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Privacy Policy

At Vestwell, we consider privacy a fundamental aspect of our relationship with our current, former, and prospective clients, and other individuals whose personal information we collect and process to perform our services. One or more of our privacy policies may apply to you depending on your relationship with us. From time to time, we may update or revise these policies. If there are changes to the terms of these policies, documents containing the revised policy or policies on the relevant website(s) mentioned below will be updated.

Plan Sponsors, Participants, Beneficiaries, and Alternate Payees who use Vestwell’s recordkeeping and other services to support their defined contribution workplace retirement plans

Information about how Vestwell collects, uses, and shares personal information of current, former, and prospective clients and end users of services supporting workplace retirement plans is discussed in the Vestwell Privacy Policy. Individuals who create a Vestwell account on our platform are also required to agree to our Vestwell Platform Terms of Use, which is provided during the account registration process.

Employers and individuals enrolled in state-sponsored retirement, college savings, or Achieving a Better Life Experience (“ABLE”) programs

Information about how Vestwell collects, uses, and shares personal information of individuals who are enrolled in a state-sponsored retirement program (such as Secure Choice programs), tax-advantaged college savings plan, or ABLE program is discussed in the Vestwell Privacy Policy. If you are enrolled in one of these savings programs, the program board or state that sponsors the program may have different privacy policies or regulations that apply to you instead of the Vestwell Privacy Policy.

Individuals enrolled in an Individual Retirement Account (“IRA”) offered by Vestwell Advisors, LLC, and individuals enrolled in an Emergency Savings Account (“ESA”) offered by Vestwell Trust Company, LLC

Federal law known as the Gramm Leach Bliley Act (“GLBA”) gives consumers the right to limit some, but not all, sharing of their personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read our GLBA Notice carefully to understand how we collect, use, and share your personal information. This is the privacy notice that applies to your IRA and ESA accounts and services with Vestwell.

For individuals who open an ESA with Vestwell, we will be sharing your personal information with the Bank of New York Mellon (the “Bank’) for account opening and verification purposes. The Bank’s privacy policies are located here. Unless prohibited by applicable Law, the Bank or its affiliates may contact you to provide information on products and services that they believe will be of interest to you. If you wish to formally confirm your desire to opt-in or opt-out of receiving such communications or confirm or correct information, you can do so by contacting the Bank at Global_Privacy_Compliance@bnymellon.com.

Employers and employees who use the Gradifi powered by Vestwell platform

Information about how we collect, use, and share personal information of current, former, and prospective clients and eligible employees who use the Gradifi platform is discussed in the Vestwell Privacy Policy located on www.gradifi.com. By using our Gradifi solutions services, including the College Save-Up, Student Loan Paydown, and Refinance Services, individuals and employers must also comply with and are considered to have agreed to the terms of our Gradifi Platform Terms of Use.

If you are a resident of California and use or receive any of our services; represent an individual who uses or receives our services; or are employed by or apply for a position at Vestwell

The California Consumer Privacy Act (“CCPA”) provides California residents privacy rights with respect to certain personal information. If you are a California resident, please review our California Notice at Collection and Privacy Notice for more information. Information about how we collect, use, and share the personal information of California resident employees or applicants for a position at Vestwell is available in our California Resident Employee, Applicant, or Prospective Applicant Privacy Notice and the California privacy notice from our recruiting provider Greenhouse.

Information about how we collect, use, and share the personal information we collect from California residents who act in their capacity as representatives of individuals who are enrolled in a state-sponsored ABLE program or who otherwise serve in a representative capacity on behalf of a participant in any of our savings programs is available in our Privacy Notice for California Resident Representatives of Savings Program Participants.