Openfinance GLBA Policy Notice

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.

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number
• Income
• Risk Tolerance
• Account Transactions
• Assets, and
• Employment Information

When you are no longer our customer, we continue to share your information as described in this notice.

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Openfinance Technologies, LLC ("Openfinance") chooses to share; and whether you can limit this sharing.

For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes — to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We don't share

For our affiliates' everyday business purposes — information about your transactions and experiences

Yes

No

For our affiliates' everyday business purposes — information about your creditworthiness

No

We don't share

For our affiliates to market to you

No

We don't share

For nonaffiliates to market to you

No

We don't share

Openfinance Technologies, LLC

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We collect your personal information, for example, when you:

• give us your income information or provide account information
• show your government-issued ID or show your driver’s license
• give us your contact information

We also collect your personal information from others, such as credit bureaus, affiliates or other companies.

Federal law gives you the right to limit only

• sharing for affiliates’ everyday business purposes—information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Your choices will apply to everyone on your account.

Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Openfinance Holdings, Inc.
• CFX Direct, LLC

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Nonaffiliates we share with can include collection agencies, IT service providers, consumer reporting agencies, and others.
• Openfinance Technologies, LLC does not share with nonaffiliates so they can market to you.

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.Federal law gives you the right to limit only

• Openfinance Technologies, LLC doesn't jointly market.