Privacy Policy

FriedmannAI Inc. ("Friedmann AI", "we", "us") provides financial advisors with digital tools and software for financial planning. We are located at 407 Iroquois Shore Rd. Unit 8, Oakville ON L6H 1M3, Canada. We run the website https://www.friedmann.ai/ and its subdomains. We also run mobile applications, programs and interfaces (collectively referred to as our "Platform").

We respect your privacy and want to be clear about what information we collect, why we collect it, and what we do with it. We follow the Personal Information Protection and Electronic Documents Act ("PIPEDA"), which is Canada's privacy law for businesses collecting and handling Personal Information.

This Privacy Policy ("Policy") applies to the Personal Information we collect from those use our Platform ("Users"). Please read this Policy carefully. If you have any questions about the Policy or our privacy practices, you can reach out to our privacy officer, Ameen Neami at team@friedmann.ai.

If you are located in a jurisdiction outside Canada with specific privacy laws, you may have additional rights not described in this Policy. We recommend you seek independent legal advice to determine whether our privacy practices are compatible with your local legal privacy legislation before using our Platform. If our practices do not meet your local legal requirements, do not use our Platform or provide any Personal Information. Continued use of our Platform constitutes your acknowledgment of these limitations and your voluntary assumption of any associated risks.

Platform use and any dispute over privacy are subject to the terms of this Policy, our Terms of Service, and the terms of any other agreement you have entered into with us.

By using our Platform, you acknowledge you have read and understood this Policy and consent to the collection and use of Personal Information as described in this Policy. If you do not consent, you must not use the Platform.

"Personal Information" is any information that could be used to identify you as an individual. Personal Information includes information that could identify you when combined with other details.

We collect Personal Information from all Users of our Platform, including those who visit our website and those who register an account.

Visitors

You are a "Visitor" when you visit our website and its subdomains and interact with the content of our website. From Platform Visitors, we collect:

• IP address
• Timestamp
• Pages visited
• Interactions with content
• Session duration
• Geolocation
• Information about browsers and devices
• Internet and network activity

Registered Users

You are a "Registered User" when you register for an account and interact with or pay for services through our Platform. From Registered Users, we collect:

• The same information we collect from Platform Visitors
• Personal identifiers including name, phone number, email address, mailing and billing addresses, and identification documents to validate your identity
• Financial information, including banking and credit/debit card information, and the details of any transaction carried out through our Platform
• Information about Platform use, including Personal Information shared when you provide comments or feedback about your Platform experiences.

In using our Platform, Registered Users may enter, upload or otherwise provide Personal Information about their clients, including personal identifiers (e.g. name, contact information) and financial information (e.g. income, assets, and liabilities) ("Client Personal Information").

REGISTERED USERS REPRESENT AND WARRANT THAT THEY HAVE OBTAINED ALL NECESSARY CONSENTS FROM THEIR CLIENTS TO COLLECT, USE AND DISCLOSE CLIENT PERSONAL INFORMATION THROUGH OUR PLATFORM, AND THAT SUCH CONSENTS COMPLY WITH ALL APPLICABLE PRIVACY LAWS.

We may collect other information which may be used in combination with identifying or potentially identifying information. We will treat combined information as Personal Information.

We collect Personal Information for the following purposes:

• To provide and administer our Platform and services, including personalizing your experience and providing other services you may request;
• To create, maintain and monitor Registered User accounts;
• To provide technical support, respond to communications and feedback, and communicate updates and necessary information regarding your use of our Platform;
• To process transactions and payments;
• To share marketing and promotional communications, in accordance with your consent/preferences for receiving such communications;
• To share with third-party service providers to support service provision, administration, advertising and improvement of our Platform;
• To undertake research and development activities to improve our existing or to create new products, features and services, and/or to expand our user base;
• To fulfill the purposes described to you when the information was collected; and/or
• To comply with necessary laws, including in support of fraud prevention, anti-money laundering, security investigations, risk assessments, and regulatory compliance.

We will ask for your permission before using your Personal Information for any purpose not described in this Policy. You can withdraw your consent at any time by contacting us using the information provided below.

We do not sell Personal Information to third parties. We do not use Client Personal Information to train the FriedmannAI model.

We collect Personal Information:

• Automatically, directly or through third-party plugins and integrations when you visit or interact with our Platform, including through server logs, cookies and other tracking technologies that gather information about Users and User activity;
  • Cookies are small files stored on your device by your web browser. Cookies allow the Platform to store information that will recognize you each time you visit. You may refuse to accept cookies or delete stored cookies through your browser.
  • You may change privacy settings in your browser to limit or request sites not to track your activity.
• When you provide such information to us, such as when you create an account, interact with the features on our Platform, complete forms, respond to surveys, post comments or reviews, initiate a transaction or complete a purchase;
• When we verify your identity, including when you share your government issued identification; and/or
• Through direct communications with us, including communications received via email, phone, responses to questions, customer service records, User feedback, live chat and other online support channels.

We take safeguarding your information very seriously. We have implemented commercially reasonable administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control.

All Personal Information we collect is stored as data on third-party servers. We take reasonable steps to ensure our server providers adhere to industry security standards for the protection of Personal Information. These servers are located in Canada and the United States of America. When Personal Information is transferred to the United States, it becomes subject to the U.S. CLOUD Act and other U.S. laws that may permit U.S. government authorities to access such data.

We protect the Personal Information of our Users using cyber security services, firewalls, as well as other security measures embedded within our third-party service providers. From time to time, your Personal Information may be accessed by FriedmannAI-authorized services or staff in another country where we or authorized third parties operate. We use commercially reasonable efforts to implement and enforce these measures.

Where you must complete sign-in processes to access certain features of our Platform, you are responsible for keeping your sign-in information confidential and secure. Do not share your sign-in information with anyone.

Some of our third-party service providers are located outside of Canada. For Users located in Quebec, data may be stored outside of Quebec. Data may be transferred to or processed in the United States of America. We take steps to safeguard data and keep Personal Information secure when it is shared with third-party service providers outside Canada. The laws in other places may differ from those in Canada. Government authorities in jurisdictions outside Canada may access Personal Information in accordance with local laws.

By using our Platform, you agree to the transfer of your Personal Information for the purpose of storage and processing.

If we discover a security incident that compromises our storage and protection of Personal Information, we will notify Users and the appropriate regulatory authorities as required by applicable law.

We retain your Personal Information while it is needed to fulfill the intended purpose for which it was collected and for seven years following the cessation of its intended purpose. We may also retain Personal Information as necessary:

• For legitimate business purposes, such as auditing or account recovery;
• To comply with applicable federal, provincial or other laws;
• To prevent fraud or future abuse; or
• By contract with a partner and/or institution.

Third-party service providers are external, independent entities that offer technologies and services useful to our Platform. We may share Personal Information with third-party service providers.

We may transfer Personal Information to the following third-party service providers:

Data Storage & Infrastructure

• Supabase
• IBM Cloud
• Redis Cloud

Identity Verification

• Supabase

AI & Chatbot

• OpenAI
• Together AI

Tracking & Analytics

• Sentry
• PostHog
• Tavily

Payment Processing

• Stripe

In addition to the third parties listed above, we may share your Personal Information with third parties for the following purposes:

• Cloud storage and infrastructure;
• Analytics;
• Identity verification, ensuring accuracy of information provided, and conducting necessary background checks;
• Customer support;
• Marketing and advertising, including through social media advertising services, advertising networks, and other service providers to reach and understand our Users or measure advertising effectiveness;
• Research, including with third parties to conduct surveys or research projects in collaboration with us or on our behalf;
• Safety and security;
• Professional services, including accountants, consultants, lawyers and other professionals service providers; and
• Insurance and financing partners.

By using our Platform, you consent to our sharing your Personal Information with third parties for the purposes described in this Policy. We will seek your consent before sharing Personal Information with a third party for a purpose not described in this Policy.

Our Platform includes links to third-party websites. We provide links to third-party websites as a convenience to the user. These links are not an endorsement of or referral to the third party. We are not responsible for the websites or privacy policies of these third parties. If you follow any of these links, please read the third party's privacy policy carefully.

The transmission of information via the internet is not completely secure. While we use commercially reasonable security measures to protect our Users' Personal Information, no method of electronic storage or transmission over the Internet is 100% safe. The use of our Platform carries inherent risks that, despite our use of commercially reasonable security safeguards, we cannot completely eliminate. By using our Platform, you acknowledge that you understand and accept this risk.

Under PIPEDA, Users have the following rights when it comes to the collection and use of their Personal Information:

• The right to confirm collection and use of your Personal Information. You have the right to confirm the collection of your Personal Information, the type of Personal Information collected, its use and whether it has been shared with third parties.
• The right to access. You have the right to request access to your Personal Information.
• The right to correct your Personal Information. You have the right to request that we correct or update any Personal Information about you that is inaccurate or incomplete.
• The right to withdraw consent. You have the right to withdraw your consent to our use of your Personal Information. This includes requesting that we remove your Personal Information from our databases as well as opting out or unsubscribing from marketing and promotions.
• The right to non-discrimination. We will not use your Personal Information to profile or categorize you in a way that leads to unfair, unethical or discriminatory treatment contrary to human rights law. We will not discriminate against you for exercising any of these rights.

Note: Certain features of our Platform require Personal Information to function effectively (e.g. account registration, payment processing). Where accurate Personal Information is a necessary technical and/or operational requirement for service delivery, not providing accurate Personal Information, deleting your Personal Information or withdrawing your consent for the collection, use or disclosure of your Personal Information may limit or prevent your access and use of our Platform.

• The right to file a privacy-related complaint. You have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the relevant provincial privacy authority in the event you believe FriedmannAI's actions are in contravention of applicable privacy law.

You may access, update, delete, and/or correct inaccuracies in the Personal Information shared when you registered for your account, subject to limited exceptions prescribed by law. To make these changes, log into your account, go to your account profile, and make the necessary changes.

To opt-out/unsubscribe from our marketing and promotional communications, please click the appropriate link at the bottom of the communication/change your notification settings in your account or contact us using the contact information provided below.

You may exercise your right to access or correct your Personal Information or withdraw your consent to its use by submitting a written request using the contact information provided below. We will respond to your request within 30 days of receiving the request and may verify your identity before fulfilling any such request. If we need more time, we will let you know and explain why.

When you make a privacy-related request that involves data collected by our third-party service providers, we may communicate with them as needed and to the extent permitted by law. We will keep you informed on the status of your request in such cases.

If you have a concern or complaint, you can contact our privacy officer (contact details below). We will respond to you within 30 days of receiving your complaint. If we need more time to resolve your complaint, we will let you know and provide you with an expected timeline for resolution.

Our services are not meant for people under 16 years old. We do not knowingly collect Personal Information from children under 16. If you are under 16, please do not use our services or provide any Personal Information to us. We encourage parents and legal guardians to monitor their children's internet usage and to help enforce this prohibition. If you have reason to believe that a child under the age of 16 has provided information to us, please contact our privacy officer as set out below.

We update this Privacy Policy when necessary to reflect changes in our practices or legal requirements. When we make important changes that affect your privacy rights, we will:

1. Post the updated policy on our website with a clear summary of what has changed.
2. Send you an email notification about the changes we make.
3. Post a notice on our Platform about these changes.

The updated policy will take effect 30 days after we post it, unless we specify a different date.

We strongly encourage you to check back frequently to see any updates or changes to our Privacy Policy.

All issues and questions concerning the application, construction, validity, interpretation and enforcement of this Privacy Policy shall be governed by and construed in accordance with the laws of the Province of Ontario, and the federal laws of Canada applicable therein. Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Ontario, provided nothing herein prevents us from seeking injunctive relief in any jurisdiction to protect our intellectual property or confidential information.

Please contact our privacy officer, Ameen Neami at team@friedmann.ai directly if:

• You have any questions or comments about this Policy
• You need help accessing, updating, and/or correcting inaccuracies in your Personal Information, or
• You otherwise have a question or complaint about the treatment of your Personal Information.

To protect your privacy, we will verify your identity before providing access to your Personal Information or responding to your privacy requests. We will only ask for information necessary to verify your identity.