Odyssey Money, Inc.

Odyssey Money, Inc. ("Odyssey", "us", "we", or "our") operates odysseymoney.ai (the "Site"). This page informs you of our policies regarding the collection, use and disclosure of information we collect on the Site or any offline location that makes this Privacy Policy available to you.

By using the Site or interacting with us offline, you agree to our Terms and Conditions and our collection, disclosure, and use of information in accordance with this policy, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Site.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the "Contact Us" section. If you are a Nevada or California resident, please see the additional disclosures at the end of this Privacy Policy.

Information Collection

A. Information You Provide

While using our Site, we may ask you to provide us with certain information, including information you provide when you register an account, update your profile, access our content, make a purchase, or contact customer support. The categories of information we collect includes:

• Contact Data, including your first and last name, email address, postal address, and phone number.
• Site Account Information, including your Site username, password, password hints, and information for authentication and account access.
• Financial Information, as required to provide the services on the Site, such as retirement account information. This may include details such as account numbers, balances, other attributes, and credentials to financial accounts. We only collect and use this information, including the information made available to us through such access, at your direction to complete your transactions, to update your contact details as necessary to complete your transactions, or if otherwise directed by you.
• Demographic Data, including your age, gender, and country.
• Profile Data, including your interests, inferences, preferences, and favorites.
• Content, including content within any messages you send to us (such as feedback, special instructions you provide, and questions to customer support). We also collect content within any messages you exchange with us through our chat functionality on the Site.
• Employment Data, including the retirement plans used by your former and current employer, and other employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically

In addition, we automatically collect information when you use the Site. The categories of information we automatically collect include:

• Service Use Data, including data about features you use, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics, emails and advertisements you view, products and services you view and purchase, and your referring and exiting pages.
• Device Data, including your computer's Internet Protocol ("IP") address, browser or device type, browser or device version, your internet service provider, and your device's regional and language settings.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

The types of tracking technologies we use to automatically collect information include:

• Log Files, which are files that record events that occur in connection with your use of the Site.
• Cookies are files with small amounts of data stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. 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), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties, including Meta (e.g., Facebook and Instagram), TikTok, Google, and others. These pixels allow us and our partners — including advertising agencies and platforms — to track conversions and user behavior on and off our Site, deliver personalized advertising, improve the effectiveness and relevance of our marketing campaigns, and enable features such as social media integrations.
• App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Site, and provide you with additional functionality.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the "Analytics and Advertising" and "Your Rights and Choices" sections below.

C. SMS Communication Policy

We may collect your mobile phone number in connection with the performance of our Services. By providing your mobile phone number and opting in, you consent to receive SMS messages from us.

The following terms explain how we use your number for SMS communications and how you may opt out of receiving messages.

Collection and Use of Mobile Phone Numbers

• No Marketing Use: Phone numbers collected as part of the SMS consent process will not be used or shared with third parties for marketing purposes.
• Types of Messages: If you have opted in to receive SMS messages, we may send appointment reminders, follow-up messages, billing notifications, and other customer service-related communications.
• Message Frequency: The number of messages you receive will vary based on the type of communication. For example, appointment reminders and billing updates may be sent up to twice per week.
• Standard Charges: Standard message and data rates may apply based on your mobile carrier's pricing plan. Fees may vary for domestic and international messages.

Third-Party Service Providers

We may utilize third-party service providers to facilitate and process SMS communications. These providers process your personal information solely to deliver SMS messages on our behalf and are contractually required to maintain confidentiality and security. However, we encourage you to review their privacy policies to understand how they handle personal information.

How to Opt In

You can opt in to receive SMS messages by:

• Providing your mobile phone number via our online platform.
• Giving verbal consent during a recorded conversation.
• Submitting an online or paper form that includes an SMS consent section.

How to Opt Out

You may opt out of receiving SMS messages at any time by:

• Replying STOP to any message you receive from us.
• Adjusting your communication preferences in your online account settings.
• Contacting our customer support team at support@odysseymoney.ai.

Once you opt out, you will no longer receive SMS messages from us, except for transactional or legally required communications (if applicable).

D. Information from Other Sources

We also collect information from other sources. The categories of sources from which we collect information include:

• Data brokers from which we purchase data to supplement the data we collect.
• Other entities with which you interact in order to use the Site. For example, we collect information from the Plaid service in order to assist you with establishing your retirement account(s) with the requested financial institution. This requires that you use Plaid to link your financial account to Plaid, in order to send your financial information to the Site. We strongly encourage you to review Plaid's privacy policy. We are not responsible for Plaid's privacy practices. Plaid will provide the Site with an access token related to your financial information to facilitate the services requested by you.
• Social networks with which you interact.
• Partners that offer co-branded services, products, or programs.
• Publicly available sources, including data in the public domain.

USE OF INFORMATION

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

• Operating and managing our Site.
• Performing services requested by you, such as helping facilitate any transactions where we act as an agent on your behalf, responding to your comments, questions, and requests, and providing customer service.
• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Preventing and addressing fraud, breach of policies or terms, and threats or harm.
• Monitoring and analyzing trends, usage, and activities.
• Conducting research, including focus groups and surveys.
• Improving the Site and other Odyssey websites, apps, marketing efforts, products, and services.
• Developing and sending newsletters, advertising, direct marketing, and communications about our and other entities' products, offers, promotions, rewards, events, and services.
• Conducting promotions, including verifying your eligibility and delivering prizes connected with your entries.
• Fulfilling any other purpose at your direction.
• With notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the "Your Rights and Choices" section below.

Sharing of Information

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

• Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the "Analytics and Advertising" section below. In other instances, we share information with vendors and other parties, such as Plaid, in order to provide the service to you, comply with your requests, market and advertise to you, and otherwise comply with the law.
• Financial Institutions. We share information with financial institutions, such as 401(k) and IRA providers, when you engage us to transact with them on your behalf. We may be compensated in connection with these activities.
• Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
• Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
• Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
• Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Site or anyone else.
• Facilitating Requests. We share information at your request or direction.
• Consent. We share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the "Your Rights and Choices" section below.

Other Parties

We offer parts of our Site through websites, platforms, and services operated or controlled by other parties. Our Site includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. In addition, we integrate technologies operated or controlled by other parties into parts of our Site.

We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Site on social media (e.g., by using a hashtag associated with Odyssey in a tweet or post), we may use your reference on or in connection with our Site.

Please note that when you interact with other parties, including when you leave our Site, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Analytics and Advertising

We use analytics services, such as Google Analytics, to help us understand how users access and use the Site. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google, Facebook, and TikTok that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Site (including our website and emails) 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").

We also use audience matching services to reach people (or people similar to people) who have visited our Site or are identified in one or more of our databases ("Matched Ads"). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Site, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our Site and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Site and your rights and choices regarding analytics and advertising, please see the "Information Collected Automatically" and "Your Rights and Choices" sections.

Your Rights and Choices

A. Account Information

You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to the email address set out in the "Contact Us" section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

B. Tracking Technology Choices

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Do Not Track. Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do about these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to "Do Not Track" signals. For more information on "Do Not Track," visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Site may not function correctly.

C. Analytics and Interest-Based 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/.

Facebook provides settings to allow you to opt out of the use of certain information collected by Facebook at https://www.facebook.com/help/247395082112892.

TikTok provides settings to allow you to opt out of the use of certain information collected by TikTok at https://support.tiktok.com/en/account-and-privacy/personalized-ads-and-data/use-of-off-tiktok-activity-for-ad-targeting.

The companies we work with to provide you with targeted ads 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; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) 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).

To opt out of us using your data for Matched Ads, please contact us as set forth in the "Contact Us" section below and specify that you wish to opt out of matched ads. We will request that the applicable party not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable party to opt out.

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting "Limit Ad Tracking" (for iOS devices) or "Opt out of Interest-Based Ads" (for Android devices).

Please note that if you opt out of using any of these methods, 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.

D. Communications

• E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the "Contact Us" section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
• Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.

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

Children

The Site is intended for general audiences, and is not directed at children under 13 years old. We do not knowingly collect personal information (as defined by the U.S. Children's Privacy Protection Act, or "COPPA") from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, contact us at support@odysseymoney.ai. We will remove the personal information in accordance with COPPA. We do not knowingly "sell," as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission over the Internet, is not 100% secure and we cannot guarantee the security of information about you.

International Transfer

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Site from outside the U.S., please be aware that information collected through the Site may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Site or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.

Changes to this Privacy Policy

This Privacy Policy is effective as of November 21, 2023 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Site after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy then posted.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us at support@odysseymoney.ai.

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at support@odysseymoney.ai.

Additional Disclosures for Nevada Residents

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at support@odysseymoney.ai.

Your Privacy Rights for California Residents (Shine the Light)

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in "Contact Us" above and specify that you are making a "California Shine the Light Request." We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.