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Introduction

Last Modified: April 2018

Vimvest IP, LLC, a Florida limited liability company ("Vimvest"), respects your privacy and is committed to protecting it through Vimvest’s compliance with this policy. This policy describes:

• the types of information that Vimvest may collect or that you may provide when you install, register with, access, or use the Vimvest mobile application (this "App"); and
• Vimvest’s practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information Vimvest collects in this App.

This policy DOES NOT apply to information that:

• Vimvest collects offline or on any other Vimvest apps or websites, including Vimvest’s or third-parties’ websites you may access through this App; or
• you provide to or is collected by any third party (see “Third Party Information Collection”).

Vimvest’s websites and apps and such third parties may have their own privacy policies, which Vimvest encourages you to read before providing information on or through them.

Please read this policy carefully to understand Vimvest’s policies and practices regarding your information and how Vimvest will treat it. If you do not agree with Vimvest’s policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time. Your continued use of this App after Vimvest makes changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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Children Under the Age of 13

This App is not intended for children under 13 years of age, and Vimvest does not knowingly collect Personal Information from children under 13. If Vimvest learns it has collected or received Personal Information from a child under 13 without verification of parental consent, Vimvest will delete that information. If you believe Vimvest might have any information from or about a child under 13, please contact Vimvest at privacy@vimvest.com.

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Information Vimvest Collects and How Vimvest Collects It

Vimvest collects information from and about users of this App:

• directly when provided by you; and
• automatically when this App is used.

Information You Provide to Vimvest

When you download, register with, or use this App, Vimvest may ask you to provide information:

• by which you may be personally identified, such as name, postal address, email address, telephone number, Facebook user name, or social security number ("Personal Information"); and
• that is about you but does not individually identify you, such as your employment status, net worth, liquid net worth, and citizenship status.

This information includes information that you provide by filling in forms in thisApp and information provided at the time of registering to use this App, subscribing to Vimvest’s service, and requesting further services.

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Automatic Information Collection

When you download, access, and use this App, it may use technology to automatically collect:

• Usage Details. When you access and use this App, Vimvest may automatically collect certain details of your access to and use of this App, including traffic data, logs, and other communication data and the resources that you access and use on or through this App;
• Device Information. Vimvest may collect information about your mobile device and internet connection, including the device's IP address, operating system, browser type, mobile network information, and the device's telephone number;
• Stored Information and Files. This App may also access metadata and other information associated with other files stored on your device.This may include, for example, photographs, audio and video clips, personal contacts, and address book information; and

If you do not want Vimvest to collect this information, you may opt out at anytime by contacting Vimvest at privacy@vimvest.com or by using the opt-out feature in the operating system on your phone.

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"Do Not Track" Requests

Some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized. Furthermore, Vimvest does not track its users over time and across third party mobile applications to provide targeted advertising. As such, this App does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  However, some third-party technologies used in this App may keep track of your activities when they serve you content, which enables them to tailor what they present to you.  To determine whether any of the third-party services this App uses honor DNT requests, please read their privacy policies.  For more information about these third-party services, see “Third Party Information Collection”.  For more information about “do not track,” visit www.allaboutdnt.org.

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Information Collection Technologies

The technologies Vimvest or its third-party services use for automatic information collection may include cookies (or mobile cookies).  A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of this App.

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Third-Party Information Collection

When you use this App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties include:

• Plaid Inc. (“Plaid”) – This App uses technology from Plaid to gather your data from financial institutions. By using this App, you grant Vimvest and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy, which is currently available at https://plaid.com/legal;
• Stripe, Inc. (“Stripe”) – Stripe’s PrivacyPolicy is currently available at https://stripe.com/us/privacy/;
• Apex Clearing Corporation (“Apex”) – Apex’sPrivacy Policy is currently available at https://www.apexclearing.com/wp-content/uploads/2018/02/apex-privacy-policy-2018.pdf.

These parties may also include:

• your mobile device manufacturer; or
• your mobile service provider.

These entities may collect or receive information you provide within this App, including information about your use of this App; information associated with your Personal Information; or information, including Personal Information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. These third parties may collect, use, store, or transmit information in accordance with their applicable privacy policies and business practices, which are not under Vimvest’s control. For more information on third-party practices, please refer to such third parties’ applicable privacy policies, terms of use, end user license agreements, or similar disclosures, which may be available from the Apple App Store or Google Play Store or by contacting the third party for more information. If you have questions about which third parties may have access to your information through your access to or use of this App, you may contact us at privacy@vimvest.com for more information.

Vimvest does not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Your Choices About Vimvest’s Collection, Use, and Disclosure of Your Information,” below.

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How Vimvest Uses Your Information

Vimvest uses information that it collects about you or that you provide to it, including any Personal Information, to:

• provide you with this App and its contents, and any other information, products, or services that you request from Vimvest;
• fulfill any other purpose for which you provide it;
• give you notices about your account or services, including expiration and renewal notices;
• carryout Vimvest’s obligations and enforce Vimvest’s rights arising from any contracts entered into between you and Vimvest, including this

App's End User License Agreement and for billing and collection; and

• notify you when App updates are available and of changes to any products or services Vimvest offers or provides through it.

The usage information Vimvest collects helps it to improve this App and to deliver a better and more personalized experience by enabling Vimvest to:

• estimate Vimvest’s audience size and usage patterns;
• store information about your preferences, allowing Vimvest to customize this App according to your individual interests;
• speed up your searches; and
• recognize you when you use this App.

Vimvest may also use your information to contact you about Vimvest’s and its affiliates’ goods and services that may be of interest to you. If you do not want Vimvest to use your information in this way, please check the relevant box located on the form on which Vimvest collects your data or adjust your user preferences in your account profile. For more information, see “Your Choices About Vimvest’sCollection, Use, and Disclosure of Your Information,” below.

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Disclosure of Your Information

Vimvest may disclose aggregated information about this App’s users and information that does not identify any individual or device without restriction.

In addition, Vimvest may disclose Personal Information that it collects or you provide:

• to Vimvest’s subsidiaries and affiliates;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vimvest’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Vimvest about App users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by Vimvest when you provide the information;
• with your consent;
• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce Vimvest’s rights arising from any contracts entered into between you and Vimvest, including the EULA and for billing and collection; or
• if Vimvest believes disclosure is necessary or appropriate to protect the rights, property, or safety of Vimvest, Vimvest’s customers, or others. This includes sex changing information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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Your Choices About Vimvest’s Collection, Use, and Disclosure of Your Information

Vimvest strives to provide you with choices regarding the Personal Information you provide to Vimvest. This section describes mechanisms Vimvest provides for you to control certain uses and disclosures of your information.

You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of this App may then be inaccessible or may not function properly.

Vimvest does not control third parties' collection or use of your information. However, these third parties may provide you with ways to choose not to have your information collected or used in certain ways. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI")on the NAI's website.  For more information about third-party services, see “Third Party Information Collection”.

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Accessing and Correcting Your Personal Information

You can review and change your Personal Information by logging into this App and visiting your account profile page.

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Your California Privacy Rights

California Civil Code Section1798.83 permits users of this App that are California residents to request certain information regarding Vimvest’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@vimvest.com or write Vimvest at 3322 Bee Ridge Rd Sarasota, FL 34239.

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Data Security

Vimvest has implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where Vimvest has given you (or where you have chosen) a password for access to certain parts of this App, you are responsible for keeping this password confidential. Vimvest asks you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although Vimvest does its best to protect your Personal Information, it cannot guarantee the security of your Personal Information transmitted through this App. Any transmission of Personal Information is at your own risk. Vimvest is not responsible for circumvention of any privacy settings or security measures Vimvest provides.

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Changes to Vimvest's Privacy Policy

Vimvest may update its privacy policy from time to time. If Vimvest makes material changes to how it treats users' Personal Information, it will post the new privacy policy on this page with a notice that the privacy policy has been updated and either notify you at the email address specified in your account or include an in-App alert the first time you use this App after Vimvest makes the change.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring Vimvest has an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

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Contact Information

To ask questions or comment about this privacy policy and Vimvest’s privacy practices, contact Vimvest at:

Vimvest Holdings, LLC
3322 Bee Ridge Road
Sarasota, FL 34239
Email: privacy@vimvest.com

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Introduction

Last Modified: July 31, 2019

Vimvest, LLC, a Florida limited liability company (“Vimvest” or the “Company”) is a registered investment advisor specializing in combining goal-based investing, saving and giving into an unified financial planning experience (collectively, the “Services”). Before using or referring clients to the Services offered by Vimvest and those of its subsidiaries and affiliates, these terms and this agreement (“Agreement”) should be read carefully.

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Referral Bonus & Registration Bonus

The Company hereby agrees to pay “Referrer” a Referral Fee of $5 U.S. Dollars (the “Referral Bonus”) for each of Vimvest’s clients (“Client”) who (1) registers for the Services as a result of the Referrer (“Registration”) and (2) holds an account in good standing. All Referral Bonuses earned by the Referrer shall be due and payable by the Company to the Referrer after ten (10) business days of the client’s Registration, provided however that if Client cancels his or her registration within thirty (30) days of his or her initial registration, no Referral Bonus will be due and payable to Referrer. Client will also earn $5 as a bonus for its Registration as a client during the Registration Period and remains a Client for a period of at least 30 days after Registration.

Bonus and Registration Bonus programs are a limited time offer. Referral Bonuses and Registration Bonus are in the form of a $5 deposit into the initial Investment or Saving account with Vimvest. The Referral Bonus is applied once Registration is complete. This requires that the account be approved and that both parties have completed a first deposit into an Investment or Saving account with Vimvest. To be eligible for the Referral Bonus, the person or persons you refer must use your personal Referral Code when they sign up, or upon completing Registration. If an ACH deposit is reversed from a connected account/bank, all bonuses will be subject to suspension.

Vimvest defines an account in good standing as a verified Investment or Saving account with a successful initial deposit in the minimum amount of $5 with no other suspensions. Referrals who close their account before 30 days, or make any transaction which results in a reversal from their bank will not qualify for the Referral Bonus. To be eligible for the Referral Bonus, the persons you refer must use your personal Referral Code upon sign up.

Vimvest reserves the right to restrict or revoke this offer at any time. Referral Bonus amounts are subject to change at the discretion of Vimvest, LLC. Furthermore, Vimvest may from time to time implement incentive or promotional programs where additional compensation may be offered. Incentive or promotional programs and the associated reward amounts may be changed, revoked, or terminated at the sole discretion of Vimvest.

Notwithstanding the foregoing, the Company retains the right to reject a Referral for any reason or for no reason. Each Referral Bonus paid with respect to a specific Referral shall be considered complete consideration for such Referral. Referrer shall be responsible for any and all income and other taxes applicable to it in connection with the receipt of the Referral Bonus as an independent contractor of the Company. The Company will not be responsible for any expenses of the Referrer in the course of the performance of its obligations hereunder unless such expenses have been previously approved in writing by the Company.

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Referrals

As a component of the Referral, the Referrer: (i) shall perform his or her duties in a manner consistent with the instructions of the Company and the Investment Advisers Act of 1940, as amended (the “Act”); and (ii) shall communicate regularly with the Company regarding any progress the Referrer has made in obtaining Referrals.

• Client acknowledges that Referrer has entered into an agreement with the Company, a registered investment advisor, where the Company has agreed to pay Referrer a fee in exchange for enrolling clients in the Company’s services. Referrer is not an employee or otherwise affiliated with the Company. The Company has agreed to pay Referrer a fee for these solicitation services. The fee is $5 U.S. Dollars for every client who is referred to the Company by Referrer up to twenty (20) clients, or $100 U.S. Dollars per calendar month. The Company pays this fee to Referrer out of its investment management fee. This means that Client does not pay any additional fees as a result of Referrer’s solicitation services. Company website will contain the Company’s current “brochure” containing all information required by Part 2 Form ADV (the “Brochure”). All important disclosures about the Company’s investment management services, fees, and conflicts of interest are in the Brochure. Client hereby acknowledges Client’s consent to this Referral Bonus Disclosure as well as to the Brochure.

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Representations and Warranties of Referrer

The Referrer hereby represents and warrants that the Referrer: (i) is not a person subject to a Securities and Exchange Commission (the “Commission”) order issued under section 203(f) of the Act; (ii) is not a person convicted within the previous ten years of any felony or misdemeanor involving conduct described in section 203(e)(2)(A) through (D) of the Act; (iii) is not a person who has been found by the Commission to have engaged, or has been convicted of engaging, in any of the conduct specified in paragraphs (1), (5) or (6) of section 203(e) of the Act; (iv) has the right to enter into this Agreement; (v) is not a party to any agreement, contract, or understanding that would prevent, limit or hinder his/her performance of this Agreement; (vi) will not enter into any contract, agreement or understanding which is in conflict or which would interfere with the full and complete performance of any of the duties or grants hereunder; and (vii) is not a party to any pending claims or litigation which might affect his/her performance of this Agreement.

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Representations and Warranties of Company

The Company hereby represents and warrants that the Company: (i) is registered under the Act; (ii) has the right to grant the rights and licenses granted herein; (iii) is not a party to any agreement, contract, or understanding that would prevent, limit or hinder its performance under this Agreement; and (iv) is not a party to any pending claims or litigation which might affect its performance under this Agreement.

If you do not want Vimvest to collect this information, you may opt out at anytime by contacting Vimvest at privacy@vimvest.com or by using the opt-out feature in the operating system on your phone.

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Limitation of Warranties

EXCEPT AS SPECIFICALLY SET FORTH IN THIS AGREEMENT, TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE COMPANY DISCLAIMS ALL WARRANTIES AND REPRESENTATIONS, WHETHER EXPRESS, IMPLIED, OR STATUTORY, WITH RESPECT TO THE SERVICES PROVIDED AND OTHER OBLIGATIONS UNDERTAKEN HEREUNDER, INCLUDING WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE (EVEN IF REFERRER HAS BEEN INFORMED OF SUCH PURPOSE), OR WARRANTIES ARISING FROM A COURSE OF DEALING, USAGE OR TRADE PRACTICE. FURTHER, THE COMPANY DOES NOT MAKE ANY WARRANTY THAT THE QUALITY OF THE SERVICES PURCHASED OR OBTAINED BY A CLIENT AFTER A REFERRAL WILL MEET SUCH CLIENT'S EXPECTATIONS.

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Information Collection Technologies

The technologies Vimvest or its third-party services use for automatic information collection may include cookies (or mobile cookies).  A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of this App.

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Indemnification

Each of the Company and the Referrer (an “Indemnifying Party”) shall indemnify, defend and hold harmless the other (the “Indemnified Party”), its affiliates, and each of their directors, officers, employees, and agents from and against all claims, suits and proceedings and any and all related liabilities, losses, expenses, damages and costs (including, without limitation, reasonable attorneys' fees) (collectively, “Losses”) incurred by the Indemnified Party, relating to or arising out of the breach by the Indemnifying Party of any of its duties, obligations, representations or warranties under this Agreement. An Indemnified Party will (i) promptly notify the Indemnifying Party of any claim, suit, or proceeding for which indemnity is claimed (but the Indemnifying Party shall be relieved from liability only to the extent any delay in providing such notice prevents the Indemnifying Party from defending such claim, suit or proceeding); (ii) cooperate reasonably with the Indemnifying Party at the Indemnifying Party's expense; and allow the Indemnifying Party to control the defense or settlement thereof. The Indemnified Party will have the right to participate in any defense of a claim and/or to be represented by counsel of its own choosing at its own expense.

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Limitation of Liability

NEITHER THE COMPANY NOR THE REFERRER WILL BE LIABLE TO THE OTHER PARTY FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL OR EXEMPLARY DAMAGES (EVEN IF SUCH HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES) SUCH AS, BUT NOT LIMITED TO, LOSS OF REVENUE OR ANTICIPATED PROFITS OR LOST BUSINESS.

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Confidentiality

Referrer, Client and Company, and either of their affiliates, and their or their affiliates' officers, directors, trustees, employees, advisers, agents and other personnel, shall use at least the same care and discretion to prevent disclosure of Confidential Information (as hereinafter defined) of the other party as it uses with similar Confidential Information of its own that it does not desire to disclose, but in no event with less than a reasonable degree of care. Either party may use Confidential Information of the other party in order to carry out its obligations hereunder, but in doing so will only allow dissemination of Confidential Information internally on a need-to-know basis (provided such persons are first informed of the confidential nature of such information and directed to use or disclose it only as permitted herein). If either party must disclose any Confidential Information of the other party as required by law, then that party may make such disclosure after providing the other party with reasonable notice so that the other party may seek protective relief. Nothing herein shall be construed as granting either party any property rights, by license or otherwise, to any Confidential Information of the other party, or to any invention or any patent, copyright, trademark, or other intellectual property right of the other party except as specifically provided for in this Agreement. Neither party shall make, have made, use or sell any product or service or other item using, incorporating or derived from any of the other party's Confidential Information except as provided in this Agreement. For purposes of this Section, “Confidential Information” means (1) business or technical information or data (oral, written, electronic or otherwise), including, without limitation, a trade secret (as defined under applicable law), of or about a party provided or made available by such party to the other party that is competitively or commercially valuable to that party and not generally known or readily available by legal means to others, and (2) information regarding the existence, content or status of the business relationship described herein. Confidential Information shall not include information which (i) at the time of disclosure, was published, known publicly, or otherwise in the public domain, (ii) after disclosure, is published, becomes known publicly, or otherwise becomes part of the public domain through no fault of the party receiving the Confidential Information, (iii) prior to the time of disclosure, is known by that receiving party or, after disclosure, is independently developed by that receiving party as evidenced by its written records, (iv) after disclosure, is made available to that receiving party in good faith by a third party who is under no obligation of confidentiality or secrecy to the party disclosing the Confidential Information, or (v) information agreed to be disclosed in accordance with this section regarding confidentiality.

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Work for Hire

Referrer expressly acknowledges and agrees that any work prepared by the Referrer under this Agreement shall be considered "work for hire" and the exclusive property of the Company unless otherwise specified. To the extent such work may not be deemed a "work for hire" under applicable law, the Referrer hereby assigns to the Company all of its right, title, and interest in and to such work. The Referrer shall execute and deliver to the Company any instruments of transfer and take such other action that the Company may reasonably request, including, without limitation, executing and filing, at the Company's expense, copyright applications, assignments , and other documents required for the protection of the Company's rights to such materials.

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Use of Trademarks

Referrer recognizes the Company's right, title, and interest in and to all service marks, trademarks, and trade names used by the Company and agrees not to engage in any activities or commit any acts, directly or indirectly, that may contest, dispute, or otherwise impair the Company's right, title, and interest therein, nor shall the Referrer cause diminishment of value of said trademarks or trade names through any act or representation. The Referrer shall not apply for, acquire, or claim any right, title, or interest in or to any such service marks, trademarks, or trade names, or others that may be confusingly similar to any of them, through advertising or otherwise. Effective as of the termination of this Agreement, whether by expiration or otherwise, the Referrer shall cease to use all of the Company's trademarks, marks, and trade names.

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Termination

The Company may terminate this Agreement at any time, with or without cause, with or without notice, effective immediately. Referrer may terminate this Agreement for any reason or no reason, at any time, upon notice to the Company. Referrer’s termination notice will be effective upon the Company processing the notice. All provisions of this Agreement shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

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Governing Law and Arbitration

This Agreement (and any further rules, policies or guidelines incorporated by reference herein) shall be governed by and construed in accordance with the laws of the State of Florida, without giving effect to any principles of conflicts of law. Unless otherwise agreed in writing by Referrer and the Company, any dispute arising out of or relating to the Agreement, or the breach hereof, shall be finally resolved by arbitration administered by the American Arbitration Association ("AAA") under its Commercial Arbitration Rules. If parties are unable to select an arbitrator then AAA shall select the arbitrator. Judgment on any award entered by the arbitrator may be entered in any court having jurisdiction thereof. CLIENT AND REFERRER EACH AGREE THAT IT MAY BRING CLAIMS AGAINST THE COMPANY ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

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Notifications and Communications

For purposes of communicating with Client or Referrer, notice shall consist of an email from us to an email address associated with Client’s or Referrer’s account. Client and Referrer each also agree that the Company may communicate with Client or Referrer, as applicable, through other means including email, cellular telephone, telephone or delivery services including the U.S. Postal Service. Client and Referrer each agree that the Company shall have no liability associated with or arising from either party’s failure to maintain accurate contact information.

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Integration and Severability

This Agreement is the entire agreement between Referrer and the Company with respect to client Registrations and Referral Bonuses, and supersedes all prior or contemporaneous communications and proposals (whether oral, written or electronic) between Referrer and the Company with respect to all Referrals. If any provision of this Agreement is found to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that the Agreement will otherwise remain in full force and effect and enforceable. The failure of either party to exercise in any respect any right provided for herein shall not be deemed a waiver of any further rights hereunder.

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