General Privacy Policy

Effective date: February 12, 2021

This Privacy Policy (“Policy”) explains how Hennii, Inc. and its affiliates, including Hennii Payments Solutions, Inc. and Hennii Investment Advisory Services, Inc. and their respective agents, representatives, assigns, successors and service providers (collectively, “Hennii” or “we,” “us,”), collect, store, use, share and protect your personal data, which we obtain when you visit our websites, use our App or use our services. You accept this Policy and all of its terms whenever you access or use Hennii’s products, website, services, features and technologies, including Hennii’s App (the “Services”). Hence, please read this Policy carefully.

Remember that your use of our Services is at all times subject to our Terms of Service, which incorporates this Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

Our Services are intended for a U.S. audience. If you visit or use one of our Services, your information may be transferred or processed in the United States. We currently do not offer products or services to non-U.S. customers.

This Policy only applies to Hennii and not to any third-party sites or services you may access through our website, our App, or by using any of our Services and so does not apply to information submitted or collected by websites maintained by other companies or organizations to which we may link or who may link to us. Hennii is not responsible for the actions and privacy policies of third-party websites.

This Policy covers how we treat “personal data” that we gather when you access or use our Services. “Personal data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. We may create aggregated, de-identified or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular member. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you. Such aggregated, de-identified or anonymized data is not considered personal data.

In this Policy, we cover:

● Personal Data We Collect

● How We Collect Personal Data

● How We Use Your Personal Data

● Who We Share Personal Data With

● Our Services are Not Intended for Children

● Your California Rights

● Your Nevada Rights

● Additional Choices

● Do Not Track

● International Data Transfers

● Third Party Links and Websites

● How Hennii Protects Your Personal Data Changes to this Policy

● Questions/Contact Us

Personal Data We Collect

We may collect, receive, and develop several categories of personal data:

Account registration information,

Such as your name, email, postal address, user name and password, telephone number and preferences when using our Services.

Information about your personal characteristics

Such as your full name, age, phone and/or cell number, date of birth, nationality, gender, signature, utility bills, citizenship, disability, military status, and photographs.

Government-issued identification

Such as your social security number or equivalent, driver’s license number, taxpayer identification number, and passport number).

Transaction information

Such as purchases of goods and services, online shopping cart information, securities and crypto-currency trading activity, account withdrawals and account balances.

Institutional information

If you are a business, information such as your company’s legal name, employer identification number (or comparable number issued by a government), information on beneficial owners and proof of legal formation (e.g., articles of incorporation).

Financial information

Such as your bank account information, including account and routing numbers, tax information; credit and debit card information, credit history, and credit scores.

Employment-related information

Such as your job title and salary information.

Other information you may provide

Such as information you provide when you contact us with questions, feedback, survey responses, participation in contests, promotions or other prospective seller marketing forms or devices, suggestions for improvements of our services or products, referrals, or otherwise communicate with us.

Internet activity information

Such as your IP address, geolocation data, unique device ID, browser type and language, operating system, information about how you interact with our Services, including your access time, “log-in” and “log-out” information, browser type and language, and information collected via cookies and similar technologies (described below), including pages visited on our website, referring and exit pages, and the dates and times of the visits.

Personal data

You affirmatively disclose to us in connection with your interactions with us, including through your use of our Services.

How We Collect Personal Data

We collect and obtain the personal data described below from the following categories of sources:

From you

We collect information that you provide to us when you open an account or provide account information, contact us, initiate a transaction, or use our Services.

From your device

  • Overview of information we collect from your device.
    We, along with our advertising/analytics partners and service providers (who deliver services on our behalf), may set cookies, web beacons, pixels, tags, scripts, and software development kits (SDKs) on your browser or device when you visit our website in order to remember user preferences, analyze trends and site performance, administer the site, track users’ movements and behavior around the site, target users with advertisements, measure advertising effectiveness, and prevent fraud.
  • “Cookies.”
    Are small text files that are placed on your device by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive. Note that this Policy covers only our use of Cookies and does not include use of Cookies by such third parties.
  • “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs)
    Are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
  • Information Sent By Your Mobile Device.
    We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
  • Geo Location Information.
    When you use our App or access our Services via our website, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
  • Information Relating to Your Use of Our Services.
    Our servers automatically record certain information about how our users (each, a “User”) use our Services (we refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used. We may use third party data collection tools such as those offered by Snowflake to provide us with analytics data regarding Users’ interactions with our Services. You may opt-out of Snowflake’s automatic retention of data collected while using the Services by visiting https://www.snowflake.com/privacy-policy/.

● From other sources

Including the following:

  • Public databases and ID verification partners.
    We obtain information about you from public databases and ID verification partners to verify your identity in accordance with applicable law (e.g., anti-money laundering laws).
  • Credit, compliance and fraud information.
    We also obtain information about you from third party sources, such as credit report information, identity verification information, fraud detection processes, where relevant collection procedures, and information about any person or corporation with whom you have had, currently have, or may have a financial relationship.
  • Blockchain data.
    We may analyze public blockchain data and obtain information about your transactions from blockchain analysis providers to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms of Use, and to analyze transaction trends for research and development purposes.
  • Data append services, data brokers, and joint marketing partners.
    We receive personal data from these sources so that we can better understand which of our Services may be of interest to you.
  • Audio, electronic, visual or similar information.
    We will also collect any call recordings when you talk to customer service as well as any photo IDs and profile pictures you provide, i.e., on a driver’s license or passport.
  • External bank account information providers.
    When you use certain Services, we may collect from you, e.g., usernames, passwords, account numbers, and other account information for third-party websites and our third-party financial partners who maybe a broker-dealer like Drivewealth LLC, a bank like Coastal Bank or an insurance company like John Hancock. This information is used to obtain your account, transaction, banking information, or insurance information from the relevant financial institution on your behalf in order to display the information to you or to fulfill your requests for certain products, services, or transactions through a Service, which will include budgeting assistance, the buying and selling of securities and virtual currencies, also the buying and selling of insurance policies. By using our Services, you grant us, our third party partners like Drivewealth LLC, Coastal Bank and our partner insurance company, and our vendors, such as Unit 21, Plaid, Google or Amazon Web Services the right, power, and authority to act on your behalf to access and transmit this personal and sensitive information about you between Hennii, its third party partners, and its vendors in order for Hennii to be able to provide you with the financial services you have requested. You agree to your sensitive personal and financial information being transferred, stored, and processed by our third-party partners and vendors in accordance with their privacy policies found on their websites’, e.g., Drivewealth’s privacy policy found at: https://legal.drivewealth.com/privacy-policy.

How We Use Your Personal Data

We may use your personal data in the following ways:

To provide you with our Services.

We use your personal data to provide you with our Services. For example, in order to facilitate Financial Services, as well show you your account information, verify access to your account[s], and also keep your account information and transaction history up to date. Should you choose to buy and sell securities or virtual currencies through Hennii, we will share your personal and sensitive data with our partner broker-dealer, Drivewealth, LLC, should you decide to use the banking services available through the App, we will share your personal and sensitive with our partner bank, Coastal Bank, or should you elect to purchase insurance through the App, we will share your personal and sensitive data with our partner insurance company.

To improve our Services and run our Services.

We may use personal data to research, analyze, and understand how users access and use our Services, both on an aggregated and individualized basis, in order to help us improve our Services and develop new products. We also use personal data to operate, maintain, test, improve (including developing new products and services), enhance, update, monitor, diagnose, fix, and improve our Services.

To correspond with you.

We use personal data to provide you with customer support anytime you reach out to us with questions or issues arising from your account. We also use personal data to send customers technical alerts, updates, security notifications, and administrative communications.

Personalize your experience.

When you use our services and sites, as well other third-party sites and services. In this case, we might use tracking technologies like cookies.

For marketing purposes.

We may use your personal data to communicate with you regarding certain products, services or promotions offered by Hennii or certain third-party products and services we believe you may be interested in, provided that you have not already opted out of receiving such communications.

Send you locally relevant options.

We can only do this if you agree to let us track your location. If you do, this can help us enhance the security of our sites and services, and customize our services by sending your relevant coupons and otherwise personalizing content for you (e.g., through appropriate ads and search results).

Make it easy for you to find and connect with others.

For example, if you let us access your contacts, we can suggest connections with people you may know.

To detect, investigate, and prevent fraud and security issues.

We use your personal data as necessary to protect our company, our customers, and our business partners, including by investigating and preventing fraudulent activities, unauthorized access to the Services, and other illegal activities.

Comply with laws and regulations.

We use your personal data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to comply with anti-money laundering laws, to report to credit bureaus, and to respond to subpoenas or requests from government authorities.

Other.

Prevent, investigate, or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you. We may also use personal and sensitive data for any other purposes disclosed to you at the time your information is collected or pursuant to your consent. Should you want to link a bank account, a broker-dealer account, an account at your insurer that you hold with a U.S. financial institution (“Financial Account”) to your Hennii account, we will collect certain information from you about your Financial Account[s], such as your online login credentials, for the purposes of providing the Services to you. If you give us access to your Financial Account[s], you acknowledge and agree that we will have access to your transaction information, amount of funds, and other information about you and your Financial Account[s] that may be available through the online settings for your Financial Account[s] or otherwise through the relevant financial institution (“Financial Information”) that we require in order to provide the Services to you.

Who We Share Personal Information With

We do not “sell” personal data as most people would typically understand that term. However, we may share your personal data across our services We share your personal data with:

Service providers and third-party partners.

We share your personal data with service providers and third party partners like Drivewealth LLC or Coastal Bank that we have engaged to perform services on our behalf. This includes service providers that: conduct research and analytics; create content; provide customer, technical or operational support; conduct or support marketing (such as email or advertising platforms); host the Services; maintain databases; send or support online or mobile advertising; allow you to conduct transactions in connection with the Financial Services such as buying and selling securities and virtual currencies, paying your bills, buying insurance policies; and otherwise support or help us provide the Services. Service providers and third party partners also include payment processors, payment networks, external bank account information provider, card fulfillment vendors, mobile check deposit processing service providers, credit reporting and scoring agencies, providers of identity services, risk investigation and mitigation service providers, hosting, technology and communication providers, security and fraud prevention consultants, risk investigation and mitigation service providers, broker-dealers, insurance companies, support and customer service vendors and product fulfillment and delivery providers.

Advertising and marketing partners.

We share your personal data with other third parties, including advertising/analytics partners who enable the delivery of interest-based advertising to users, as well as vendors that provide specific services we do not, e.g., the purchase and sale of securities or virtual currencies.

Affiliates, investors and business partners.

We share your personal data with our affiliates, investors and business partners, e.g., merchants you order goods or services from using our App, subject to the terms of this Policy or otherwise as we disclose to you at the time the data is collected.

Law enforcement agencies, governmental authorities or regulators.

We will share your personal data when we believe it is appropriate to comply with the law, enforce or apply our conditions of use and other agreements, or protect the rights, property, or safety of the Services, our users, or others.

Mergers, acquisitions, and business transfers.

We will share your personal data if we are acquired by or enter into a merger with another company, or otherwise reorganize our business.

Credit bureaus and collection agencies.

Depending on circumstances, we may share your personal data with credit bureaus and collection agencies, as permitted by law.

Third parties.

We may also share your personal data with third parties with your consent or at your direction or for any legitimate business purpose not otherwise prohibited by law.

We may also share personal data for other reasons we may describe to you from time to time as permitted by law. We may also share your personal and sensitive data: (i) in an emergency, to protect the health and safety of users of our Services or the general public; (ii) to respond to claims that any posting or other content violates the rights of third parties; and (iii) in order to investigate, prevent, defend against, or take other action regarding violations of our terms of service governing the Services, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network or Services.

Our Services Are Not Intended for Children

We do not knowingly collect personal data from children under 18. If you are a parent or legal guardian and you think your child under 18 has given us information, you can contact us at privacy@hennii.com. Please do not attempt to register for or otherwise use the Services or send us any personal data if you are not at least 18.

Your California Rights

If you are a user of the Services and a California resident, California’s “Shine the Light” law (California Civil Code §1798.83) permits you to request and obtain from us once a year, free of charge, information regarding our disclosure of your personal data (if any) to third parties for direct marketing purposes. If this law applies to you and you would like to make such a request, please submit your request in writing in compliance with the below section (Questions/Contact Us).

Your Nevada Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to third parties who intend to license or sell that personal data. You can exercise this right by contacting us at privacy@hennii.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal data as sales are defined in Nevada Revised Statutes Chapter 603A.

Additional Choices

You have certain choices about how we use your personal data, including with respect to.

Marketing communications.

We may send you emails regarding the Services. If you do not want to receive promotional emails, you can click the unsubscribe link in any marketing email from us or contact us at privacy@hennii.com and let us know. However, there may be certain administrative emails that you will have to continue to receive in order to use the Services.

Cookies.

You also have choices with respect to the following types of cookies that we use on our website:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. This category of cookies cannot be disabled.
  • Analytical cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Advertising or targeting cookies. These cookies are used to make advertising more relevant to you and your interests. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use the cookies to build a profile of your interests and deliver relevant advertising on other websites.

In the U.S., you can opt out of tracking on our website or others for online behavioral advertising by visiting the Digital Advertising Alliance’s Consumer Choice page at http://www.aboutads.info/choices/ or the Network Advertising Initiative’s page at http://www.networkadvertising.org/choices/. You may opt out of receiving certain targeted advertising in mobile apps through participating members of the DAA by installing the AppChoices mobile app, available at https://youradchoices.com/appchoices.

You may also disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to disable all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website.

Disabling a cookie or category of cookie does not delete the cookie from your browser. You will need to do this separately within your browser. If you have disabled one or more analytical cookies, we may still use information collected from cookies prior to your disabled preference being set.

Do Not Track

When we collect tracking information on our website, we do not respond to users’ Do Not Track settings in browsers. However, you may choose to decline cookies in your browser settings on a desktop computer, or by declining tracking in your settings on a mobile device.

International Data Transfers

Hennii is headquartered in the United States and may have service providers in other countries. Your personal data may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as comprehensive as those in your jurisdiction.

Third Party Links and Websites

If you click on a link to a third-party website, you will be taken to a website we do not control. This Policy does not apply to the privacy practices of that website, which may collect information from you. Read the privacy policy of other websites carefully. We are not responsible for these third-party websites or their policies.

How Hennii Protects Your Personal Data

While we take reasonable steps to protect your personal data, nothing on the internet is 100% secure. For these reasons, we cannot guarantee that all of your personal data will never be disclosed in ways you do not expect or which are not described in this Policy.

We seek to protect your personal data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

While we protect our systems and services, we cannot guarantee the security of your information during transmission and any transmission is at your own risk. Also, you are responsible for keeping your password[s] and account information safe and private. You are also responsible for making sure you’re your Personal Data is accurate and up-to-date.

Changes to this Policy

From time to time we may change our privacy policies. This helps us stay up-to-date with changes in our business as well as the most current laws and regulations. After a new Policy is published, we’ll collect, store, use and protect your personal data as we explain in the revised Policy.

We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our website or via email. Please check our website periodically for updates. Your continued use of our Services means that you consent to the collection, use and disclosure of your personal Data as set out in the updated Policy.

Questions/Contact Us

If you have questions about the guidelines described in this Policy, please email us directly at

privacy@hennii.com or visit our Customer Service web portal or call 646-683-8907.

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