Privacy Policy

Effective as of March 8, 2019

This privacy policy (the “Privacy Policy”) applies to the BenjaminTM Artificial Intelligence Applications and Online Software (“Benjamin”), owned and operated by YourWela, LLC, a Georgia limited liability company (“WELA” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information Benjamin collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use. By using Benjamin, you are agreeing to the terms of this Privacy Policy. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

1. INFORMATION WE COLLECT OR RECEIVE
In the course of operating Benjamin, we will collect and/or receive the following types of information. You

authorize us to collect and/or receive such information.

a. Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, and phone number. We do not collect any Personal Information from you when you use Benjamin unless you provide us with the Personal Information voluntarily.

b. Third-party Log In. If you sign in through or on behalf of any company which you are an owner, employee, agent or representative, you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that such company would provide to us through such company’s Application Programming Interface (“API”). Such information may include, without limitation, your first and last name, company username, company profile picture, headline, unique identifier and access token, and e- mail address.

c. Geolocational Information. Certain features and functionalities of Benjamin are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of such Geolocational Information occurs only when Benjamin is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.

d. Third-Party Analytics and Integration. We may use third-party analytics services (e.g., Google Analytics) to evaluate your use of Benjamin, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to Benjamin and mobile and Internet usage. We may also use third-party services (e.g., Google Cloud and/or Google Compute Engine instances) to integrate Benjamin into your use of such third-party services for purposes of, among other things, helping you schedule meetings, organize and add notes for your meetings, send meeting invites or send one-way emails from email accounts which you create and integrate into Benjamin. These third parties may use cookies and other technologies to help analyze and provide your data to us. You consent to the processing of data about you by these providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please contact us through www.getwela.com. Please be advised that if you opt out of any such service, you may not be able to use Benjamin’s full functionality.

e. Other Information. In addition to the Personal Information and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of Benjamin; your interactions with us; and information regarding your computer and mobile devices used to access Benjamin (collectively, the “Other Information”). Such Other Information may include:

i. From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.

ii. From Your Activity. We may collect or receive information regarding:

A.IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;

B.browser type and language;

C.referring and exit pages and URLs;

D.date and time; and

E.details regarding your activity on Benjamin, such as search queries and other performance and usage data.

iii.About Your Mobile Device. We may collect or receive information regarding: A.type of mobile device;
B.advertising Identifier (“IDFA” or “AdID”);
C.operating system and version (e.g., iOS, Android or Windows);

D.carrier; and

E.network type (WiFi, 3G, 4G, LTE).

iv. From Cookies. We may use both session cookies, which expire once you close Benjamin, and persistent cookies, which stay on your devices until you delete them and other technologies to help us collect data and to enhance your experience with Benjamin. Cookies are small text files an app can use to recognize a repeat visitor to Benjamin. We may use cookies for various purposes, including to:

A.type of mobile device;
B.personalize your experience;
C.analyze which portions of Benjamin are visited and used most frequently; and D.measure and optimize advertising and promotional effectiveness.

If you do not want us to deploy cookies in Benjamin, you can opt out by setting your mobile device to reject cookies. You can still use Benjamin if you choose to disable cookies, although your ability to use some of the features may be affected.

2. THIRD-PARTY ADVERTISING
Our current Policy is not to share your Personal Information, Geolocational Information or Other Information with

third parties for any third party interest-based ad distribution. 3. HOW INFORMATION IS USED AND SHARED

a.You authorize us to use the Personal Information, Geolocational Information, and the Other Information (collectively, the “Information”) to:

i.provide and improve Benjamin; ii.provide our services;
iii.administer our promotional programs; iv.solicit your feedback; and

v.inform you about our products and services.

b.We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional

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programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law

c.In an ongoing effort to better understand our users, Benjamin, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve Benjamin and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe Benjamin and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

d.We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us (“our Affiliates”); provided however, that any of your Information shared with our Affiliates may be shared only for the sole purposes of improving your experience in using Benjamin in connection with the permissions set forth in this Section 3. We nor our Affiliates will use any of your Information to solicit your customers or clients.

e.As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

f.To the extent permitted by law, we may also disclose the Information:

i.when required by law, court order, or other government or law enforcement authority or regulatory agency; or

ii.whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

4. ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES

If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to Benjamin (e.g., requests for support).

We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

5. HOW WE PROTECT YOUR INFORMATION

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail and in selecting your passwords.

California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please contact us at www.getwela.com with “California Privacy Rights” in the subject line.

6. IMPORTANT NOTICES TO NON-U.S. RESIDENTS

Benjamin and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use Benjamin, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

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7. CHILDREN

Benjamin is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use Benjamin. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

8. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted within Benjamin. By accessing Benjamin after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

9. HOW TO CONTACT US

If you have questions about this Privacy Policy, please contact us at www.getwela.com with “Privacy Policy” in the subject line or mail us at the following address: 10 Glenlake Parkway North Tower, Suite 1000, Atlanta, Georgia, 30328.

WELA STRATEGIES PRIVACY NOTICE Wela Strategies values our customers and makes it a top priority to safeguard the confidential information of our customers. We are committed to protecting your privacy and maintaining your trust and confidence. Wela Strategies collects information about you to assist us in providing services and products to help you meet your financial goals and objectives and provide high standards of customer service. Additionally, information is obtained from you in order to help us fulfill our legal and regulatory requirements. Information collected may vary depending on the products and services requested and the scope of your engagement with us. Information Collected About You Wela Strategies collects nonpublic personal information about you from the following sources: ♦ Information provided on applications and related forms, such as name, address, telephone number, Social Security or Tax Identification number, birth date, net worth, annual income, information about your personal finances, financial information such as bank accounts, and medical information if insurance services are provided. ♦ Information about your transactions with us, such as account balances, payment history, account numbers, and account activity. ♦ Information from your employer, association, or benefit plan sponsor regarding any group products we may provide or assist in reviewing on your behalf. We do not disclose information to nonaffiliated third parties about our current or former customers, except as permitted by law. However, should for any reason our policy change, we will notify you by providing you with an amended Privacy Notice prior to making disclosure of your nonpublic information to nonaffiliated third parities that are not permitted under law. Policies and Practices to Protect Your Personal Information We train our staff to take caution in handling personal information. We restrict access to nonpublic information about you to staff that need to know such information, who assist in providing products and services to you, or who assist in the administration of the office, in order to maintain confidentiality of your information. Further, we limit staff access to information to only those who have a business or professional reason for knowing such information. Limited access is given to nonaffiliated third parties, as permitted by law, in order to execute securities transactions on your behalf, or in order to provide account maintenance or customer service on your accounts. If you close your account, cease services with us, or become an inactive customer, we will continue to adhere to the privacy policy disclosed herein, unless we notify you by providing an amended Privacy Notice. Disclosure of Personal Information 6/2001 We may disclose personal information obtained from you to financial service providers that service or provide support to your accounts, as permitted under law, such as: ♦ Securities broker/dealers. ♦ Third-party administrators and vendors hired to effect, administer, or enforce transactions or services in your accounts. We will not share information about you with nonaffiliated third parties, unless we have provided you with an updated Privacy Notice and provided you with an opportunity to approve or disapprove of the sharing of your information. Additionally, we may be required by law or regulation to disclose information to third parties such as in response to a subpeoena, to prevent fraud, to comply with rules and regulations to which we are subject, in response to inquiries from industry regulators, and in order to comply with our broker/dealer’s policies with whom our associated persons may be registered. We will affirm our Privacy Policy annually in writing, provided you maintain an ongoing relationship with us.

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