Privacy Policy

3Nickels powered by GuidedChoice

OVERVIEW GuidedChoice (“we” or “us”) operates its websites, including our GuidedChoice
and 3Nickels branded advice tools, i.e., the GuidedChoice Advisory Service and 3Nickels app, for the benefit of our customers and business partners
(“customers,” “users” or “you”). This Privacy Policy describes our practices in connection with
information that we collect when you visit any of our websites.

GENERAL GuidedChoice values your privacy. As a GuidedChoice user, be assured that your
privacy is protected. Information obtained directly from our users, your plan sponsor, and/or
plan record keeper is used only for the stated purpose. Information that GuidedChoice
collects and maintains will not be released to any party outside of GuidedChoice except as
otherwise disclosed in this Policy.

TECHNOLOGY We help protect against unauthorized access and alteration to customer data
through the use of malware detection and prevention, firewalls, and other industry-standard
technologies. GuidedChoice encrypts sensitive information transmitted online and uses
advanced technologies for information backup and recovery.

EMPLOYEE TRAINING Only authorized personnel have access to confidential information.
We require our employees to have information security training and implement these
practices every day.

OBTAINING AND HANDLING YOUR CONSENT By using our websites or submitting
personal information to us via your record keeper, plan sponsor, manual input, and/or
electronic updates through account aggregation services, you agree that we may collect your
personal information and you consent to the use, disclosure, and transfer of your personal
information in accordance with this Policy and as permitted or required by law. If you do not
agree with this Policy, please do not use our websites, provide us with your personal
information, or otherwise grant your consent.

You may refuse consent to our collection, use, and disclosure of your personal information,
subject to legal and contractual requirements and reasonable notice. You may withdraw or
revoke your consent to further collection, use, and disclosure of your personal information
for certain of the purposes identified herein.

There are instances where we may collect, use, or disclose your personal information
without your consent. For example, we may use or disclose your personal information to
comply with a subpoena or court order or under applicable law.

WHAT INFORMATION GUIDEDCHOICE COLLECTS GuidedChoice may capture the following
information about users of our services:

Categories of Personal Information	Specific Personal Information and Their Source		Retention Period
Identifiers	Information collected directly from user, your plan sponsor, and/or plan record keeper: Name Address Phone Email address Date of birth Gender Marital status Tax filing status* State where you file your tax return Retirement age Spouse’s name Spouse’s gender Spouse’s retirement age Dependent’s name Dependent’s birth year Eligibility for HSA* Self-employment status* *3Nickels only		In cases where investment advice has been provided, by law we must keep record of that advice and who it was for, as well as the information used to determine it. Any other data collected will either be deleted or obfuscated so that it cannot be associated with a particular user.
Financial information (as described in CA Code §1798.80)	Information collected directly from user, your plan sponsor, plan record keeper, and/or account aggregation: Your annual salary Spouse’s annual salary Other financial information, e.g., investment balances, pension information, contributions to retirement plans
Professional or employment-related information	Information collected directly from user, your plan sponsor, and/or plan record keeper: Company name Company information
Internet/electronic activity	User status when logged in to GuidedChoice-branded or 3Nickels-branded account	Website cookies

HOW GUIDEDCHOICE USES THE INFORMATION IT COLLECTS This Privacy Policy describes
how GuidedChoice treats information we receive from you when you use our websites and
mobile apps.

HOW DO WE USE YOUR INFORMATION? We may use the information we collect from
you for a variety of reasons related to our business operations and as set forth in this
Policy. Examples of ways that we may use such information include the following:

• Providing financial advice and guidance,
• Responding to your requests,
• Communicating with you,
• Contacting you at a telephone number you have given us to in order to respond
  to a service request,
• Tracking our visitors’ use of our websites,
• Improving the content, appearance, and utility of our websites,
• Compliance, audits, and providing assistance to law enforcement, and
• Completing a corporate transaction, such as a merger, sale, joint venture, or
  disposition of all or any portion of our business, assets, or stock.

HOW DO WE SHARE YOUR INFORMATION? GuidedChoice is committed to protecting
the personal information that our customers provide to us. The data you send to or
enter into a GuidedChoice or 3Nickels website is considered your confidential and
proprietary information. It is our policy to respect the privacy of our customers, and for
this reason we do not sell, reveal, or share any of your personal information with any
third parties, including your own employer. We will not monitor, edit, or disclose the
contents of your data except to our service providers for our business purposes or if
required to do so by law or in the good faith belief that such action is necessary to:

1. Conform to the law or comply with legal process served on GuidedChoice,
2. Protect and defend the rights or property of GuidedChoice, or
3. Act under exigent circumstances to protect the personal safety of our customers
   or the public.

DO WE MONITOR WHO USES OUR WEBSITE? Each time a user visits our website, our
server collects certain use and navigation information. This information is aggregated
and analyzed to tell us when and how the website is used and navigated, including the
number, frequency, and duration of visits to each web page. It also helps to inform us of
any performance-related issues we have so that we can correct them to provide you with
a more efficient website.

WHAT ARE “COOKIES” AND HOW DO WE USE THEM? Cookies are small files that are
stored by your browser on your computer’s hard drive while accessing the Internet.
Server programs that provide information back to the website then read these files.
Most companies like ours make use of browser cookies. Once you become a user of our
website, we may use cookies occasionally to store some information on your computer,
which we use only for the purpose of authentication and session maintenance. Our
cookies do not contain any personal information about you; they enable us to provide
you system access of the web pages. The cookies will not enable third parties to access
any of the information stored on your computer. Most web browsers are set to accept
cookies automatically, but usually you can either change the browser preferences to
warn when a cookie is about to be written, or to not accept them at all. Parts of our
website will function without cookies, but cookies will be required to use our web-based
and mobile advice tools and services.

RETENTION OF YOUR PERSONAL INFORMATION The personal information that you
provide will be retained by us for a period necessary for the purpose in question or in
accordance with applicable laws.

SECURITY We seek to use reasonable organizational, technical, and administrative
measures to protect Personal Information within our organization. Unfortunately, no
data transmission or storage system can be guaranteed to be 100% secure. If you have
reason to believe that your interaction with us is no longer secure, for example, if you
feel that the security of your account has been compromised, please notify us
immediately in accordance with the “Contact Us” section below.

CHOICE AND OPT-OUT Subject to reasonable notice, you may withdraw your consent to
certain of the purposes identified herein at any time, unless the personal information is
necessary for us to fulfill our legal requirements or similar obligations. To withdraw your
consent, please contact us at the address below and advise us of what personal
information you no longer wish us to use.

If you withdraw or revoke your consent, you acknowledge that we may not be able to
provide you or continue to provide you with certain services or information which may
be of value to you. In the event of changes or opt-out requests, we may retain your personal information for reasonable purposes, for example, in connection with your past
transactions.

Please note, to identify you, we may need to ask you for additional information in order
to be able to fulfill your opt-out request, and that applicable laws may contain
restrictions and other provisions that relate to your rights above.

CALIFORNIA PRIVACY RIGHTS AND CHOICES The California Consumer Privacy Act of 2018
(the “CCPA”) and the California Privacy Rights Act 2023 (the “CPRA”) provides California
residents with specific rights regarding the collection and storage of their personal
information. This section describes how these rights apply to you if you are a California
resident.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS You have the
right to request that GuidedChoice disclose the following information to you about our
collection and use of your personal information over the past twelve (12) months. Once
we have received a request from you, we may ask you to provide certain information to
identify you and verify your request. Upon verification, we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you
   (e.g., use of cookies, third party, etc.).
3. The specific pieces of personal information we collected about you.
4. Our business or commercial purpose for collecting that personal information.
5. We do not sell personal information; however, if we disclose your information to
   a third party, we will provide to you the categories of third parties with whom we
   share personal information and the categories of information that we share with
   each third-party recipient.

DELETION REQUEST RIGHTS You have the right to request that GuidedChoice delete or
correct any of the personal information collected from you and retained by us, subject to
certain exceptions. Once your request is verified and we have determined that we are
required to delete that data in accordance with applicable law, we will delete and direct
our service providers to delete your personal information from our records. Your
request to delete personal information collected may be denied if it is necessary for us
to retain your information under one or more of the exceptions listed in the CCPA/CPRA.

CORRECTION REQUEST RIGHTS You also have the right to ask that GuidedChoice
correct the personal information it has about you, subject to certain exceptions. See
Exercising Your Rights below.

RIGHT TO OPT-OUT OF THE SALE OR SHARING OF YOUR PERSONAL INFORMATION You have the right to opt-out of the sale or sharing of your personal information.
GuidedChoice, however, does not sell your data and only shares data with our service
providers for our business purposes or if required to do so by law or in the good faith
belief that such action is necessary. Please see the “How do we share your information?”
section above.

EXERCISING YOUR RIGHTS To exercise any of the rights described above, please submit
a verifiable consumer request to us by:

• Calling us at 888-675-4532
• Selecting the Delete Account button under Account Settings in the 3Nickels app
• Sending an email to [email protected] or [email protected]

Only you, or a person registered with the California Secretary of State that you authorize
to act on your behalf, may make a verifiable consumer request related to your personal
information. You may also make a verifiable consumer request on behalf of your minor
child. You may make a verifiable consumer request for access only twice within a 12-
month period. Your verifiable consumer request must:

• Provide sufficient information to allow us to reasonably verify that you are the
  person about whom we collected personal information, or a person authorized
  to act on your behalf; and
• Describe your request with sufficient detail to properly understand and respond
  to it.

We will use the personal information that you have provided in a verifiable consumer
request in order to verify your request only. We cannot respond to your request or
provide you with personal information if we cannot verify your identity or authority.

Making a verifiable consumer request does not require you to create an account with us.

RESPONSE TIMING AND FORMAT We will acknowledge your request within ten (10)
days and will process it within forty-five (45) days of receipt. If we are unable to deliver a
response to verifiable consumer requests within this timeframe, we will inform you of
the reason and estimated extension period in writing. We will deliver a written response
by mail or electronically, at your option.

Any disclosures will cover only the 12-month period preceding the verifiable consumer
request’s receipt. The response we provide will also explain the reasons we cannot
comply with a request, if applicable. Data portability requests will be issued in a format
that is readily useable. We do not charge a fee unless your request is excessive, repetitive, or manifestly unfounded. If the request warrants a reasonable fee, we will tell
you why and provide you with a cost estimate before completing your request.

ACCOUNT DELETION RIGHTS APPLIES TO ALL USERS Regardless of US state residency, all
users can request deletion of their account. The easiest method for 3Nickels’ users is to use
the app to log into your 3Nickels account and under Account Settings, select the Delete
Account button. GuidedChoice Advisory Service user accounts can be deleted by email or phone request only if (1) you have not received advice from the service or (2) we did not receive the data about you and your employer retirement plan from your employer or plan record keeper. By law, we must maintain records of advice recipients as described above; in addition, we cannot remove accounts that are part of an employer plan, as we are not the source of authority. We will acknowledge your request via the email associated with your
account within ten (10) days of receipt and process your request within forty-five (45) days.
You are also welcome to contact customer service at 888-675-4532, [email protected], or if
using a GuidedChoice-branded service, [email protected].

CONTACT US From time to time we may make changes to our Privacy Policy. As we do, we
will make them available on our website, so be sure to check for any changes.

WHAT IF I HAVE QUESTIONS OR COMMENTS? If you have any questions or comments
regarding our Privacy Policy, feel free to contact us at 888-675-4532 or [email protected].

If you wish to access or change any of the information collected by GuidedChoice, you may
do so by sending an email to [email protected] or [email protected]. When
contacting us, please be sure to provide us with your exact e-mail address, name, address
and/or telephone number(s) so that we may handle your request appropriately. In some
circumstances, we may not provide access to your personal information if, for example, it
contains the personal information of other people, if it constitutes confidential commercial
information, or if it is otherwise not the subject of an access request.

Revised 5/16/2024

© 2024 GuidedChoice®