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Qapital Online Privacy Policy 

Effective date: March 31, 2025 

This Privacy Policy explains how Qapital, LLC, Qapital Invest, LLC, and any other entity in the  Qapital company group (collectively, “Qapital,” “we,” “us,” or “our”) collects, uses, and discloses  personal information when you access our websites at www.qapital.com and www.wedbushnext.com, along with any other path segments or subdirectories, or our mobile  applications (the “Qapital App”) in connection with our product and service offerings  (collectively, the “Qapital Service”). It does not address our privacy practices relating to Qapital  job applicants, employees, and other personnel. 

By accessing or using any part of the Qapital Service (or by clicking to accept or agree to the  Qapital Terms and Conditions when this option is made available to you), you signify that you  have read and understood this Privacy Policy. Terms not defined herein shall have the  meanings given such terms in the Qapital Terms and Conditions. 

Financial Products or Services and Related Notices/Consents: If you apply or sign up for,  or otherwise use, a financial product or service from us, we will use and share any “nonpublic  personal information” (as such term is defined under the Gramm-Leach-Bliley Act or “GLBA”)  

that we collect from or about you in accordance with our Qapital Consumer Privacy Notice,  which offers you certain choices with respect to the collection, use, sharing, and processing of  your nonpublic personal information by financial institutions. This includes information we collect  when you access or use the Qapital Services to manage or conduct transactions. Please see  our Qapital Consumer Privacy Notice to learn how we use your “nonpublic personal information”  and your choices relating thereto.

We may need to share certain information with financial institutions and our other third-party  partners to provide portions of the Qapital Service that you elect to use. For example, if you  provide your online login information for financial accounts to us, we may disclose that to your  financial institution or its intermediary to establish a connection between your financial account  and your Qapital Accounts and thereby obtain access to your financial records. 

Similarly, if you link your Qapital Accounts to other services (such as a third-party fitness  application), we may share your personal information to provide the features you have  requested. If you apply for a financial product or service, such as a Qapital Visa® Debit Card or  Qapital Invest, we will disclose any personal information that the financial institution requires to  complete the transaction in question or as needed to meet any legal requirements.  

Note that Qapital will also have access to information in connection with the use of third parties,  including those described in the Note on Certain Third-Party Relationships below. In general, we  may share your personal information with third parties (or use information from such third  parties) when necessary to fulfill your requests for services; to complete a transaction that you  initiate; to meet the terms of any agreement that you have with us or our partners; to manage  our business; or as otherwise permitted under applicable law. 

Note on Certain Third-Party Relationships: Plaid Inc. (“Plaid”) provides account linking and  aggregation services to Qapital that enables the transfer of your personal information to and  from your third-party external financial account and your Qapital Accounts. In order to use  Plaid’s account linking and aggregation services, you will be asked to, and must, agree to  Plaid’s End User Privacy Policy (currently located at https://plaid.com/legal/#end-user-privacy policy). Further, you must expressly grant Plaid the right, power, and authority to access and  transmit your information as reasonably necessary for Plaid to provide these services to you on  Qapital’s behalf. Qapital will also have access to information about the transactions associated  with, and the cash flows into and out of, accounts linked through Plaid.

If you choose to sign up for a Qapital Visa® Debit Card, you understand that such card is issued  by Lincoln Savings Bank and you confirm acceptance of Lincoln Saving Bank’s privacy  practices which can be found at https://www.qapital.com/terms/terms-qapital-spending/ and  https://www.wedbushnext.com/terms/qapital-spending/. 

Apple Health Kit: Depending on your use of the Qapital Service, we may also collect fitness  data through Apple Health Kit. If you choose to have the Qapital Service integrate with your  Apple Health Kit, that data may be used to provide certain services, such as linking savings  

rules to your Apple Health activities. The Qapital App will only have access to the information  you choose to link in your Apple Health Kit. Please review Apple’s privacy policy for information  on how Apple Health Kit uses and shares your personal information. This Privacy Policy does  not apply to the collection and use of your information by Apple Health Kit. 

Personal Information We Collect 

The personal information we collect from, and about, you may vary depending on how you  engage with the Qapital Service and the information you provide voluntarily.  

• Information You Provide 

We may collect personal information directly from you or otherwise in connection with your use  of the Qapital Service, including: 

• Contact Information, including your name, contact details (such as a postal address and  email address), and communication preferences. 
• Inquiry Information, including information provided in messages sent through forms or  surveys, to our email addresses, or via phone. This also may include information  provided when you sign up for our newsletters.
• Testimonial Information, including your contact information along with a statement  regarding the Qapital Service. 
• Information that We Collect Automatically 

We and our third-party partners may use various technologies to automatically collect certain  information when you access or use the Qapital Service, including: 

• Device Data, including internet protocol (IP) address, operating system, device type and  version, browser type and version, browser id, the URL entered and the referring  page/campaign, date/time of visit, other user agent string data, the time spent on the  Qapital Service, and any errors that may occur during the visit to the Qapital Service.  “Device Data” may overlap with the other categories of data below. 
• Analytics Data, including the path taken to the Qapital Service, through our the Qapital  Service, and when exiting the Qapital Service, usage and activity on or in connection  with the Qapital Service (including transactions made therein, to the extent not related to  our financial products and services), metrics on how many emails we send are actually  opened and which attachments or links are opened, clicked, or viewed (such as via  pixels, as described further below). 
• Location Data, including the precise or coarse geographic location we or our third-party  providers may collect, such as via permissions within app operating system or browser  functionality. 

Advertising/Advertising Measurement Data, including data associated with your view of,  or click on, advertisements served on the Qapital Service, cookie IDs or other digital or  proprietary identifier (e.g., iOS IDFA, Google AAID) assigned to such device, and device  metadata, analytics data, and location data described above, in each case, for purposes  of serving advertising (personalized or otherwise) or facilitating advertising  measurement/attribution to better optimize or otherwise understand the effectiveness of  ad campaigns.

For information about our and our third-party partners’ use of cookies and other tracking  technologies to collect information automatically, and choices individuals may have in relation to  its collection or use, please see the “Your Choices” section below. 

• Information from Third-Party Sources 

We may receive personal information about you from third parties and combine this information  with other information we have. 

• Affiliates. We may receive personal information from other companies owned or  controlled by Qapital and other companies owning or under common ownership with  Qapital. This includes any subsidiaries (i.e., any organization we own or control) or our  parent company (i.e., any organization that owns or controls us) and any subsidiaries it  owns. 
• Service Providers and Business Partners. Our service providers that perform services on  our behalf, such as email marketing providers, and other business partners collect and  share personal information with us in connection with the facilitation of the Qapital  Service or for the advertising of such Qapital Service or other third-party services or  products that may be of interest to you. 
• Social Media and Professional Networks. When an individual interacts with us through  various social media and professional networks, such as when someone communicates  with us through LinkedIn, we may receive some information about the individual that  they permit the network to share with third parties. The data we receive may be  dependent upon an individual’s privacy settings with the network. Individuals should  always review and, if necessary, adjust their privacy settings on third-party websites and  networks before sharing information with us or the social media and professional  network platform.
• Information Providers. We may from time to time obtain information from third-party  information providers to correct or supplement other personal information we collect. For  example, we may obtain updated contact information from third-party information  providers to connect (or re-connect) with individuals. 
• Publicly Available Information. We may also collect personal information from publicly  available sources, such as government records or publicly available websites, to  supplement other personal information we collect. 

How We Use Personal Information We Collect 

We use the personal information we collect for our business purposes, including the following: 

• To provide, analyze, and improve the Qapital Service; 
• To market products and services that we believe may be of interest to you, whether  products or services that are part of the Qapital Service (e.g., new or improved products  or services) or third-party products or services, and measuring the effectiveness of such  marketing; 
• To communicate with you, such as to respond to your comments and questions, provide  customer service or feedback, troubleshoot problems, or for any other purposes in  connection with the Qapital Service; 
• For market and demographics/audience research and project planning;
• To prevent, investigate, detect, and protect against error, fraud, or other criminal activity;
• To solicit your feedback; 
• To render your personal information anonymous or pseudonymous and create  aggregated data; 
• For our internal business purposes and to enforce our Terms and Conditions;
• To comply with our legal obligations; 
• As otherwise permitted by this Privacy Policy; and
• For any other lawful, legitimate business purpose. 

How We Share Information Collected 

We may share your personal information in the following ways: 

• Affiliates. We may share the information described in this Privacy Policy within the  Qapital company group.  
• Service Providers and Business Partners. We use third-party service providers and  business partners to help us manage and improve the Qapital Service. We also use  these third parties to host or facilitate portions of the Qapital Service, target and  implement our email communications and direct mailings, manage our relationships with  the people and companies that use the Qapital Service, process payments, and assist  with market research, security, connecting to other services, troubleshooting problems,  and detecting and protecting against error, fraud, or other criminal or malicious activity. 
• Data Analytics Providers. We share information with data analytics providers who  analyze statistics and trends relating to the usage of and activity relating to the Qapital  Service. These data analytics providers produce reports and make suggestions for our  customer and business strategy based on the personal information and other information  analyzed. 
• Marketing Partners. We coordinate and share personal information with our marketing  partners (including brands, social media providers, or advertising technology companies)  to communicate with individuals about the Qapital Service or third-party products and  services, including by serving ads that may be of interest to you (e.g., ads for the Qapital  Service on third-party digital properties, ads for third-party products or services on the  Qapital Service) and to measure the effectiveness of such marketing campaigns.  
• Legal Process and Suspected Fraud. We may share or disclose information collected  through the Qapital Service when Qapital determines, in its sole discretion, that the 

disclosure of such information is necessary or authorized under the law; to comply with  applicable law or a court order, subpoena, or other legal process; to investigate, prevent,  or take action regarding illegal activities, suspected fraud, violations of our Terms and  Conditions, or situations involving threats to our property or the property or physical  safety of any person or third party; to establish, protect, or exercise our legal rights or  defend against legal claims; or to facilitate the financing, securitization, insuring, sale,  assignment, bankruptcy, or other disposal of all or part of our business or assets. 

• Sale or Merger. Information collected through the Qapital Service may be transferred to  a third party as a result of a sale, acquisition, merger, reorganization or other change of  control, reorganization, bankruptcy, or asset sale. If we sell, merge, or transfer any part  of our business, part of the sale may include your personal information. Any subsequent use of your personal information shall take place in accordance with this Privacy Policy  or other policy issued by the acquiring third party. 
• Otherwise with Consent or Direction or via Notice. We may disclose personal information  to certain other third parties or the general public with the individual’s consent or  otherwise at their direction. For example, we may obtain consent to post a quote about  the Qapital Service or an individual’s testimonial to our public website. Further, we may  disclose personal information where notice has been adequately provided as permitted  under applicable law (to the extent such notice is not provided in this Privacy Policy or  where the activity in question is not compatible with the activities discussed in this  Privacy Policy). 

Qapital may share de-identified, anonymized, or otherwise aggregated personal information in  order to use, analyze, or provide information. 

Your Choices 

Marketing Emails

You can stop receiving marketing email communications from us by clicking on the “unsubscribe  link” provided in such communications. You may not opt out of transactional or service-oriented  messages, as such messages are required to respond to your requests or to provide goods and  services. 

Account Deletion 

You may request to delete your Qapital Accounts:  

• If you selected a user experience tier on the Qapital Service that is subject to a recurring  periodic subscription fee, by clicking ’Close my account’ within the Qapital App’s  Membership Page and following the process thereafter; or  
• By requesting deletion via email to (a) support@qapital.com or  

support@wedbushnext.com (applicable to Wedbush Next Accounts) for your Goals  Account and Spending Account or (b) support@qapitalinvest.com or wedbush next@qapitalinvest.com (applicable to Wedbush Next Accounts) for your Invest Account. 

In either case, we will delete your Qapital Accounts (to the extent applicable) within a  reasonable time after receiving your request. Please note that, after such deletion, we may still  retain your personal information as reasonably necessary for legal compliance purposes, the  establishment, exercise, or defense of any actual or potential legal claims, internal  recordkeeping, or other business purposes.  

Use of Tracking Technologies 

We and our third-party providers may use tracking technologies, such as mobile advertising IDs  (e.g., iOS IDFA, Google AAID), “cookies” (i.e., small data files that are stored on an individual’s  browser), and similar technologies, such as web beacons, pixels, APIs, embedded scripts,  location-identifying technologies, and logging technologies to automatically collect personal 

information and use or disclose the personal information for the purposes described in the  sections above. For example, the Qapital Service uses Google Analytics to collect and view  reports about the traffic on our website. More information on the use of Google Analytics can be  obtained by visiting Google’s privacy policy here and Google’s currently available opt-out  options are available here. 

Certain browsers may allow an individual to: (i) change their browser settings to notify the  individual when they receive a cookie, which may let the individual choose whether or not to  accept it; (ii) disable existing cookies; or (iii) set their browser to automatically reject cookies.  Note that similar controls may exist for other tracking technologies, such as the ability to restrict  the collection of certain mobile advertising technologies under certain device settings. Please  check your device or browser settings and related documentation for more information. 

Please note that restricting the use of such technologies may negatively impact your experience  with the Qapital Service, as some features or offerings may be less personalized or may not  work as otherwise intended. Depending on the individual’s device and operating system, an  individual may not be able to delete or block all cookies or other tracking technologies as  described in this Privacy Policy. In addition, if the individual wants to reject cookies or other  tracking technologies across all browsers and devices, they may need to do so on each browser  on each device they actively use. The individual may also set their email options to prevent the  automatic downloading of images that may contain technologies that would allow us to know  whether they have accessed our email and performed certain functions with it. 

Additional Choice Relating to Third-Party Advertising  

To learn more about interest-based advertising and how you may be able to opt-out of some of  this advertising (to the extent the advertising partner or other entity participates in such industry  opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources or the  Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or 

http://www.networkadvertising.org/choices/ and you can opt-out of receiving certain interest based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices and  downloading the mobile AppChoices app.  

Please note that, when you opt out of receiving interest-based advertisements, this does not  mean you will no longer see advertisements from us or on our online services. It means that the  online ads that you do see from these self-regulatory program participants should not be based  on your interests. We are not responsible for the effectiveness of, or compliance with, any third  parties’ opt-out options or programs, or the accuracy of their statements regarding their  programs. In addition, third parties may still use cookies or other tracking technologies to collect  information about your use of our online services, including for analytics and fraud prevention as  well as any other purpose permitted under those self-regulatory programs. 

Third-Party Links 

The Qapital Service may contain links to and from third-party digital properties or tools or  services of our business partners (including advertisers and social media sites). If you follow  any of these links or otherwise utilize these tools or services, please note that these third parties  have their own privacy policies and that we disclaim all responsibility or liability for their policies.  We strongly recommend that you read their policies to understand how they collect, use, and  share information. We are not responsible for the privacy practices or other practices of a third  party. 

Information Security 

We utilize measures to help protect information under our control against loss, misuse, and  alteration. Please be aware that 100% security is not possible and that you assume the risk with  respect to any information that you provide to us.

Retention of Personal Information 

The length of time Qapital intends to retain personal information is for as long as reasonably  necessary to carry out Qapital’s business purposes for such information. Please note that we  may also need to retain your data beyond your account deletion or closure date as reasonably  required, in our discretion, by federal, state, or local law or any recordkeeping or reporting  obligations. 

Children’s Privacy 

Qapital does not knowingly collect or solicit any information from anyone under the age of 13 on  the Qapital Service. In the event that we learn we have inadvertently collected personal  information from a child under age 13, we will endeavor to promptly delete that information. If  you believe that a minor in your care has provided us with information, please contact us at  support@qapital.com. 

Updates to Privacy Policy 

If we make any material changes to our privacy practices, we will update the effective date at  the top of the Privacy Policy and you shall be bound to such changes when accessing the  Qapital Service after the Privacy Policy was updated. 

Questions Regarding Privacy Policy 

We take the privacy and security of your personal information very seriously and want to earn  and keep your trust. If you have any questions, comments, concerns, or feedback regarding this  Privacy Policy or any other privacy or security concern, please send an email to  support@qapital.com.