Privacy Policy

Welcome to Freedom Reserves ("Company," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at freedomfund.io (the "Site") or use our services. Please read this policy carefully. If you do not agree with its terms, please discontinue use of our Site.

1. Information We Collect

We may collect the following categories of personal information:

Information You Provide Directly:

• Name and contact details (e.g., email address, phone number, mailing address)
• Account credentials (e.g., username and password)
• Financial information (e.g., investment amounts and payment details processed via third-party payment processors)
• Communications you send us via contact forms or email

Onboarding, Identity Verification, and Account Connection Information: When you create an account, we and our verification provider, Plaid Inc. ("Plaid"), collect information needed to verify your identity and connect your financial accounts, including:

• Identity information – name, date of birth, residential address, government-issued identification number (e.g., Social Security number), and identity document or image data you provide.
• Financial account information – account and routing numbers, account name and type, account balances, and the identity of the account owner, obtained from the financial institution you select.

See Section 2 below for how this information is handled.

Information Collected Automatically:

• Device and browser information (e.g., IP address, browser type, operating system)
• Usage data (e.g., pages visited, time spent on pages, links clicked)
• Cookies and similar tracking technologies (see Section 6 for details)

Information from Third Parties: We may receive information about you from payment processors, identity and account-verification providers (such as Plaid), analytics providers, and other trusted third-party services.

2. Identity Verification & Account Connection (Plaid)

We use Plaid to verify your identity and to connect your financial accounts during account onboarding. By using our services, you authorize us and Plaid to access and process certain information from you and from your financial institutions, as described in Section 1 above.

The identity and financial information described above is collected and processed directly by Plaid. Plaid processes it in accordance with its own End User Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy. We encourage you to review it to understand how Plaid collects, uses, and shares your information.

3. How We Use Your Information

We use the information we collect to:

• Verify your identity and prevent fraud
• Connect and maintain your linked financial accounts
• Process transactions and manage investor inquiries
• Create and manage your account or profile
• Send receipts, confirmations, and relevant documentation
• Communicate updates, newsletters, and investment information (with your consent)
• Improve and personalize your experience on the Site
• Ensure legal compliance and prevent fraud
• Respond to your inquiries and provide support
• Analyze usage trends and measure the effectiveness of our programs

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• Identity & Account Verification: With Plaid and your selected financial institution to enable identity verification and account connection.
• Service Providers: With trusted third-party vendors who assist us in operating the Site (e.g., payment processors, email platforms, hosting providers), subject to confidentiality obligations.
• Legal Requirements: When required by law, court order, or government authority.
• Protection of Rights: To protect the rights, property, or safety of Freedom Reserves, our users, or the public.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with appropriate notice to affected users.
• With Your Consent: In any other circumstance with your explicit consent.

5. Data Retention

We retain the personal information we store for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements, in accordance with our Data Retention and Disposal Policy. When data is no longer needed, we securely delete or anonymize it. Information held by Plaid is subject to Plaid's own privacy policy and retention practices.

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our Site. These may include:

• Essential cookies – necessary for the Site to function properly
• Analytics cookies – to understand how visitors interact with the Site
• Marketing cookies – to deliver relevant content and measure campaign performance

You can control cookie preferences through your browser settings. Disabling certain cookies may affect Site functionality. We do not currently respond to "Do Not Track" signals.

7. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access – Request a copy of the personal data we hold about you
• Correction – Request correction of inaccurate or incomplete data
• Deletion – Request deletion of your personal data, subject to legal retention requirements
• Opt-Out – Unsubscribe from marketing communications at any time
• Data Portability – Request your data in a portable, machine-readable format
• Restriction / Objection – Object to or restrict certain types of processing

To exercise any of these rights, please contact us at info@freedomfund.io. You may also review and manage the information held by Plaid under Plaid's End User Privacy Policy.

California Residents (CCPA): You have additional rights under the California Consumer Privacy Act, including the right to know what personal information is collected and the right to opt out of its sale. We do not sell personal information.

EEA/UK Residents (GDPR): Our lawful basis for processing your data is typically consent, contractual necessity, or legitimate interest. You may also lodge a complaint with your local data protection authority.

8. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before sharing any personal information.

10. Children's Privacy

Our Site is not directed to individuals under the age of 13. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will promptly delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. Your continued use of the website following any changes indicates your acceptance of the updated policy. We encourage you to review this policy periodically.

12. Governing Law

This Privacy Policy is governed by the laws of the State of Utah, without regard to conflicts of law principles. Any disputes shall be resolved exclusively in the state or federal courts located in Utah.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us: