send you administrative communications about the Services.

Investigations

We may use your information to detect, investigate and defend against fraudulent or unlawful activity, violations of the Pebble Finance Terms of Use and to otherwise establish, exercise and defend our legal rights.

Legal grounds

Pebble Finance Inc. relies on proprietary data. Being a free service, the Pebble Finance Demo Site and related Services may rely on advertising and partnership revenues to support the development of specialized content designed for practicing financial professionals and investors. The use of personal data is necessary to perform the contract entered into between Pebble Finance Inc. and you, to respond to legitimate interests based on the maintenance and improvement of its Services, and to comply with any legal constraints applicable to Pebble Finance Inc.

Sharing your information with third parties

Information about your use of the Services may be shared as follows:

Service providers

We work with third party service providers to help us provide the Services and to otherwise assist us in the operation of the Pebble Finance Services, including in the areas of email management and deployment, analytics, marketing, advertising, market research, identity and professional credential validation, content distribution, customer service, payment fulfillment, website maintenance and data storage and security. We may provide these service providers with personal information about users of our Services so that they can fulfill their responsibilities to us.

Member profiles

Subject to applicable law, Pebble Finance Inc. may provide Member Profiles, and portions thereof, to third parties, including our advertising customers, which these third parties may use for their business purposes including marketing.

Network profiles

Your Network Profile may be viewable by other members of the Pebble Finance Inc. team for personalization purposes and to allow you to view and connect with other members of the Pebble Finance Services.

Market research

If you receive remuneration for participating in a market research program offered through our Services, we may provide your personal information to our payment fulfillment vendor and to the program sponsor for their recordkeeping and regulatory compliance purposes. We do not disclose your survey responses to the sponsor in a manner that identifies you.

Consent

We may disclose your personal information to a third party in a manner not addressed by this Privacy Policy subject to your consent at such time.

Aggregated information

We may provide aggregated information about users of our Services to third parties as we deem appropriate in our sole discretion, in a manner that does not identify individual users.

Social widgets

We may include social widgets within our websites and apps which enable you to interact with the associated social media services. These widgets may collect browsing data which may be received by the third party that provided the widget, and are controlled by these third parties.

Affiliates

We may share your information with any member of our group of companies for their use for the purposes set forth in this Privacy Policy, including to market to you through a variety of channels as described herein, subject to applicable law.

Business transfers

In connection with a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, we reserve the right to transfer your personal information to the new party in control or the party acquiring assets.

Legal requirements

We may release personal information when we believe release is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order and to meet national security or law enforcement requirements; or is reasonable in response to a physical threat to you or others, to protect property or defend or assert legal rights.

Security of information

We have implemented appropriate technical and organizational security measures to protect the personal information that we have under our control from unauthorized access, use, disclosure and accidental loss. When you enter personal information, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology. You are solely responsible for maintaining the security and confidentiality of your account username and password. Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

Pebble Finance shall retain a user's personal data up to one year after the user's account deactivation subject to any relevant provisions of applicable law. Thereafter, the data will be archived (notably to comply with any applicable statute of limitations) or fully anonymized.

Choice and control

Account information

You may update your registration information at any time through the Account Management feature available on each of our properties. You may also contact Customer Support at contact@pebble.finance and request that your registration information be updated or deleted. Note that if we delete your account, we may maintain certain de-identified information about you for internal business purposes including research, analytics and reporting.

Cookies

Most browser software can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use our Services will be limited.

Interest-based ads

You can opt-out of interest-based advertising on our websites by rejecting cookies as described above. Please note that even if you reject cookies and opt-out of interest-based advertising, you may continue to receive generic advertisements through the Services. Note that our websites do not respond to web browser "do not track" signals. If you are in the EU or any country with stricter privacy laws than the US, please do not use Pebble Finance or any of its related services and sites as it is not governed or protected by EU safeguards.

Mobile opt-out

You may control interest-based advertising on your mobile device by enabling the "Limit Ad Tracking" setting in your iOS device's settings or "Opt out of Ads Personalization" in your Android device's settings. This will not prevent you from seeing advertisements, but will limit the use of device advertising identifiers to personalize ads based on your interests.

Precise location information

You may disable the transmission of precise location information through your device settings. To change location settings on your device, please refer to your device's official knowledge base.

Email communications

If you no longer wish to receive a particular type of email communication from us, you may unsubscribe by clicking the "unsubscribe" link located at the bottom of the email and following the instructions. Note that certain email communications that we send to members are service-related and as long as you are a member of the Pebble Finance Demo Site, you may not unsubscribe from such emails.

California residents

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

In so far as granted by applicable law (in particular in the European Union), you may ask for access to your personal data or ask us to rectify, erase, restrict or port your personal data and object to the use of your personal data. To exercise these rights, please contact Customer Support at contact@pebble.finance.

We make no automated decisions about you that create legal effects or otherwise significantly affect you.

Note to users outside of the United States

Pebble Finance and our employees are located in the United States, as is a majority of Pebble Finance's clients, as well as the platform's technical infrastructure including its data hosting facilities. In order to provide the Services to you, we will likely transfer your personal information outside of your country of residence including to the United States where it will be stored and processed in accordance with this Privacy Policy.

This means that if you are located in the EU, your personal data is transferred to the US which is not considered to have the same level of data protection as in the EU. Therefore if you are in the EU or any country with stricter privacy laws than the US, please do not use Pebble Finance or any of its related services and sites as it is not governed or protected by EU safeguards.

Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

Children's privacy

Pebble Finance and its Services are designed and intended for use by adults, and are not intended for nor designed to be used by children under the age of 18. We do not collect personal information from any person we know is under the age of 18.

Privacy policy changes

We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address included in your account profile) and/or by means of a notice on our websites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.

Contacting us

If you have general questions about your account or the Services, contact Customer Support at contact@pebble.finance. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at contact@pebble.finance.

Pebble Finance users from the EEA may contact our Data Protection Officer at contact@pebble.finance.

Please note that if you contact us to assist you, we may need to verify your identity before fulfilling your request.