Privacy Policy

Telona LLC, a Florida limited liability company and a subsidiary of SponsorCloud LLC ("Telona," "we," "us," or "our"), is committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use and share it, and the choices you have. It applies to the Telona website at telona.co, the Telona application, and the related products and services we provide (collectively, the "Service"). Telona is a wealth and net worth tracking application, and we handle financial information about you, so please read this Policy carefully.

This Privacy Policy is incorporated into and subject to our Terms of Service at telona.co/terms. By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please do not use the Service.

1.Key Definitions

Personal Information. Information that identifies, relates to, or could reasonably be linked with you, such as your name, email address, postal address, account information, and financial information. It does not include information that has been aggregated, de-identified, or anonymized so that it can no longer reasonably be associated with you.

Financial Account Information. Information about the external financial accounts you choose to connect to the Service, including transactions, investment holdings, and liabilities, obtained on a read-only basis through our service provider Plaid.

SponsorCloud Data. Information that SponsorCloud shares with Telona at your direction when you connect Telona from the SponsorCloud investor portal, including your investment holdings, distributions, and contact information, and the addresses and employer identification numbers (EINs) of investing entities associated with your profile.

2.Information We Collect

2.1Information you provide to us

• Account and profile information, such as your name, email address, and login credentials.
• Information you enter into the Service, such as assets, liabilities, valuations, and net asset values (NAV) for private holdings and other investments that are not automatically valued.
• Communications you send us, such as when you contact support, and any information contained in them.
• Payment information, if you purchase a paid feature. Payments are processed by Stripe, and your full payment card details are handled by Stripe, not stored by Telona.

2.2Financial Account Information from connected accounts (via Plaid)

When you connect an external financial account, you authorize Telona and our service provider Plaid Inc. to access that account on your behalf, on a read-only basis, to retrieve your transactions, investment holdings, and liabilities. Your online banking credentials are provided to and handled by Plaid, and Telona does not receive or store your bank or financial institution usernames or passwords. The connection cannot be used to move money. Plaid’s handling of your information is governed by Plaid’s end user privacy policy, available at plaid.com/legal.

2.3Information from SponsorCloud

If you create or connect your Telona account from within the SponsorCloud investor portal, SponsorCloud shares SponsorCloud Data with us at your direction so that it is available in your Telona account. SponsorCloud and Telona each act as separate controllers of the information they hold. This Policy governs Telona’s handling of the information; SponsorCloud’s own privacy policy governs SponsorCloud’s handling.

2.4Information we collect automatically

When you use the Service, we automatically collect certain technical information, such as your IP address, device and browser type, approximate location derived from your IP address, and information about how you interact with the Service. We collect this information using cookies and similar technologies, as described in Section 7.

3.How We Use Information

We use the information we collect to:

• provide, operate, and maintain the Service, including aggregating and displaying your investments, assets, liabilities, and net worth;
• provide performance tracking, projection, and similar features based on the data available to us;
• create and manage your account and authenticate you;
• process payments for paid features;
• respond to your requests and provide customer support;
• maintain the security and integrity of the Service, including detecting and preventing fraud and unauthorized access;
• improve, develop, and analyze the Service, including through the use of aggregated or de-identified data;
• send you administrative and service-related communications, and, where permitted, marketing communications you can opt out of; and
• comply with legal obligations and enforce our Terms of Service.

We do not use your Financial Account Information for any purpose other than providing and improving the Service and the purposes described in this Policy. We do not sell it, and we do not use it for advertising.

Aggregated and de-identified information. We may create de-identified and aggregated information from the data we collect, including by combining your information with that of other users. This information does not identify you or any individual, and we may use and disclose it for any lawful purpose, including to analyze and improve the Service, to present general trends and benchmarks within the Service, and for research and commercial purposes. We do not sell your Personal Information.

4.How We Share Information

We do not sell your Personal Information, and we do not share it for cross-context behavioral advertising or targeted advertising. We share information only as follows:

Service providers. We share information with third parties that perform services for us, such as account aggregation (Plaid), payment processing (Stripe), cloud hosting, analytics, and customer support. These providers may use your information only to perform services for us and are bound by contractual obligations to protect it.

Affiliates. We share information with SponsorCloud LLC and other affiliates as needed to provide and support the Service and consistent with this Policy.

At your direction. We share information with third parties when you direct or authorize us to do so.

Legal and safety. We may disclose information when reasonably necessary to comply with a law, regulation, legal process, or governmental request, to enforce our Terms of Service, to detect or prevent fraud or security issues, or to protect the rights, property, or safety of Telona, our users, or others.

Business transfers. If Telona is involved in a merger, acquisition, financing, reorganization, or sale of assets, your information may be transferred as part of that transaction, subject to this Policy.

5.Plaid

We use Plaid to connect your external financial accounts. By using the Service to connect an account, you grant Telona and Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide its services to us. You agree to your information being treated in accordance with Plaid’s end user privacy policy, available at plaid.com/legal. You can revoke access to a connected account at any time in your account settings; you may also contact Plaid directly regarding information Plaid holds about you.

6.How We Protect Your Information

We use commercially reasonable physical, technical, and administrative safeguards designed to protect the information we collect, and we limit access to personnel who need it to perform their duties. Connections to external financial accounts are tokenized and read-only, and we do not store your bank credentials. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping your login credentials confidential and for using secure networks and devices.

7.Cookies and Similar Technologies

We and our service providers use cookies and similar technologies to operate and secure the Service, remember your preferences, and understand how the Service is used. Strictly necessary cookies are required for the Service to function. Analytics cookies help us measure and improve the Service. You can control cookies through your browser settings, though disabling some cookies may affect functionality. Our Service does not currently respond to "Do Not Track" browser signals. Although we do not sell or share Personal Information, where required by law we honor recognized opt-out preference signals, such as Global Privacy Control (GPC).

8.Data Retention and Account Deletion

We retain your information for as long as your account is active or as needed to provide the Service, and thereafter as described below.

Deleting your account. You may delete your account at any time through your account settings or by emailing support@telona.co. When you delete your account, we will revoke the access tokens for your connected accounts and stop retrieving data from them, and we will delete or de-identify your Personal Information within ninety (90) days.

Information we may retain. We may retain a limited amount of information after deletion where necessary to comply with legal, tax, audit, or regulatory obligations, to resolve disputes, to prevent fraud and abuse, or to enforce our agreements. We retain this information only for as long as required and then delete or de-identify it. We may also retain aggregated or de-identified information that can no longer be associated with you.

Backups. Residual copies of your information may persist in our backups for a limited period and are purged on a rolling cycle.

SponsorCloud and Plaid. Deleting your Telona account does not delete information held by SponsorCloud or by Plaid. To address information held by those companies, please contact them directly using the information in their respective privacy policies.

9.Your Choices and Rights

Access and correction. You can review and update much of your profile information directly in the Service. You may also contact us to request access to or correction of your Personal Information.

Deletion. You may delete your account as described in Section 8, or contact us to request deletion of your Personal Information.

Connected accounts. You may disconnect any linked financial account at any time in your account settings.

Marketing communications. We may contact you by email, in-app push notification, and, where you have opted in, by text message. You may opt out of marketing emails using the unsubscribe link, opt out of text messages by replying STOP, or contact us at support@telona.co. We may still send you administrative or service-related messages about your account and the Service.

To exercise any of these choices, contact us at support@telona.co. We will verify your request and respond as required by applicable law.

10.U.S. State Privacy Rights

This section describes rights available to residents of U.S. states with comprehensive privacy laws.

10.1California (CCPA/CPRA)

The following table describes the categories of Personal Information we collect, the sources, and the categories of recipients with whom we may share it for a business purpose. We do not sell Personal Information and do not share it for cross-context behavioral advertising. Categories not listed below are not collected.

Category

Your California rights. Subject to certain exceptions, California residents have the right to know and access the Personal Information we collect, to request correction, to request deletion, to data portability, and to opt out of the sale or sharing of Personal Information. Because we do not sell or share Personal Information as those terms are defined, there is nothing to opt out of, but you may still exercise your other rights. We will not discriminate against you for exercising your rights.

10.2Other U.S. states

Residents of other states with comprehensive privacy laws may have similar rights, including the right to access, correct, delete, and obtain a portable copy of their Personal Information, and to opt out of the sale of Personal Information, targeted advertising, and certain profiling. Telona does not sell Personal Information, does not use it for targeted advertising, and does not engage in profiling that produces legal or similarly significant effects. To exercise your rights, contact us at support@telona.co. You may appeal a decision by replying to our response.

How to submit a request and verification. Submit requests to support@telona.co. Only you, or someone legally authorized to act on your behalf, may make a request. To protect your information, we will verify your identity by matching information you provide against information we hold, and by confirming the request through the email associated with your account.

11.Financial Privacy

Because Telona provides financial account aggregation, some of the information we handle is nonpublic personal financial information under U.S. financial privacy laws. We limit our use and disclosure of that information to providing and improving the Service and to the other purposes described in this Policy, we do not sell it, and we do not use it for advertising. This Privacy Policy serves as our financial privacy notice and contains the disclosures required under those laws. We share this information only with service providers, with our affiliates, and at your direction, so we do not share it in a way that requires us to offer you an opt-out.

12.Children

The Service is intended only for adults who are at least eighteen (18) years of age. We do not knowingly collect Personal Information from anyone under 18. If we learn that we have collected Personal Information from a person under 18, we will delete it. If you believe a minor has provided us information, please contact us at support@telona.co.

13.Where Your Information Is Processed

Telona is based in the United States, and your information is collected and processed in the United States. If we transfer information to service providers located elsewhere, we will maintain appropriate protections consistent with this Policy.

14.Changes to This Privacy 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 in the Service, by email, or by other reasonable means, and we will update the "Last Revised" date. Where applicable law requires your consent to a change, we will obtain it.

15.Contact Us

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

Telona LLC

7901 4th St N, Ste 300, St. Petersburg, FL 33702

support@telona.co

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