Privacy Policy

1. Introduction

This Privacy Policy describes how Collective Liquidity, Inc. and its affiliates (together, "Collective," "we," "us," or "our") collect, use, and share information when you use the Collective Compass website at collectivecompass.ai, the Compass AI assistant, the Compass Advisor Portal (the "Advisor Portal"), and any related services (collectively, the "Services").

By using the Services, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree, please do not use the Services.

2. Who This Policy Covers

We serve several types of users, and the information we collect differs by user type:

• Employees and individual users who interact with the Compass AI assistant on one of our websites, with or without registering for an account.
• Financial advisors who register for and use the Compass Advisor Portal.
• Wealth management firms, RIAs, and software platforms that inquire about licensing Compass or schedule a demo.
• Liquidity and product providers that provide product information to Compass and participate in the Compass network.

3. Information We Collect

3.1 Information You Provide Directly

Conversations with the Compass AI. When you chat with Compass, you may share information and documents about your employer, equity holdings (such as stock options, RSUs, and shares), vesting schedules, financial circumstances, tax situation, financial goals, and financial products you are considering. Unregistered users may use the AI without creating an account. If you register for an account, we retain your conversation history and the information and documents you have shared so the AI can remember them across sessions.

Account and registration information. When you create an account, we collect your name, email address, and password. Financial advisors must register with a verified work email address and answer brief onboarding survey questions.

Advisor client information. If you are a financial advisor, you may enter information about your clients into the Advisor Portal, including their financial circumstances, holdings, objectives, and documents. You are responsible for ensuring you have the legal right and any necessary client consents to share that information with us (see Section 7).

Payment information. If you purchase Compass credits, payment is processed by our third-party payment processor. We do not store full payment card numbers on our systems; we retain limited transaction records (such as purchase amount, date, and credit balance).

Lead and demo request information. If you request a demo on behalf of a firm or platform, we collect your name, email, firm name, and survey responses, and we may collect scheduling information when you book a meeting.

Communications. We collect information you provide when you contact us, respond to surveys, or participate in promotions (such as event-based credit promotions).

3.2 Information Collected Automatically

When you use the Services, we automatically collect:

• Usage data, such as pages viewed, features used, queries submitted, credit consumption, session duration, and interactions with the AI.
• Device and log data, such as IP address, browser type, operating system, device identifiers, referring URLs, and timestamps.
• Cookies and similar technologies, as described in Section 8.

3.3 Information from Third Parties

We may receive information about you from:

• Verification sources, used to confirm that advisor registrants are licensed or practicing financial professionals.
• Liquidity and product providers, who may confirm whether a referral resulted in a transaction.
• Business partners and publicly available sources, including professional directories and regulatory databases (such as FINRA BrokerCheck / SEC IAPD).

4. How We Use Information

We use the information we collect to:

• Provide, operate, and improve the Services, including generating AI responses, financial planning analyses, and product recommendations based on the information you share.
• Create and manage accounts, verify advisor identity and professional status, and administer credits, subscriptions, and promotions.
• Connect you with liquidity and product providers. A core function of Compass is recommending third-party products and, where you choose, initiating transactions and delivering your information to a provider as a referral (see Section 5.1).
• Process payments and maintain transaction records.
• Communicate with you about the Services, including account notifications, approval confirmations, credit balances, and (with your consent where required) marketing communications.
• Monitor, analyze, and improve the performance, safety, and accuracy of the AI and the Services.
• Detect, prevent, and address fraud, abuse, security incidents, and violations of our terms.
• Comply with legal, regulatory, and contractual obligations.

5. How We Share Information

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

5.1 Liquidity and Product Providers (Referrals)

When you engage Collective Execution Services, we share with potential providers of the product or service you select in your execution services request only the information reasonably necessary for the provider to propose indicative terms. This may include your or your clients' equity details and other relevant financial information, but Collective will not reveal your identity or your clients' identities to any product or service provider without your consent. Collective may receive referral fees from product and service providers.

5.2 AI and Technology Service Providers

Compass is powered in part by third-party large language model (LLM) providers. Your queries and relevant context may be transmitted to these providers to generate responses. Our agreements with LLM providers prohibit their use of your data to train their models. We also use service providers for hosting, analytics, payment processing, email delivery, scheduling, and customer support, each of which processes information only as needed to perform services for us.

5.3 SaaS Platform Partners

If you access Compass through a third-party wealth management platform that has licensed Compass as a sub-agent, that platform's own privacy policy governs its collection and use of your information. We share with the platform only the information necessary to deliver the integrated service and usage data needed for billing.

5.4 Corporate and Legal

We may share information: among our affiliates and subsidiaries; in connection with a merger, financing, acquisition, or sale of assets (in which case we will require the successor to honor this policy or notify you of changes); to comply with law, regulation, subpoena, or legal process; to enforce our terms; or to protect the rights, property, or safety of Collective, our users, or others.

5.5 Aggregated and De-Identified Data

We may use and share aggregated or de-identified information - such as anonymized secondary-market trading insights, product-term coverage, and demand trends - that cannot reasonably be used to identify you. This data helps power Compass's market intelligence for all users.

6. Important Notes About the AI

• Compass provides informational and planning tools. Compass is not a substitute for personalized advice from a licensed financial, tax, or legal professional, and outputs may contain errors. See our Terms of Service.
• Please do not share more sensitive information than necessary. In particular, do not share government ID numbers, full account numbers, or passwords in chat unless a specific, secure transaction workflow requests them.
• If you use Compass without registering, your conversation is not linked to a persistent account, but it may be retained for a limited period for security, quality, and abuse-prevention purposes.

7. Advisors' Responsibilities for Client Data

If you are a financial advisor and you input information about your clients into Compass, you represent that you have obtained all consents and have the legal authority required to share that information with us and with providers you engage through Compass. With respect to advisor-entered client data, we act as a service provider/processor to you, and we use that data only to provide the Services to you, consistent with this policy and our agreement with you or your firm.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to keep you signed in, remember preferences, measure usage, and improve the Services. We use:

• Essential cookies required for the Services to function (login, security, credit tracking).
• Analytics cookies to understand how users interact with the Services.
• Marketing cookies used to measure and improve the effectiveness of our marketing campaigns.

You can manage cookies through your browser settings. Where required by law, we will request your consent before setting non-essential cookies.

9. Data Retention

We retain personal information for as long as needed to provide the Services, comply with legal and regulatory obligations (including financial-services recordkeeping requirements), resolve disputes, and enforce agreements. Registered users' conversation histories are retained while the account is active. You may request deletion as described in Section 11; note that we may retain certain records where required by law (for example, transaction and referral records).

10. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, and monitoring. No system is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and regulators as required by law.

11. Your Privacy Rights

Depending on where you live, you may have rights to:

• Access / know the personal information we hold about you.
• Correct inaccurate personal information.
• Delete your personal information, subject to legal exceptions.
• Portability - receive a copy of your information in a usable format.
• Opt out of targeted advertising or "sharing"/"selling" as defined by applicable law.
• Limit use of sensitive personal information where applicable.
• Non-discrimination for exercising your rights.

California residents: You may exercise rights under the California Consumer Privacy Act (as amended by the CPRA) by contacting us as described below. We will verify your identity before fulfilling requests and respond within the timeframes required by law. You may designate an authorized agent to make requests on your behalf.

Other U.S. states: Residents of states with comprehensive privacy laws (including Colorado, Connecticut, Virginia, Texas, Utah, Oregon, etc.) may have similar rights, including the right to appeal a denied request.

To exercise any of these rights, contact us at privacy@collectivecompass.ai.

12. Marketing Communications

You may opt out of marketing emails by using the unsubscribe link in any marketing message or by contacting us. We will continue to send transactional and account-related messages (such as approval notifications and credit-balance alerts) as needed to operate the Services.

13. Children's Privacy

The Services are intended for adults and are not directed to anyone under 18. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, contact us and we will delete it.

14. International Users

The Services are operated from the United States and are intended for users in the United States. If you access the Services from outside the U.S., you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those in your jurisdiction.

15. Third-Party Links and Services

The Services may contain links to third-party websites, providers, and scheduling tools. This Privacy Policy does not apply to those third parties, and we encourage you to review their privacy policies.

16. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy with a new "Last Updated" date and, where appropriate, by email or in-product notice. Your continued use of the Services after changes take effect constitutes acceptance of the updated policy.

17. Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at: