Legal Agreements

Privacy Policy

Last Update: March 17, 2023

Introduction

Every Securities LLC ("Every Securities," "we," "us," or "our"), a registered investment advisor, considers the protection of your information to be a most important priority. This Privacy Policy explains how we collect, use, share, and protect your personal information when you visit our website, use our application, or engage with any of our services (collectively, the "Services").

Our privacy policy and practices are designed to support this objective. We want you to understand what information we collect and how we use it. We would be unable to provide our Services to you without the personal data you provide us, which is why we take our responsibility to protect your personal data very seriously.

If you do not want us to collect personal data from you or share personal data with any third parties or otherwise disclose your personal data, you should not access our website, download or use our application, or use our Services.

1. Personal Data We Collect

We may collect non-public, sometimes personal, information about our clients and parties who engage our firm to participate in certain securities transactions from the following sources:

Information we receive from you on applications and other forms
Information we receive from you in order to provide certain investment banking advisory services
Information concerning your transactions with us, our affiliated persons, or others
Information from a consumer-reporting agency or vendor providing anti-money laundering or Know Your Customer compliance services

This information generally falls into the following categories:

Identifiers

Examples: First and last name, email address, mailing address, username, password, account credentials, device fingerprint
Sources: Directly from you (forms you complete, services you obtain from us)
Purposes:
- Managing your account information
- Helping you access and restore access to your account
- Preventing unauthorized access
- Sending administrative information
- Providing our investment advisory services

Customer Records

Examples: Bank account details, bank routing and account numbers, social security numbers, government-issued identification, credit information, investment objectives and history
Sources: Directly from you
Purposes:
- Verifying your identity to comply with anti-money laundering laws
- Processing transactions
- Complying with applicable securities regulations and consumer protection laws
- Providing our investment advisory services

Internet Activity Information

Examples: IP address, device ID number, browsing history, interaction with our website/application
Sources: Indirectly from your activity on our platforms
Purposes:
- Analytics and performance monitoring
- Security monitoring
- Service improvement

2. How We Use Your Personal Data

We use your personal data for the following purposes:

Providing Our Services: To deliver the services you've requested, process transactions, and maintain your account
Communication: To respond to your inquiries, provide customer support, and send important notices
Security: To verify your identity, protect against fraudulent or unauthorized activity
Improvement: To analyze usage patterns, troubleshoot issues, and enhance our Services
Marketing: To inform you about products, services, or promotions that may interest you (subject to your preferences)
Legal Compliance: To fulfill our legal obligations and respond to legitimate requests from authorities

3. Information Sharing Practices

We do not disclose any non-public information about you to anyone, except as permitted or required by law.

We restrict access to non-public personal information about you to those employees, affiliated persons and registered representatives who need to have access to such information in order to provide securities related services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information.

In limited circumstances permitted by law, we may share your personal data with:

Service Providers

Third-party vendors, consultants, contractors, and other service providers who help us provide the Services and who need access to such information to do their work
Examples include identity verification services, cloud hosting providers, and customer support tools
All sharing is conducted under appropriate data protection agreements

Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your personal data may be transferred as part of that transaction
The acquiring company would continue to be bound by this Privacy Policy until it is changed

Legal Requirements

To comply with applicable laws and regulatory requirements (including SEC and FINRA regulations)
To respond to subpoenas, court orders, or legal process
To protect our rights, privacy, safety, or property
To detect, prevent, or address fraud, security or technical issues

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

Authenticate users and maintain your login sessions
Remember your preferences and settings
Understand how you navigate through our website
Analyze the performance of our website and services
Deliver relevant advertising
Prevent fraud and enhance security

You can manage cookie preferences through your browser settings, though blocking certain cookies may impact your experience and the functionality of our Services.

5. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal data:

For California Residents (CCPA Rights)

Right to Know: Request what personal information we've collected, used, disclosed, or sold
Right to Delete: Request deletion of personal information we've collected
Right to Opt-Out: Opt-out of the sale of your personal information (note: we do not currently sell personal information)
Right to Non-Discrimination: Receive equal service and pricing even if you exercise your privacy rights

For All Users

Access: Request access to your personal data
Correction: Request correction of inaccurate data
Restriction: Request restriction of processing in certain circumstances
Objection: Object to processing of your personal data
Data Portability: Request transfer of your data to you or a third party

To exercise any of these rights, please contact us at [your privacy email]. We may need to verify your identity before responding to your request.

6. How We Protect Your Data

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of sensitive information
Secure access controls
Regular security assessments
Employee training on data protection
Contractual safeguards with third-party processors

However, no method of transmission over the Internet or electronic storage is 100% secure, so we cannot guarantee absolute security.

7. Data Retention

We retain personal data only for as long as necessary to:

Fulfill the purposes outlined in this Privacy Policy
Comply with legal obligations
Resolve disputes
Enforce our agreements

When personal data is no longer needed, we will securely delete or anonymize it.

8. Third-Party Links

Our website and application may contain links to third-party websites or services that are not owned or controlled by us. This Privacy Policy only applies to our Services. We have no control over and assume no responsibility for the privacy practices of any third-party sites or services.

9. Children's Privacy

Our Services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children. If we learn we have collected personal information from a child under 16, we will delete that information as quickly as possible. If you believe a child under 16 has provided us with personal information, please contact us.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The revised Privacy Policy will be effective as of the updated date at the top of this page. We encourage you to review this Privacy Policy periodically.

11. Contact Us

If you have any questions regarding this policy or our data practices, please contact us:

Every Securities LLC Phone: (650) 719-1492 Email: support@Everysecurities.io

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2024 Every, Inc.

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*Every is not a bank. Banking services provided by Thread Bank, Member FDIC. The Every Visa Business Debit Card is issued by Thread Bank, pursuant to a license from Visa U.S.A. Inc. and may be used anywhere Visa cards are accepted.

For Every customers with deposit accounts on Thread Bank, your deposits qualify for up to a maximum of $2,500,000 in FDIC insurance coverage when placed at program banks in the Thread Bank deposit sweep program. Your deposits at each program bank become eligible for FDIC insurance up to $250,000, inclusive of any other deposits you may already hold at the bank in the same ownership capacity. You can access the terms and conditions of the sweep program at go.thread.bank/sweepdisclosure and a list of program banks at go.thread.bank/programbanks. Please contact customerservice@thread.bank with questions on the sweep program.”

**Terms and conditions apply to the Cashback rewards program. Cashback earned will be credited to your account daily. ATM transactions, the purchase of money orders or cash equivalents, and account funding made with your debit card are not eligible for Cashback. Please refer to the Rewards Terms and Conditions for more details. No minimum opening deposit or minimum balance required.
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***Your deposits qualify for up to $3,000,000 in FDIC insurance coverage when placed at program banks in the Thread Bank deposit sweep program. Your deposits at each program bank become eligible for FDIC insurance up to $250,000, inclusive of any other deposits you may already hold at the bank in the same ownership capacity. You can access the terms and conditions of the sweep program at https://go.thread.bank/sweepdisclosure and a list of program banks at https://go.thread.bank/programbanks. Please contact customerservice@thread.bank with questions regarding the sweep program.

[1]Yield is an annualized 4-week T-bill rate when held to maturity as of [08/21/24] [date must be within the last 7 days] . The rate shown is subject to price fluctuation and is net of fees. T-bills are purchased at a discount to par (par= $1,000), with the price being subject to market fluctuation. The amount of T-Bills available at a particular yield will depend upon the sellers’ offer size; any remaining cash balance after the purchase may not earn the same yield. In general the bond market is volatile, and fixed income securities carry interest rate risk. Fixed income securities are subject to increased loss of principal during periods of rising interest rates. Fixed income securities also carry other risks, including inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties.

[2]Yield as of [08/21/24]. The SEC yield for a money market fund is calculated by annualizing its daily income distributions for the previous 7 days. You should consider the investment objectives, risks, charges, and expenses of a money market fund carefully before investing. This and other information is found in the fund’s prospectus. Please read the prospectus before investing. An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although a money market fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Yields fluctuate and past performance is no guarantee of future results.

[3] Atomic Invest LLC (“Atomic”), through a clearing relationship with Pershing LLC (“Pershing”) offers a cash sweep program. Funds in transit to or from Program Banks are generally not FDIC-insured. The Sweep Program is administered by Pershing, LLC. Deposits at each Program Bank are insured by the FDIC up to $250,000 for each insurable capacity. Based on eligibility criteria, the two FDIC-insured programs (“Bank Deposit Programs”) offered are 1) Dreyfus Insured Deposits (DIDI) and 2) Liquid Insured Deposits. Funds deposited into each sweep program, in aggregate, are eligible for up to $2,500,000 of FDIC insurance. The sweep programs can be configured so that once the funds reach one or more Program Banks (up to $250,000 for each insurable capacity at up to ten Program Banks), then the next Bank Deposit Program is initiated. Although certain types of accounts, such as trust accounts may be eligible for additional FDIC insurance based on the number of beneficiaries, funds will be allocated to each Program Bank in such a way that provides up to $250,000 of FDIC insurance for individual accounts and $250,000 of FDIC insurance for trust and other corporate account types, in each case per Program Bank. If clients elect to exclude one or more Program Banks from receiving deposits the amount of FDIC insurance available through the Atomic Invest account may be lower. Clients are responsible for monitoring their total assets at each Program Bank, including existing deposits held at Program Banks outside of the Atomic Invest account, to ensure FDIC insurance limits are not exceeded, which could result in some funds being uninsured. For more information on FDIC insurance please visit www.FDIC.gov. Deposits held in Program Banks are not protected by SIPC. For more information see Pershing’s Terms and Conditions and the Atomic Invest Form ADV Part 2A.

Every, Inc. has an engagement with Atomic Invest, LLC (“Atomic Invest”), an SEC-registered investment adviser, to bring you the opportunity to open an investment advisory account. Investment advisory services are provided by Atomic Invest. Companies which are engaged by Atomic Invest receive compensation of 0% to 0.85% annualized, payable monthly, based upon assets under management for each referred client who establishes an account with Atomic Invest (i.e., exact payment will differ). Atomic Invest also shares a percentage of compensation received from margin interest and free cash interest earned by customers with Every, Inc.. Every, Inc. is not a client of Atomic Invest, but our engagement with Atomic invest gives us an incentive to refer you to Atomic Invest instead of another investment adviser. This conflict of interest affects our ability to provide you with unbiased, objective information about the services of Atomic Invest. This could mean that the services of another investment adviser with whom we are not engaged could be more appropriate for you than Atomic invest. Neither Atomic Invest nor Atomic Brokerage, LLC (FINRA registered broker-dealer and member of SIPC), nor any of their affiliates is a bank. Investments in securities are Not FDIC insured, Not Bank Guaranteed, and May Lose Value. Investing involves risk, including the possible loss of principal.

Payment services for Every, Inc. are provided by The Currency Cloud Limited. Registered in England No. 06323311. Registered Office: Stewardship Building 1st Floor, 12 Steward Street London E1 6FQ. The Currency Cloud Limited is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 for the issuing of electronic money (FRN: 900199)
International payment services in the United States are provided by Visa Global Services Inc. (VGSI), a licensed money transmitter (NMLS ID 181032) in the states listed here. VGSI is licensed as a money transmitter by the New York Department of Financial Services. Mailing address: 900 Metro Center Blvd, Mailstop 1Z, Foster City, CA 94404. VGSI is also a registered Money Services Business (“MSB”) with FinCEN and a registered Foreign MSB with FINTRAC. For live customer support contact VGSI at (888) 733-0041

Before investing, consider your investment objectives and the fees and expenses charged by Atomic Invest and/or Atomic Brokerage. Advisory services through Atomic Invest are designed to assist clients in achieving a favorable outcome in their investment portfolio. They are not intended to provide tax advice or financial planning with respect to every aspect of a client’s financial situation and do not include investments that clients may hold outside of Atomic Invest. For more details about Atomic Invest and/or Atomic Brokerage, please see the Form CRS, Form ADV Part 2A, the Privacy Policy, and other disclosures. Custodial and clearing services are provided to Atomic Invest and Atomic Brokerage by Pershing LLC.