2021/10/06

Feather Finance Inc. -- Privacy Policy

At Feather Finance, we understand that confidentiality and security of the personal information ("Personal Information") that you share with us is important. Feather Finance Inc. (“Feather Finance”, “FF”, "we," "us" or "our"), is committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be clients, employees, agents, job applicants or others inside or outside of FF. That is why we have developed specific policies and practices designed to protect the privacy of your Personal Information. By opening an account at FF or by utilizing the services available through FF, you have consented to the collection and use of your Personal Information in accordance with this privacy policy ("Privacy Policy" or "Policy"). We encourage you to read this Privacy Policy carefully.

This Policy is based on the privacy and data protection principles common to the countries in which we operate. This Policy is intended to summarize FF's data protection practices generally and to advise our clients, prospective clients, job applicants, website visitors and other third parties about FF's privacy policies that may be applicable to them.

This Policy is specifically addressed to those who provide Personal Information to FF or who visit or use FF's websites, portfolio management software application and social media sites.

FF collects and processes Personal Information from you. This may include, among other things, information provided during the FF account opening process or during use of any of FF's website applications (for example, your name, email address, investment account data, etc.).

For what purposes will we use your Personal Information?

We may use your Personal Information for the following purposes ("Permitted Purposes"):

• To provide services to you in accordance with any agreement(s) you or your organisation may have with us, for our own administrative, record-keeping and compliance procedures;
• To provide you or your organisation with our portfolio management system;
• To pursue legitimate interests, including to carry out, monitor and analyze our business or operations including the activities set out in this Privacy Policy;
• To enforce or apply any agreement and/or to protect our (or others') property or rights and to defend any potential claim;
• To respond to requests for information from you and to follow up with you afterwards to see if we can provide any further assistance;
• To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
• To conduct monitoring by us using various methods, including: (i) the use of "intelligent" automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;
• For statistical purposes and for market research and product analysis and to develop and improve our products and services;
• To comply with applicable laws in any country.

Depending on which of the above Permitted Purposes we use your Personal Information for, we may process your Personal Information on one or more of the following legal grounds:

• Because processing is necessary for the performance of your instruction;
• Because processing is necessary for the purposes of our legitimate interest or those of any third party recipients that receive your Personal Information, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

In addition, the processing may be based on your consent where we have expressly sought and you have expressly given that to us.

Who we share your Personal Information with, and in what circumstances

We may share your Personal Information in the following circumstances:

• Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process.
• FF does not share your Personal Information under any other circumstances with any other third party.
• You may authorize partner Financial Institutions (e.g. Securities Brokers) to share your brokerage account data with FF via OAuth. If you choose to do so, we will connect directly with these Financial Institutions and request only the data necessary to provide you with the functionality of our portfolio management system. The Personal Information shared with FF in such a way is protected by the terms of this Privacy Policy (i.e. FF will not share it with any third party, unless required by courts/law enforcement authorities/regulators, as stated above).
• We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so, when we are allowed or required by applicable law or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities

Updating your Personal Information

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know (https://featherfinance.com/#about for contact details).

Updates to this Privacy Policy

This Privacy Policy was last updated on 6 October 2021. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.