Privacy Policy of Measured Financial, Inc.

Revised April 1, 2023

Measured respects your privacy. This Privacy Policy ("Policy") is meant to help you understand the types of Personal Information that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices and your privacy rights. Please read this Policy carefully, as it applies when you use our Services or products, visit our website, or use the Measured mobile app.

Measured partners with a number of service partners and third-party service providers (collectively “Service Providers”) to provide you and your business with the best integrated securities-backed loan and financial advice platform. Some of these Service Providers have their own privacy statements or policies; this Policy does not apply when you are linked to a service providing a different privacy policy or when the website, product, or service involved is operated by a company other than Measured.

If you have any questions about this policy or privacy at Measured, please reach out to us at privacy@Measured.com or via any of the other methods identified in the “How to Contact Us” section below.

I. Who We Are

A. Measured. This Policy applies to Measured Inc. and its affiliates, including, without limitation, Measured Advisers, LLC and Measured Securities, LLC (collectively, “Measured”, “we”, “our”, and “us”).

B. Personal Information. “Personal Information” is any information that identifies, relates to, or reasonably could be linked to or associated with a particular person.

C. Services. “Services” means the financial products, securities-backed lending, investment advisory, cash management, integrations with Third-Party Services, and all other services provided by Measured, including those available through your Measured account.

II. What Personal Information We Collect About You and Where It Comes From

A. Information Measured Collects from You

We collect and process Personal Information through our Services when you interact with Measured. The data we collect from you varies depending on what specific Services you use. In some cases you actively provide us with the information and in others, Measured collects the information automatically. Measured collects personal information from you when you directly interact with Measured in the following ways:

Filling out an application and creating a Measured account
Connecting your third party banking or brokerage account to Measured’s platform
Making a securities transaction in your Measured account
Making or receiving payments (such as receiving loan proceeds or paying back a loan)
Signing in to access your Measured Account
Browsing the platform or our website
Using our iOS or Android mobile apps
Using integrations to connect your Measured Account to third party services
Calling, chatting, contacting, or interacting with Measured
Reading emails from Measured
Engaging in our affiliate referral program
Entering a Measured sweepstakes, contest, or promotion

Measured may collect the following categories of Personal Information from you when you interact with or use our Services.

Contact Data, such as your name, email, phone number, and address.
Professional Data, including your title or role on your team.
Account Credentials, including your password (hashed) and information for authentication and account access.
Identity Data, such as your date of birth, your Social Security Number (SSN) and copies of your passport, driver’s license, or other national ID and any information captured on such ID (such as facial images/ photographs) or through our ID verification process (including the ID verification results).
Financial Data, including your bank account information, routing and account numbers for reimbursements, transaction history, and related information, and your Measured account data.
Transaction Data, including information associated with use of your Measured account and transactions such as wire transfers and ACH payments.
Communications and Online Content, including content within any messages you send to us (such as when contacting support or asking a question).
Referral Data, including information you provide about any potential referrals as part of our affiliate referral program, such as their name, email address, and phone number.
Service Use Data, Device Data and Location Data via Tracking Technologies. When you access or interact with our Platform or use any of our mobile apps, Measured uses several types of activity tracking tools to collect data about how and when you interact with our web pages and mobile application; the type of device, browser, and operating software you use; your IP address and other device event information; and imprecise location data that can be derived from this information (such as location that can be identified from your IP address). Unless these technologies have been disabled by a user, Measured automatically collects this data through the following types of tracking technologies:

Log Files record events that occur in connection with your use of the Services.
Cookies are small data files stored on your device that allow us to uniquely identify your browser. We use two types of cookies: session cookies and persistent cookies.

Session cookies support website navigation and expire when you close your browser
Persistent cookies allow us to identify your unique device across different sessions. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

Pixels (also known as web beacons) are code embedded in a website, email, or advertisement that sends information about your usage to a server. Pixels are used in combination with cookies to allow Measured to track a particular browser’s online activity, like what communications or pages you viewed.
Device Fingerprinting is the process of combining and analyzing data elements from your device's browser to uniquely identify your browser and device.

B. Information Measured Collects from Other Sources

Measured may also collect information about you from other sources. The paragraphs below describe the categories of third parties Measured collects Personal Information from and what categories of data we collect from them. The information categories referenced in the paragraphs below have the same description as provided in Section II.A of this Policy.

Category of Third Party: Financial Institutions (including banks and broker dealers)

Personal Information Category Collected: Contact, Financial, Transaction
When Data is Collected: These entities are Measured’s partners in holding your securities and and providing you with Measured Account services such as loans or investment advice.

Category of Third Party: Identity Verification Services; Financial Information Providers; Fraud and Financial Crime Monitoring, Prevention, and Detection Service Providers

Personal Information Category Collected: Contact, Identity, Professional, Financial, Transaction, Service Use Data, Device Data, Location Data
When Data is Collected: When Measured is confirming your identity; onboarding or maintaining information for your account; or managing fraud, financial crime, or other legal risks

Category of Third Party: Third Party Integrations and Service Providers: Banks and Brokerages

Personal Information Category Collected: Contact, Account Credentials, Identity, Financial, Transaction
When Data is Collected: When you link your Measured Account with your personal bank account. Measured does not store non-Measured financial account credentials on Measured systems

Category of Third Party: Social Networks and Online Advertising

Personal Information Category Collected: Contact, Professional, Marketing
When Data is Collected: When Measured uses these providers to serve or assist in serving our advertisements

Category of Third Party: Joint Marketing, Business Partnership, Referrals, and Rewards Partners

Personal Information Category Collected: Contact, Professional, Marketing, Referrals, Rewards, and data regarding your relationship with these partners
When Data is Collected: When Measured engages in joint marketing activities and our referral and rewards programs with these partners, as well as when we acquire information about you and your relationship to these partners

III. How Measured Processes and Stores Personal Information

A. How Measured Processes Personal Information

Measured processes Personal Information to provide its customers with a reliable, secure, and loved solution for securities-backed loans. That requires us to process Personal Information for a number of purposes, as described below:

Providing Measured Services. We use all of the categories of Personal Information we collect to provide Measured’s Services. Personal information may be used as part of the data analytics processes that enable our Services.
Improving and developing the Services. We use all of the categories of Personal Information Measured collects other than identity data to understand how you use our Services, and to improve them. We also use the information to analyze trends and performance to identify future opportunities for the development, promotion, and improvement of our Services. We use analytics services, to help us understand how users access and use our Services.
Securing the Services and Fraud Detection. We process and analyze all categories of Personal Information Measured collects for the purposes of maintaining the safety and security of our systems, websites, Services, including identifying and troubleshooting any problem with the Measured Products or Services, investigating suspicious activity, detecting potentially fraudulent or unauthorized activity, enforcing our terms and policies, and in protecting the rights of Measured, our customers, and those we all do business with.
Providing Customer Support. We process all categories of Personal Information Measured collects to troubleshoot and diagnose problems with our Services, and provide other customer care and support services, including to help us support, improve, and secure the quality of our Services, to investigate security incidents, and provide appropriate training to Measured staff.
Sending administrative communications. We may use your Contact and Transaction information to send you information related to our Product and Services such as confirmations, invoices, technical notices, service updates and security feeds, security alerts, and support, onboarding, and administrative messages.
Sending marketing communications and placing advertising, including marketing analytics. We use your Contact, Transaction, and Marketing information we collect to advertise and promote Measured Services by phone, text, email, or chat, and additional products and services from our partner companies, according to your marketing preferences.

In addition, we may work with agencies, advertisers, ad networks and other technology services to place advertisements on our behalf on other websites and services. For example, we may place ads through advertising and social media firms that you may view on their platforms as well as on other websites and services. As part of this process, we (or these third parties) may incorporate tracking technologies into our own Website and emails or other communications as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you ("Interest-based Advertising").

While you may disable some tracking technologies in your browser settings by blocking cookies in your browser, using global privacy controls, or using other privacy settings on your device or browser, you may still receive non-targeted advertisements we send as part of a general marketing campaign.

Complying with legal obligations, defending legal claims, and preventing and detecting crime and misuse of Measured Services. We may process all categories of Personal Information Measured collects to fulfill Measured’s legal and regulatory rights and obligations, including in the following situations:

when cooperating with public and government authorities, courts or regulators in accordance with applicable laws;
to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
to protect Measured’s legal rights, pursue remedies available to us, and limit our damages;
to protect against misuse or abuse of our Services;
to protect personal or public property or safety;
to comply with judicial proceedings, court orders or legal processes; or
to respond to lawful requests.

When complying with court orders and other similar legal processes, Measured strives for transparency. We will make reasonable efforts to notify our customers and users of any disclosure of their Personal Information, unless we are prohibited by law or court order, or exigent circumstances prevent us from doing so.

For our business purposes. We may use information for other legitimate business purposes, such as developing new Services; enhancing, improving or modifying our Services; mitigating financial loss, claims, liability, and other harms to our users, Measured, our partners, or third parties.
With Notice to You and Your Consent. We may otherwise process Personal Information after providing notice to you and obtaining your consent. You may opt out of or refuse your consent for this processing; please see the “Your Rights and Choices” section below for how to do so.

B. Anonymized and aggregated data. To improve and market our Services, better target advertisements, and for other promotional purposes, Measured may transform Personal Information into de-identified information removing or masking information that could be used to identify you and by aggregating or combining de-identified data with other information.

C. Transfers of your Personal Information between Measured affiliates

When you sign up for Measured, information may be shared with Measured’s affiliates Measured Advisers, LLC and Measured Securities, LLC for the provision of investment advisory and securities brokerage services.

IV. How Measured Discloses Personal Information to Other Parties

A. Measured’s Disclosures of Personal Information to Third Parties

Measured discloses Personal Information for several business purposes. Measured discloses the following data categories for the following purposes:

Business Purpose: Obtaining a loan

Data Categories Disclosed: Contact, Financial
Category of Recipient: Banking institution receiving funds

Business Purpose: Providing Measured Services and determining eligibility or interest in additional Services

Data Categories Disclosed: All categories collected
Category of Recipient: Other Measured affiliates

Business Purpose: Providing and securing Measured Services, complying with our regulatory obligations, data analytics, data hosting, and technical support

Data Categories Disclosed: All categories collected
Category of Recipient: Service Providers operating and providing services and staff augmentation on Measured’s behalf

Business Purpose: Advertising and Marketing Analytics

Data Categories Disclosed: Contact, Marketing, Service Use, Device, Location
Category of Recipient: Advertising agencies, advertisers, ad networks, technology Service Providers

Business Purpose: Managing referral partnerships

Data Categories Disclosed: Contact, Financial, Transaction
Category of Recipient: Referral partners

B. Restrictions on Service Provider’s Use of Your Personal Information

Measured may transfer your Personal Information to our Service Providers. Measured contractually prohibits our Service Providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us and fulfilling their own regulatory and legal obligations, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for other purposes except as prohibited by applicable law or contractual obligation.

C. Data transfers in corporate transactions

In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information and data we process from you may become part of the assets we transfer or share in preparation for any such transaction. Any acquirer or successor of Measured may continue to process Personal Information consistent with this Policy.

D. Compliance and compelled disclosures

We may disclose or transfer Personal Information in the following circumstances:

To comply with applicable law, regulation, broker-dealer, or custodian rules;
To enforce our contractual rights or comply with contractual obligations;
To protect the rights, privacy, safety and property of Measured, you, our customers, our business partners, or others; or
To respond to requests from auditors, courts, law enforcement agencies, regulators, and other public and government authorities, which may include authorities outside your country of residence. When complying with court orders and other similar legal processes, Measured strives for transparency. We will make reasonable efforts to notify our customers and users of any disclosure of their Personal Information, unless we are prohibited by law, court order, or exigent circumstances prevent us from doing so.

E. For California residents: No sale or sharing of Personal Information

Measured does not sell or allow our Service Providers to process your Personal Information for their own use without your consent, unless the processing of that information is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, protect our property or operations, or enforce the rights and protect the property or operations of our business partners and customers. As part of our arrangements with Service Providers, Measured may receive your Personal Information from and transfer your Personal Information to our Service Providers as part of providing our Services and Products, but these transfers are conducted under contracts that protect your data from additional uses and are not considered a sale pursuant to California law. Measured also does not share Personal Information for cross-contextual behavioral advertising as defined in the California Privacy Rights Act.

Measured has not sold or shared Personal Information for cross-context behavioral advertising for the last 12 months.

V. How Measured stores and protects Personal Information

A. How long Measured retains Personal Information and when we delete it

Measured collects and retains Personal Information to provide our Services. We retain that information for as long as we have a business or operational reason to retain that information, or where we have a legal or regulatory obligation to continue to retain that Personal Information after it has served its business or operational purpose. Measured deletes or de-identifies Personal Information when we no longer are required to or have a reasonable business purpose to retain it.

Measured’s legal retention obligations may require us to retain your Personal Information after you are no longer an authorized user of a Measured account or after your Measured account has closed. These retention obligations also prohibit us in some cases from deleting certain Personal Information after you have asked us to delete your data under the data privacy and data rights laws in different jurisdictions. Measured retains data where it is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements or where deleting it prevents us from billing for our Services, calculating taxes, conducting required audits, or carrying out other legitimate business functions.

B. Where Measured stores Personal Information

Measured may process and store Personal Information for the purposes described in this Policy in any locationin which Measured, its subsidiaries, affiliates, or Service Providers operate.

C. Measured’s data security

Measured uses organizational, technical, and administrative measures to protect Personal Information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. The specific measures we use include encrypting your Personal Information in transit and at rest, device and identity verification processes, and idle lockouts.

Where you have created a username and unique password to enable you to access your Measured Account, or use our Services, it is your responsibility to keep this password secure and confidential.

Please contact us as set out in the "How to Contact Us" section below immediately if you believe that your Personal Information or any other confidential information that you have provided to us is no longer secure or has been lost or stolen.

VI. Additional Important Information About Your Personal Information

A. Measured Account users

Measured Services are intended for use only by individuals, and you may only use a Measured Account or Card if you are an individual acting on your own behalf. You may access, update, or delete certain information within your Measured Account through the Platform.

B. Closure of a Measured Account

Closure or deletion of your Measured Account will mean that you will permanently lose access to the Personal Information and data associated with it. Personal information or de-identified information associated with your Measured Account may nonetheless remain on systems owned or maintained by Measured where required to comply with the law, our contractual obligations, or carrying out legitimate business functions.

Where Measured retains Personal Information after an account has closed, individuals may have the right to access, delete, or assert other rights under the laws of their jurisdiction.

VII. Your Rights and Choices

A. Your Choices with Measured

1. Electronic Communications

Emails. You may choose not to receive promotional emails from us by following the unsubscribe/opt-out instructions in those emails at any time. Please note that you cannot opt-out of non-promotional messages, such as those about your Measured account, transaction information about our Services (such such as updates to our platform agreement, privacy notices, security alerts, and other notices relating to your access to or use of our Services) or our ongoing business relationship.
Text, SMS, or WhatsApp Messages. If you have opted in to receiving text, SMS, or WhatsApp messages related to your use of the Products or Services, you can opt-out at any time by texting "STOP" to the short code. After you send the SMS or WhatsApp message "STOP" to us, we will send you an SMS or WhatsApp message to confirm that you have been unsubscribed. After this, you will no longer receive SMS or WhatsApp messages from us.

Please note that your opt out is limited to the email address or phone number used and will not affect subsequent subscriptions.

2. California Resident Rights and Choices

If you are a California resident, you have certain rights over the information that we have about you. You can:

Delete any Personal Information we have collected from you when we do not have legal or contractual obligations to keep the information or a need for the information to carry out a legitimate business function.
Opt out of the sale of your Personal Information and opt out of having your personal data shared for the purpose of cross-context behavioral advertising. As discussed above, Measured does not sell your Personal Information nor share it for these purposes.
Request that Measured corrects any inaccurate Personal Information Measured holds about you.
Request that Measured limit the use and disclosure of your sensitive Personal Information to uses that are necessary to provide our Services and to the uses defined in California law or regulation (defined in the California Civil Code, Section 1798.121–these uses generally are to allow).
Request that Measured provide you with any or all of the following regarding Measured’s data processing for the 12 months preceding the request:

The categories of information Measured has collected about you;
The categories of sources from which the Personal Information is collected;
The business or commercial purpose for collecting Personal Information;
The categories of third parties to whom Measured discloses Personal Information; and/or
A copy of the specific pieces of information Measured has collected about you.

Appoint an authorized agent to act on your rights on your behalf. Measured will require appropriate proof of the agent’s authority to make these requests and will need to verify your identity directly.

Measured will not discriminate against you for any use of your privacy rights.

To exercise any of these rights, you may make a request by emailing us at privacy@Measured.com. Measured will confirm receipt of your request and provide you with information about our processes for acting on your request, including when you can expect a response, within 10 business days. We will need to verify your identity to ensure the security of your Personal Information before providing you with any Personal Information.

If you are currently a Measured user, you may correct any Personal Information we have about you either in your settings, or by using the contact details above.

3. Residents of other locations

If you reside in a US state or territory other than California and would like more information about how Measured processes your Personal Information or have questions about your rights under this Policy, please submit your request to privacy@Measured.com.

B. Your Choices with Google Analytics and Interest-Based Advertising Providers

1. Google Analytics

Measured uses Google Analytics to better understand how users interact with our websites and advertising. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.

2. Interest-Based Advertising

The companies we work with to provide you with targeted ads in connection with the Services are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance ("DAA") and/or the Network Advertising Initiative ("NAI"). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants' other customers or from other technology services).

Please note that if you opt out using any of the methods described for Google Analytics, DAA,or NAI, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities' statements regarding their opt out options or programs.

VIII. Updates to This Policy

We may update this Policy from time to time in response to changing legal, regulatory, technical or business developments. When we update this Policy, we will notify you of material changes, changes that limit any of the rights you have related to the manner in which we process your Personal Information, or that we are required to disclose by law, via a prominent notice on our website, login screen, your mobile app, or via email at least 30 days prior to the changes taking effect. We will obtain your consent to any material changes to this Policy if, and where, required by applicable data protection laws.

IX. How to Contact Us

If you have concerns, questions, or would like to better understand our privacy practices at Measured, please contact us using the following details:

By email: privacy@Measured.com

By mail:

Measured Financial, Inc.

Attn: Legal

187 Lafayette St., Floor 4

New York, NY 10013 USA

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