Privacy Policy

This privacy policy (the "Privacy Policy") covers the following affiliated companies: BBAE Holdings LLC, Redbridge Securities LLC, and BBAE Advisors LLC, and Redbridge Finance LLC. These entities are collectively referred to as "BBAE," “the BBAE Platform”, "affiliated companies," "we," "us," and "our" throughout this Privacy Policy.

Overview

We are committed to preserving the privacy and confidentiality of our customers' personal information. In the process of offering and providing financial products and services, we collect and maintain certain personal information about our customers. This information may originate from the details you provide on applications or other forms, from your inquiries via mail, email, or telephone, or from other interactions.

This policy details the personal information we collect, as well as how we utilize and disclose it. It also outlines the steps you can take to limit the use and sharing of your personal information. We do not reveal personal information about our customers to non-affiliated third parties, except as outlined herein.

Online Privacy

BBAE may periodically collect information from you through automated means. When you browse our site, use the iOS and Android applications, use our services, or read our emails or newsletters, we may use "cookies" or other online tracking mechanisms, including pixel tags, web beacons, clear GIFs, and device fingerprints, to provide better service, facilitate your use of the site or services, store online preferences, track usage of the site or services, tailor the marketing of business services, or enhance security. BBAE does not store login credentials used to link account information.

Some of our cookies are used for web analytics and intelligence about our site. We may also use web beacons or other technologies for similar purposes, and we may include them in marketing email messages or our newsletters to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device but may work in conjunction with cookies to monitor online activity.

By using our site or applications, you agree that we can place cookies on your device and use other online tracking mechanisms as explained in this privacy notice. You may be able to control your acceptance of cookies and similar technologies on a website, and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. If you do not accept cookies, you may experience some inconvenience in your use of some sites and online products. For instance, a website may not be able to recognize your device, and you may need to answer challenge questions or provide additional information each time you log on.

To help us protect against fraud, provide our services to you, and improve our services, we collect location data, which includes current and historical information concerning a user's geographic location, GPS location, transaction location, and IP addresses that are used in conjunction with our services. With your permission, we collect your precise location data and use that information, for example, to help protect against fraud by detecting and declining debit card transactions or account withdrawals that may occur far away from your device's location. You may decline to allow us to collect such geolocational information, in which case BBAE may not be able to provide certain features or functionalities to you.

We also may obtain information about the device you use, including the Universally Unique Identifier, the advertising identifier ("IDFA" or "AdID"), operating system and version, wireless carrier, and network type. This information is used to identify customer device issues and for marketing purposes.

By providing your mobile phone number, you expressly consent to BBAE and its authorized agents contacting you via calls or SMS messages. These communications may be facilitated by automated dialing systems or pre-recorded messages. Standard message and data rates may apply to these communications. If you wish to opt out of receiving phone or text communications, please email your request to support@bbae.com.

Interest-based Advertising

We utilize "interest-based" ads, commonly referred to as "online behavioral advertising." In partnership with ad networks and advertising providers ("Advertising Providers"), we display ads both on our behalf and for other entities on non-affiliated websites. Our Advertising Providers may employ cookies and similar technologies to gather details about your online activities over time and across third-party websites or services. This information aids in tailoring advertising to align with your interests and preferences, derived from your web browsing patterns. Some ads are personalized to be relevant to you, using the data BBAE and its Advertising Providers have collected from your site visits, both on our platform and elsewhere.

To evaluate your engagement with our platform, we use third-party analytics services, such as Google Analytics, Facebook, Singular, among others. These services help us to compile activity reports, study performance metrics, and understand mobile and internet usage related to our platform. For detailed information on these third parties and instructions for opting out of their data collection, please visit www.google.com/analytics. Please note that opting out might limit your ability to fully utilize our platform's functionality. Rest assured, all information we collect is aggregated, anonymized, and kept devoid of direct identifiers.

We respect your privacy and are dedicated to being transparent about the data we collect:

• User Consent: By interacting with our platform, you consent to our collection and use of data as outlined herein. You retain the ability to withdraw consent and opt-out of our services at any time.
• User Control: You have the right to access, correct, or request the deletion of your personal information. These actions can be completed through your account closure or by reaching out to support@bbae.com.
• Data Security: We have implemented stringent security measures to safeguard your personal data against unauthorized access and potential data breaches.
• Policy Updates: Any modifications to our advertising or data collection policies will be communicated to you via the platform.
• Contact Information: Should you have any inquiries or concerns regarding the handling of your data, please contact us at support@bbae.com.

Do Not Track (DNT) Signals

Currently, we do not recognize or respond to browser-initiated DNT signals, as there is no consistent industry standard for compliance.

Protecting Information

With regard to our internal security procedures, we restrict access to your personal and account information to those employees who "need to know" the information in order to provide products and services to you. We maintain reasonable physical, administrative, and technical safeguards to protect your personal information. We conduct regular internal audits of our business practices and procedures in order to protect your personal information.

We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Third Party Services

Disclosure to Service Providers

BBAE may disclose your personal information to nonaffiliated service providers who perform business functions on our behalf. This may include but is not limited to the marketing of our investment products and services and data processing. We utilize these nonaffiliated third-party service providers to aid in the efficient and effective delivery of our services.

There are circumstances where it may be necessary for BBAE to disclose nonpublic personal information we collect to such parties. However, we mandate these nonaffiliated service providers to agree to keep your information confidential and secure and to use it only as we authorize. Furthermore, disclosure of nonpublic information to nonaffiliated third parties is only done under circumstances that do not require an "opt-out" notice as permitted by state or federal law, such as servicing financial products or services you have authorized, resolving consumer disputes, or protecting against fraud or unauthorized transactions.

Marketing and Joint Marketing Agreements

BBAE may disclose certain personal information to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements. This information may include:

• Details received from you on applications or other forms, such as your name, address, mobile phone number, social security number, assets, and income.
• Information about your transactions with us, our affiliates, or others, such as your payment history and parties to transactions.
• Information received from a consumer reporting agency, such as your creditworthiness and credit history.

We require all joint marketers to enter into written contracts that define the appropriate use of your personal information, mandating measures to protect your information, and prohibiting unauthorized or unlawful use of your information. BBAE does not share, sell, or rent your personal information with outside marketers who may want to offer you their own products and services.

Sumsub

For identity verification purposes, we have partnered with Sum and Substance Ltd., “Sumsub”. By using our service, you consent to us sharing your personal information with Sumsub for the purpose of verifying your identity. Your information will be processed by Sumsub in accordance with their privacy policy. For more information about Sumsub and their practices, you can visit their website here.

Plaid

To securely connect your financial accounts to our services, we partner with Plaid Financial Ltd., “Plaid”. Plaid provides us with financial data without sharing your bank login credentials with us. By using Plaid, you agree to their end user privacy policy and acknowledge that we do not have access to, or store, any login credentials you enter into Plaid. For additional information about Plaid and their services, click here.

Important Information About Closing and Deleting Accounts

To close your account, you must first settle any open positions and withdraw all remaining funds. Once your account has a zero-dollar balance and no open positions, navigate to the Help Center in the app and reach out to us by phone or online chat to have your account closure request processed. Alternatively, you can email your request to support@bbae.com. After your account is closed, you will still be able to log in to the app, but no records will be accessible. You may be able to retrieve statements, tax documents, and trade confirmations by logging into www.bbae.com/docs with your app credentials. These documents, along with additional records, are retained for a period as required by regulations, but they are not kept indefinitely. Your information will be used solely for fulfilling our regulatory obligations. We strongly recommend downloading any necessary documents before you close your account.

If you wish to delete your login in addition to closing your account, please email us at support@bbae.com. After your account is deleted, you will not have the ability to log into the app or access statements, tax documents, and trade confirmations from www.bbae.com/docs. We urge you to download any documents you may require in the future before you request account deletion. If your account has been deleted and you need to request account documents, please contact us at support@bbae.com, and we will ascertain if the documents can be provided. Be aware that account documents, along with additional records, are stored for a certain period as dictated by regulations, but are not held indefinitely. Your information will only be used to comply with our regulatory requirements. Should you have any questions, please contact our customer support team at 1-800-950-5266 or support@bbae.com.

Retention of Your Information

We will retain your personal information for as long as it serves the purpose(s) for which it was initially collected, as stated in this Privacy Policy, or as subsequently authorized. We will not retain personal information indefinitely. Additionally, we will retain and use your personal information as necessary to comply with our regulatory obligations, resolve disputes, or enforce our agreements. If you are no longer a customer, we will not destroy your information unless required or permitted by law. We will continue to treat your personal information in accordance with this Privacy Policy and applicable laws.

Information connected to you that is no longer necessary and relevant for providing our services may be aggregated with other non-personal data to provide insights that are commercially valuable to BBAE, such as statistics on the use of services.

Children's Privacy

We do not knowingly collect or solicit any information from individuals under the age of 18 through our services. In the event that we learn we have inadvertently collected personal information from a child under the age of 18, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 18, please contact us at support@bbae.com.

California Privacy Rights

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your "personal information" (as defined in the California Consumer Privacy Act ("CCPA")), other than the personal information we collect in connection with providing financial products and services. However, the CCPA does not apply to all entities.

Depending on how you interact with our website and services, we may collect the following categories of personal information about you, in addition to the information we collect in connection with providing financial products and services:

• Identifiers, such as your name and contact information, IP address, and mobile device identifiers
• Internet usage information, such as browsing history, access history, and use and interaction with our website.

This information is used and disclosed for the purposes and to the categories of third parties described in the main Privacy Policy.

Your California Privacy Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or distributing your personal information; and the categories of third parties with whom we shared personal information.
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we may have about you.

We do not sell Personal Information to third parties. We do allow third parties to collect personal information through our service and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our service and elsewhere based on users' online activities over time and across different sites, services, and devices.

California law permits consumers to request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties' direct marketing purposes within the previous calendar year, along with the type of personal information disclosed. Please contact support@bbae.com for such requests.

Updates to this Privacy Policy

As required by federal law, we will notify you of our privacy policy annually. We reserve the right to modify this policy at any time. If we do change it, we will revise the "Effective Date" above and post the new policy to our website. To stay informed of our privacy practices, we recommend you review this Privacy Policy on a regular basis as you continue to use our services.

Contact Us

For questions about our Privacy Policy, or for additional copies of this notice, please email us at support@bbae.com.