PRIVACY POLICY

Introduction

Welcome to Innealta Capital, LLC

We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Innealta LLC (“Innealta”) and Altafid, (collectively, the “Innealta Entities”) collect, including through our websites, Innealta’s original articles, our iOS mobile application and our Android mobile application. It also explains why we collect your information and how we use it. Privacy is important to Innealta. We will never rent or sell your information to anyone. If you have any questions or if you believe that Innealta has not adhered to this privacy policy, please send us a note at support@altafid.com

Table of Contents

Privacy Notice

1. What does Innealta do with your personal information?
2. How do we use and share your personal information?
3. Who we are
4. What we do
5. Key definitions

Full Privacy Policy

1. Information We Collect and Why
2. How We Use Your Personal Information
3. How We Share Your Information
4. Opt-out Information
5. How to Request Deletion of the Personal Information We Collect
6. How Your Personal Information is Protected
7. How You Can Access or Change Your Personal Information
8. Anonymized Information
9. Other Important Information
10. International Visitors

What does Innealta do with your personal information?

Why?

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

What?

The types of personal information we collect and share depend on whether you are a visitor to our website or a client and, if a client, the product or service you have with us. Information we collect from clients includes, among other information:

• Full legal name, date of birth and social security number
• Information about your financial status
• Account balance, assets and transaction history

When you are no longer our client, we continue to retain and share your information as described in this notice below.

How?

All financial companies need to share clients’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients’ personal information; the reasons Innealta chooses to share; and whether you can limit this sharing. How do we use and share your personal information?

• As described below, you are able to limit our sharing of your transaction data by emailing support@altafid.com ** Innealta does not collect or share personal information for these purposes. Questions? Contact our customer support team at support@altafid.com or call +1 (737) 808-4640. Other important information If you are an account holder of a joint account, you have individual rights with respect to our use of your personal information. If you would like more specifics about how we use, store and share your information, read on for the rest of our privacy policy.

Full Privacy Policy

Information We Collect and Why In order to provide a high-quality service, Innealta collects various types of information when you visit the website or mobile app, sign-up as a customer, or otherwise engage with Innealta.

Visitor Information We collect various types of anonymous information about visitors to Innealta, such as device-related information (including browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the Innealta site, browsing activity, and any site that referred you to Innealta). We also collect information that you input into our website, such as your name or email address when you begin the account application process or comment on the Innealta blog. We use this information to better understand our visitors and our business, facilitate site navigation, provide the services or information you request, and enhance the Innealta service. To the extent you enter identifying information as part of the account application process, we are required by law to store that information to comply with federal regulations.

Customer Information When you choose to create an account with Innealta, we will also collect certain personal information, including your full legal name, email address, permanent address, date of birth, social security number and information about financial status. We are required by law to collect and store this information to provide you with financial services. If you do not wish to provide this information, you cannot become a Innealta customer.

Other Ways We Collect Information Apart from through the account opening process and from visitors to the site, we may collect various other types of personal information if you or a friend engages with Innealta. We collect your email address as part of our customer referral service or if you subscribe to the Innealta blog. We may also collect personal information if you enter it into our live chat program or contact us or otherwise give it to us (e.g., in an email, phone call, or live chat with a member of our customer support team). Further, we may collect information regarding your browsing activity when you visit Innealta’s websites and actions you take within your Innealta account while logged in to your Innealta account.

Cookies and Pixels Cookies are small pieces of data which are stored on your computer, mobile phone or any other device used to access the internet. Pixels are small blocks of code on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.

We use these technologies to customize Innealta and improve your experience with the site. Cookies store anonymous information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Innealta and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel that only stores anonymous information to track visitors across websites or devices to better customize our marketing and advertising campaigns. We also offer certain tools from third-party service providers that may use cookies and/or pixels.

Cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept any cookies or pixels to use this site. However, refusing to accept cookies or pixels will make the use of Innealta more cumbersome and less accessible.

Analytics Services We use third-party analytics tools, including Google Analytics (such tools collectively referred to as “Analytics Services”) to collect information about the usage of this site. The Analytics Services collect information about how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use the information we get from these Analytics Services to improve this site. These Analytics Services collect the IP address assigned to you on the date you visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

How We Use Your Personal Information

Innealta uses your personal information to provide financial advice and other services; enhance your customer experience; improve our products and features; provide customer support; open, operate, and maintain your account in accordance with applicable law; investigate and understand how Innealta is used; monitor and protect the security and integrity of Innealta; and better market and advertise Innealta’s services. If you link external accounts to your Innealta account, we may use transactional data from those accounts to provide you with financial advice or to recommend additional Innealta products and services to you. You understand and agree that Innealta will compare your identifying information with government-provided lists of suspected terrorists, and for other applicable corporate, legal, and regulatory verification requirements, including, but not restricted to anti-money laundering and Know Your Customer.

As part of this process, we may from time to time include, compile, or aggregate some of your personal information in certain data analysis, reports, or other interpretations of investment trends for both internal and external purposes. When including, compiling, or aggregating personal information for such purposes, we make sure that the information is anonymized such that it is not identifiable to any particular customer.

Additionally, we, or our service providers, may use your personal information to contact you regarding Innealta's services, resources, or Innealta job openings that we think may be of interest to you. If you no longer wish to receive marketing emails from Innealta, please click the “unsubscribe” link that can be found at the bottom of each such email message. If you no longer wish to receive text messages, please type "STOP" in response to any such text. Please note that if you hold an account with Innealta, you cannot opt-out of certain communications related to the administration of your account, including communications related to billing, statement and trade confirmation delivery or certain regulatory matters.

How We Share Your Information

We do not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law.

In order to provide financial services and in connection with our everyday business purposes and activities, we may share your personal information with third parties who perform services on our behalf. Examples of these third parties and services include consumer identification verification services, public accounting firms and other professional firms, brokerage firms, custodian banks, and certain other vendors and service providers who perform marketing, advertising, research and analytics services on our behalf. We have entered into agreements that require that these third parties keep this information confidential. We may also disclose your information to other third-party financial institutions, e.g., if you ask to transfer assets from Innealta to such financial institutions. If you choose to use Innealta’s charitable giving feature, we will share your name and email address with the recipient charity, which the recipient charity may use to contact you.

We may also disclose personal information in response to service of legal process, such as a court order, summons, or subpoena, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), frontrunning or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Terms of Service or customer agreements. We also may disclose information about you if necessary to determine your eligibility to recover compensation in connection with class action lawsuits.

Furthermore, we may disclose personal information in specific other cases with your consent.

How we share your personal information for marketing and research analytics

As disclosed above, we use certain vendors and service providers who perform marketing, advertising, research, and analytics services on our behalf.

These include platforms that monitor and provide analytics on our systems, applications that support automated emails for marketing efforts, applications that allow us to build personalized social media campaigns, and tools to record customer communication and interaction history. We use these service providers to comply with regulatory requirements, provide financial services, enhance your customer experience, improve our products and features, and provide customer support. These vendors and service providers with whom we share your personal information are bound by agreements with us to keep your personal information confidential and we never rent or sell your information to anyone. We use reasonable efforts to limit the sharing of personally identifiable information with vendors and service providers when it is not reasonably required for the service and share anonymized information in lieu of personal information when it is practicable. Certain experiences on Innealta's website and applications may entail engaging directly with third-party service providers. In such situations, you will be presented with terms and conditions that apply to the use of that service, which may include authorizing such service providers to use anonymized data from your engagement to improve their own products or services. For more information about anonymized information, see details below.

Opt-out Information

You may opt-out of promotional or marketing emails by clicking “unsubscribe”, which appears in the footer of such emails. Note that you cannot opt-out of administrative communications, such as emails that contain account statements, notify you regarding changes to your account or contain updates to our terms and conditions.

How to Request Deletion of the Personal Information We Collect

Innealta allows you to close your Innealta accounts. You can review our resource article on deleting accounts for instructions on how to do so. Closing a joint account works in the same manner, and either joint account holder can delete a shared joint account. Please note that we retain information on deleted accounts as required for legal, regulatory and security purposes.

How Your Personal Information is Protected

Innealta works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use the strongest available browser encryption, store all of our data on servers in secure facilities and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Innealta to agree to keep your information confidential.

Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain a Innealta account that you access through our website or mobile apps, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

How You Can Access or Change Your Personal Information That We Have Collected Once you have registered with Innealta, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at support@altafid.com. Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of six years.

Anonymized Information

We may share anonymized information that is summarized or derived from information you provide to us. Anonymous information is information that does not include any personally identifiable information. From time to time, Innealta performs analysis on investing related topics using anonymized and/or summarized insights from customers. Such research reports, blog posts or findings may be shared with external publishers or published by us on financial topics of interest.

Other Important Information

Former Customers If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers. We preserve former customer data in order to comply with regulatory obligations.

How We Respond to Do Not Track Signals Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Customers using certain modern browsers have the ability to activate a “Do Not Track” signal. Innealta does not currently respond to the “Do Not Track” signal.

How You Accept This Policy By using and continuing to use the Innealta websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy, and it supersedes any earlier version. Our Terms and Conditions take precedence over any conflicting privacy policy provision.

Changes to the Policy We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or app. Please check the effective date below to determine if there have been any changes since you have last reviewed the Innealta privacy policy.

Children Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Innealta and/or provided us with personally identifiable information, please contact us at support@altafid.com. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account.

International Visitors

This Service is hosted in the United States. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy.

Questions

If you have any questions on the privacy policy, please contact us at: Innealta Capital, LLC 13215 Bee Cave Pkwy, Bldg A, Suite 240, Austin, TX 78738 consulting@innealtacapital.com +1 (737) 808-4640

COPYRIGHT AND INTELLECTUAL PROPERTY POLICY

Trademarks

Innealta Capital, LLC and our affiliates (“Innealta”) works hard to make sure our goods and services are easily recognizable. We do this by associating our goods and services with our trademarks and trade dress (“Mark” or collectively “Marks”). This is why our Marks cannot be used in any manner that is deceptive or disparaging, or in connection with any product or service that is not ours. Using a Mark without our prior written consent constitutes trademark infringement and unfair competition in violation of federal and state laws.

The following is a non-exhaustive list of our Marks. The absence of a product or service name or logo from this list does not constitute a waiver of trademark or other intellectual property rights.

For more information on how to use our Marks contact support@altafid.com.

Copyright and Other Intellectual Property

Innealta maintains [innealtacapital.com, altafid.com], our mobile applications, and our other online services and websites (collectively, the “Platform”). Innealta is the owner or the authorized user of all text, images, graphics, photos, animation, music, sounds and other materials contained within the Platform. The materials contained within the Platform, including, without limitation, any copyrights, trademarks, service marks, and all other proprietary materials, are protected by U.S. and international copyright laws and treaty provisions, trademarks laws, and other proprietary rights laws. Innealta also owns a copyright in the selection, coordination, and arrangement of the material contained within the Platform.

The material contained within the Platform is provided by Innealta only for lawful uses by clients, Innealta employees, and members of the general public. The material may not be copied, republished, incorporated into another website or reproduced (whether by linking, framing, or any other method), transmitted, distributed, uploaded, posted, used to create a derivative work or exploited in any other way without the express prior written consent of Innealta Capital, LLC. Use of the Platform does not grant users any right, title, or interest in the materials contained within the Platform.

Digital Millennium Copyright Act

Innealta respects the intellectual property rights of others and expects its users to do the same. Pursuant to the Digital Millennium Copyright Act of 1998 (the “DMCA”), Innealta will respond expeditiously to notices of alleged copyright infringement on the Platform that are reported to Innealta’s Designated Copyright Agent identified in the Notice (as described below).

Innealta prohibits copyright infringing activities on the Platform and will, if properly notified of infringing files, expeditiously remove or disable access to such files. Upon receipt of the Notice, Innealta will take whatever action, in its sole discretion, it deems appropriate, including removing or disabling access to the material without prior notice, to the extent it is technologically possible given the nature of the Platform.

Notice: If you are a copyright owner, or agent thereof, please report alleged copyright infringements taking place on or through the Platform or other Innealta services by completing a DMCA notice of alleged infringement (“Notice”) and delivering it to Innealta’s Designated Copyright Agent. Upon receipt of a Notice, Innealta will take whatever action, in its sole discretion, it deems appropriate, including removal of the challenged content from the Platform. Innealta will make best efforts to review the Notice as soon as possible and to promptly remove or block access to the content, so long as all the required information is included in the Notice.

Please provide the following information to our Designated Copyright Agent:

• Identify the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on the Platform are covered by this Notice, a representative list of the copyrighted works that are claimed to have been infringed.
• Identify the material or activity claimed to be infringing or to be the subject of infringing activity and provide information reasonably sufficient to locate the material, including, at minimum, if applicable, the URL.
• Include a short explanation of how the content infringes your rights.
• Provide information reasonably sufficient to permit us to contact you, such as a mailing address, telephone number, and, if available, email address.
• Include both of the following statements in the body of the Notice: o “I hereby state that I have a good faith belief that the disputed use of the copyrighted material or reference or link to such material is not authorized by the copyright owner, its agent, or the law (e.g., as a fair use).” o “I hereby state that the information in this Notice is accurate and, under penalty of perjury, that I am the owner, or authorized to act on behalf of the owner, of the copyright or of an exclusive right under the copyright that is allegedly infringed.”
• Sign the Notice by providing a physical or electronic signature along with your full legal name. Counter notice: Once an appropriate Notice is received, Innealta will follow the procedures provided in the DMCA, which set forth a notice and takedown process, subject to the alleged infringer’s right to submit a counter-notification claiming lawful use of the copyright or other intellectual property interest that is allegedly infringed. Please note that any Notices or counter notices received may be sent to Innealta’s legal advisors.

Any Counter Notice should include the following:

• Your name, address, telephone number, and email address.
• An identification of the material that Innealta has taken down.
• A statement under penalty of perjury that you have a good faith belief that the material was removed as a result of mistake or misidentification.
• A statement that you consent to the jurisdiction of the U.S. District Court for the federal district in which you reside or the jurisdiction of the U.S. District Court for the Western District of Texas if you reside outside the United States, and that you will accept service of process from the complaining party or its agent in the event that a lawsuit is filed against you from the complaining party or its agent in the event that a lawsuit is filed against you relating to such content.
• Your physical or electronic signature.